In late October 2018, food manufacturers recalled 4 million pounds of goods shipped nationwide to grocers and food distributors due to a Canadian shipper's recall of vegetables used in the affected products. Earlier in the year, a seed snack mix produced in the United States and shipped to Canada was recalled first in Canada and later in the U.S. for fear of contamination from Listeria, a harmful bacterial contaminant.
Such incidents are emblematic of the emerging challenge of managing shipments across borders. These issues only heighten the importance of supply chain visibility and improved control of shipments between our bordering nations.
The Food Safety Modernization Act (FSMA), implemented by the FDA, regulates safety of foods from farm to table. It applies regulations to keep food shipments free from contamination during transportation. The Sanitary Transportation of Human and Animal Food section, passed in 2011, governs the transportation of human and animal food. The intent of the Act is to curb transport practices that create food safety risks. Such risks may include improper temperature control of food shipments, cleanliness of vehicles (during or between shipments), and any failure to properly protect food.
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The Safe Food for Canadians Act (SFCA) parallels FSMA. These regulations focus on prevention by removing unsafe food from the market. The regulation is a streamlined consolidation of regulations that require licensing of food importers or exporters. In addition, the Canadian regulations serve as preventive controls to address food safety risk. They aim to shorten the time to remove unsafe food from the supply chain and trace it back to its origin.
As far as FSMA, the final rule applies to shippers, receivers, loaders, and carriers that transport food in the United States by motor or rail vehicle. This is independent of whether or not the food is offered for, or enters, interstate commerce. The rule doesn't include exporters shipping food through the United States when such food does not enter distribution channels in the country. Shippers that transport food from Canada to Mexico, for example, and do not stop and distribute in the U.S. are not subject to the FSMA. However, these are a minority of shipments. Many more are distributed in the U.S., as was the case in the October vegetable recall.
What does this regulation mean for food shippers whose business may cross U.S. or Canadian borders? For starters, it’s more confusing. Who is liable? Where did the shipment originate, and where was it discovered? What are the governing food safety regulations that apply? Do they fall under Canadian jurisdiction or the FDA’s? This conundrum can be greatly helped with fleet management technology.
The shortest distance between two points in such a challenge is not just knowing and understanding the scenario, the applicable regulations, and liability, but also using technology that can assist the process. When shippers use food safety solutions with functionality that monitors and proactively alerts about any environmental conditions that might cause food to degrade, it is a boon to the new transportation environment. If this technology is employed by using wireless sensors and monitoring, the data it produces is rapidly available and provides information to drive a quick decision and take the fastest action (much like what the Canadian food company had to do).
When issues arise where food at risk needs to be removed, the automated technology is the best solution to solve the problem. It is even more important because the Canadian and FSMA compliance can be confusing to shippers – given shipper’s responsibility accompanied by fear of liability they may hold.
When proper technology is integrated into the supply chain via truck, trailer, car, or other mode of transport, and such technology engages the regulations of all nations involved in the food trade, shippers can breathe a sigh of relief as they mitigate the risk and the problem as quickly as possible.
The merit of wireless supply chain technology is well illustrated in an incident that occurred in early 2018. Retail giant Target Corporation recalled frozen ready-to-eat and not-ready-to-eat meat and poultry products due to temperature abuse during transport. The root cause was supposedly the growth of spoilage organisms or pathogens on the food products.
The FDA, in their report of the recall, described the incident's outcome by stating: "The problem was discovered on March 27, 2018, when the company received temperature records of the shipment from the carrier. All inventory of the impacted items has been removed from the store and destroyed. Target notified FSIS on March 28, 2018, that the product from the shipping container had been temperature abused. How many food shippers can provide such rapid accountability?
Incidents of recall and the risk of regulatory non-compliance provide good reason to lean heavily on technology to provide the visibility as well as accountability, for shippers to operate in our North American (and beyond North American) food supply chain.
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