Most of the transportation industry knows about the Food Safety Modernization Act (FSMA) and its seven protective rules designed to ensure the safety of the U.S. food supply. Of those rules, the Final Rule on Sanitary Transportation of Human and Animal Food has the most direct impact on shippers and carriers, and its compliance deadline of April 6 is just days away. Many companies complied long ago, but others remain unprepared. Is your company ready? If you don’t know, understanding the rule is a good place to start (

What is the Rule on Sanitary Transportation of Human and Animal Food?

This rule establishes comprehensive federal requirements designed to protect food from contamination while it is being transported by motor vehicle or rail within the United States. Standards address transportation vehicles, equipment, operations, communications, training, and record keeping.

Who must comply with the rule? Am I exempt?

Nearly everyone with a role in transporting food within the U.S. must comply, including shippers, loaders, carriers, and brokers — and even receivers of shipments, such as grocery/convenience store retailers and food services companies. While the rule excludes ocean and air transport, intermodal shippers must be careful to comply for land-based segments of routes.

The FDA does plan to issue waivers for some packaged-food companies, and those firms that comply with other established regulatory standards that ensure food safety.

Exemptions are few, but may extend to:

  • Small companies with less than $500,000 in average annual revenues
  • Parcel delivery services
  • Exporters shipping food through the country, but without distributing in the U.S.
  • Companies that pose no risk to food safety without violating public policy (

What are the requirements?

Requirements differ for carriers and shippers. Carrier requirements address:

  • Vehicles and Equipment. Along with their use and maintenance, vehicles and equipment must be designed to protect food while in transit.
  • Sanitary Procedures. Carriers must create robust procedures that address proper temperature control of shipments, separating certain foods, avoiding cross-contamination, adequate cleaning between loads, and sanitary container/equipment storage when not in use.
  • Training. Carrier personnel must undergo training to uphold sanitary practices and complete required documentation.
  • Record Keeping. Depending on the activity, carriers must retain up to a year’s worth of detailed records for training, procedures, and agreements.
  • Temperature Monitoring. The carrier and shipper must agree to a temperature-monitoring mechanism for foods that require temperature control; and the carrier must be able to demonstrate that temperatures were maintained upon the shipper’s request.

Shipper requirements focus on the written instructions and specifications they must provide to carriers to ensure the safe transportation of their food. Every shipment requires specs, which must address all relevant areas:

  • Temperature control specs and requirements for monitoring temperatures during transit
  • Cross-contamination control instructions
  • Loading and unloading instructions
  • Sanitary requirements, such as hand washing, equipment and vehicle cleaning between loads, equipment storage, etc.
  • Personnel training on sanitation and proper documentation
  • Additional processes required when a company acts in multiple capacities (e.g. manufacturer and shipper and carrier)

Ready or not, here it comes

The Sanitary Transportation of Food Rule requirements are designed around current best practices, so most transportation companies won’t have to undergo major changes to comply. If you have any questions around the FSMA and how it may impact your business, contact our team of experts or visit the FDA and US Food and Drug Administration website.

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