The Food and Drug Administration (FDA) issued an advance notice of proposed rulemaking (ANPRM) on April 30, 2010, that was the first step in writing federal regulations that will govern sanitary practices by all shippers, carriers by motor vehicle or rail vehicle, receivers and others engaged in the transportation of food for humans and animals. The FDA — which is taking this action as part of its implementation of the Sanitary Food Transportation Act of 2005 — is expected sometime in 2011 to develop and submit for public comment its proposed regulations to implement the law.
In his presentation “The Safe Food Transportation Act & Potential Regulations,” University of Kentucky food engineer Fred Payne described the milk security transport system he devised as part of a 2006 project commissioned by the Department of Homeland Security. Payne made his presentation during the National Tank Truck Carriers Cargo Tank Maintenance Seminar in Louisville, Kentucky.
The system developed at the University of Kentucky consists of a handheld device, a data server, and a processor-based system (called the Transport Monitoring System, or TMS) installed on the milk transport tank. The handheld device and server operate similarly to the system that UPS uses for identifying package pickups using barcodes. In this system, the driver identifies each dairy farm using a barcode and enters data at each farm where milk is picked up. The TMS monitors the electronic locks on the tank, the vehicle's GPS location, and the temperatures, and it automatically sends this information to the server via cell phone communications.
The first step in a bulk milk pickup is data collection at the farm. The milk truck driver inputs the required information about the collected milk into the handheld device, and the data is uploaded to the server. The information is then organized into security sessions, and the information for each truckload of milk is identified with a unique security session number. The security of the transport tank is maintained from the beginning of the cargo tank wash cycle to unloading at the processing plant. System hardware consists of electronic locks, temperature sensors, a user interface, and an auxiliary power supply.
CAN (controller area network) communication is used on the TMS, with one controller circuit board communicating with several node circuit boards to gather data from the locks and temperature sensors. Security data (such as lock position, temperature, GPS location, and power usage) are collected at one-minute intervals and transmitted automatically to the server. Communication protocols have been developed for the transmission and synchronization of the milk and security data between the handheld device, the TMS, and the data server.
After the milk has been unloaded at the processing plant, the data stored on the server can be viewed via an Internet interface. Users can easily view, print, and download a variety of forms and reports. A multitude of trace searches can also be conducted. For example, it's easy to assemble a list of all the dairy farms that contributed to given a silo of milk at the dairy processor.
“I project that the dairy industry will implement a data-management system, not for security but for traceability,” Payne said.
Also speaking at the seminar, Randy Sheeler, vice-president of operations at Herman R Ewell inc, said the challenges his company faces are no different than what the chemical industry faces — it's just that the food industry is a few years behind in the area of reloadable versus dedicated tank vehicles.
“The foodgrade industry has been predominantly dedicated,” he said. “The challenge we are facing now is, what is dedicated? What is reloadable? We've had a lot of challenges from shippers with respect to trailer configurations. A great example is the standard, vanilla trailer. In our industry, it's a 6,800-gallon tank with one domelid. But you can't haul chocolate in that type of trailer. Due to the viscosity of chocolate, the trailer must have two domelids because once you deliver and unload, the drivers are required to squeegee and push all that product out. The only way that can be done is with two separate domes.
“Another complication is that many of the loading racks we go to on the foodgrade side are designed for that single-dome trailer. So when you pull on the loading rack, the product is loaded in 20-25 minutes and you're gone. Well, now if you have two dome lids, you can't fit all the way on the scale. You have to pull up and back up. While we'd love to come back and say, ‘We'll buy all the single-dome trailers you have, and we're going to charge you a dedicated rate,’ … the response is, ‘Well, no, you can't charge us dedicated rates.’
“Foodgrade shippers and carriers also face a challenge because there are just too many areas to seal. The sealing issue is huge. If we go to a consignee and there is one seal off, the load is rejected immediately, no questions asked. And nine times out of 10, we (the carrier) own that product.”
In a related presentation, “Considerations for Food Grade Hauls in a DOT407,” Steve McWilliams of Walker Transport said the starting point in determining whether a product is a foodgrade hazmat is the Material Safety Data Sheet (MSDS), which typically will have foodgrade in the description. He said the CFR 172.101 Hazardous Material Table will not specifically list material as foodgrade.
McWilliams said operating the correct equipment is important because of the issues related to the changes in the Sanitary Food Transportation Act of 2005.
“Failure to comply with the sanitary transportation practices means the carrier is subject to sanctions and penalties,” he said.
His tips for specifying a foodgrade DOT407:
Trailers must, at a minimum, comply with: DOT407 specifications and FDA “indirect food additive” requirements for non-metal material in product contact areas. Trailers dedicated to foodgrade service are to be put into foodgrade service the first day the trailer leaves the manufacturing plant, and companies should not convert trailers that have hauled other material into foodgrade service.
- Product contact material
Material should be chosen based on compatibility with the products being hauled. Barrel, heads, and piping are stainless steel (316L common, other options available). Rubber gaskets (manhole, transfer hose, etc) should be white in color for ease of inspection, and there should be written certification from gasket manufacturers that gaskets comply with FDA CFR Title 21, Paragraph 177.2600 (“Rubber articles intended for repeated use”).
Pump, vent, and valve material should be stainless steel in product contact areas, avoiding carbon steel and aluminum (pitting). With transfer hose assemblies, non-metal material in product contact areas must comply with the appropriate section of FDA CFR Title 21, Paragraph 177. 3-A certified products, if available, will always meet FDA requirements and are designed for ease of cleaning.
- Trailer construction
No baffles due to cleaning issues. The interior weld finish should be W4 to W5, and weld finishes that could create product traps should be avoided. Avoid pipe thread connections if possible due to a potential product trap.
Seal points and every opening need to be substantial for cabinets, dome lid, venting, and transfer hose carriers. Review everything on the trailer for ways to potentially tamper with the product and eliminate the vulnerabilities.