CCJ

November 2016

Fleet Management News & Business Info | Commercial Carrier Journal

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commercial carrier journal | november 2016 61 TECHNOLOGY: FOOD SAFETY Operating temps C.R. England's shipper contracts always have required clean and sanitary equip- ment and that proper temperatures be maintained. However, some of the new provisions in contracts for FSMA and STF compliance have been broad and unworkable, Hayes says. As an example, he mentions a contract that contained wording such as this: "If the carrier fails to deliver the product in accordance with shipper instructions, the product will automatically be deemed adulterated." e term "shipper instructions" is vague and "opens the door to a lot of things," Hayes says. "We've had to work with some customers to narrow the scope." One requirement in the rule is that shippers provide carriers with an operat- ing temperature for loads. Meeting that temperature during transit is a require- ment for food safety. While shippers traditionally have included the temperature in their bills of lading to ensure product quality, the FSMA and STF rule goes a step further. Violating the operating temperature for a load is defined as more than a quality issue; it is a food safety issue. "You are always going to get safety if you have quality," Hayes says. Now the same is true in the opposite direction; if a carrier exceeds the load's operating tem- perature, it will have to deal with not only a quality issue but also a food safety issue. As such, Hayes is concerned that shippers automatically might consid- er loads adulterated if a carrier fails to keep the operating temperature within a specific range during transit, such as "37 degrees Fahrenheit plus or minus two degrees." A load of carrots and a load of mayon- naise do not carry the same food safety risks for operating temperature, but car- rots do not become toxic if the tempera- ture falls out of range by a few degrees. Also, shippers might use a narrow operating temperature for a load of mixed commodities. What will happen if the trailer temperature for a mixed load of carrots and mayonnaise reaches 40 degrees in transit? "e narrower the operating tempera- ture, the more potential that the carrier is going to have a cargo claim based on an adulterated load," Hayes says. "[e FDA] is creating a situation where the shipper is inadvertently designating things as unsafe." Gearing up with technology Trailer telematics is a common technol- ogy for carriers to comply with shipper requirements and will become the same for FSMA. ese systems monitor and communicate data to and from trans- portation refrigeration units, including temperature and operating conditions. e STF rule states that carriers need to demonstrate they have maintained requested temperature conditions during transit, but only upon request. Tem- perature records are not a requirement for every shipment, Tucker says. Even so, telematics systems can provide such records with a few mouse clicks. Blue Tree Systems' single device plat- form, the BT500, is designed for tractor and trailer telematics applications. In the trailer, the device connects to TRUs from Carrier Transicold and ermo King to capture and transmit data to Blue Tree's online fleet management system. e device also can receive inputs from tem- perature probes and door sensors. For FSMA and STF compliance, fleet users can create a PDF or spreadsheet report of trailer temperatures during tran- sit and e-mail it to customers on demand. For more real-time visibility, fleets can give shippers login credentials to the online portal. As an additional compliance tool, Blue Tree is working to add a trailer washout program. Locations of commercial and noncommercial washes will be added to its online database for automatic record- ing of time that trailers arrive and depart from wash locations. Fleets will be able to Salt Lake City-based C.R. England, the nation's largest refrigerated carrier, is spending more time these days on regulatory compliance and food safety. C.R. England uses Orbcomm's trailer tracking and monitoring system that provides around- the-clock visibility to its assets without requiring a connection to tractors.

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