Transportation integrity

Among the regulations contained in the Bioterrorism Act (Public Health Security and Bioterrorism Preparedness and Response Act of 2002) are rules requiring those who transport, distribute, receive, and hold food to establish and maintain records. These requirements are designed to increase safety and security of the human and animal food supply.

With the requirements, the US Food and Drug Administration (FDA) is able to conduct an effective and efficient trace-back investigation in the event the agency believes an article of food is adulterated and poses a threat of serious health consequences or death.

Those recordkeeping regulations related to food transportation were touched upon in a discussion that was part of the Truckload Carriers Association Refrigerated Division Annual Meeting's session on Transportation Security - Keeping The Food Safe And The Truck Moving.

The regulations allow several recordkeeping options. Carriers and freight brokers can:

  1. Establish and maintain records specified in the rule themselves, including: — Information on the immediate previous source (IPS) and the immediate subsequent recipient (ISR)

    • Origin and destination points
    • Date shipment is received
    • Date shipment is released
    • Number of packages
    • Description of freight
    • Route of movement
    • Transfer points
  2. Establish and maintain records currently required by any one of the following:

    • US Department of Transportation's Federal Motor Carrier Safety Administration roadway bills of lading

    • US Department of Transportation's Surface Transportation Board rail and water bills of lading

    • Warsaw Convention's international air transporters airway bills

  3. Enter into agreements with non-transporter immediate previous sources or immediate subsequent recipients in the US to establish, maintain, or establish and maintain the required information. Agreements between transporters and non-transporter — those who own food or who holds, manufactures, processes, packs, imports, receives, or distributes food for purposes other than transportation — must contain:

    • Effective date

    • Printed names and signatures of authorized officials

    • Description of records to be established and/or maintained

The food transportation recordkeeping regulations spell out specific record retention time periods, based upon the shelf life of the food. For foods that have a significant risk of spoilage, loss of value, or loss of palatability:

  • Within 60 days after receipt or release of the food, the record retention period is six months.

  • From 60 days to six months after receipt or release of the food, the record retention period is one year.

  • Six months or more after receipt or release of the food, the record retention period is one year for transporters and two years for non-transporters

Records on all animal feed, including dog food, must be retained for one year. This applies to both transporters and non-transporters.

Additional information can be found on the FDA website. Its web page, www.cfsan.fda.gov/~dms/recguid4.html, contains a report on Questions and Answers Regarding Establishment and Maintenance of Records.

An Overview of Bioterrorism Act's Establishment and Maintenance of Records — Final Rule can be found at www.cfsan.fda.gov/~dms/fsbtac27.html.

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