Security and Load Integrity in Refrigerated Transport

1
Security and Load Integrity inRefrigerated
Transport

• TCA Refrigerated Division
• Annual Meeting
• July 10-13, 2007

2
Agenda

• Brief overview of Bioterrorism Act recordkeeping
  regulations related to food transportation
• Maintaining load integrity
• Further discussion

3
Bioterrorism Act of 2002

• Final rule published in December 2004
• Recordkeeping requirements apply to organizations
  involved in the transportation of food, among
  others.
• Food generally means anything under FDAs
  jurisdiction, with some exclusions.

4
Definitions

• Transporter Person who has possession, custody,
  or control of an article of food in the U.S. for
  the sole purpose of transporting the food,
  whether by road, rail, water, or air.
• Includes a foreign person that transports food in
  the U.S.

5
Definitions

• Non-transporter Person who owns food or who
  holds, manufactures, processes, packs, imports,
  receives, or distributes food for purposes other
  than transportation.
• Basically, the requirements apply to carriers and
  freight brokers, but not to customs brokers.

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Options for recordkeeping

• Transporters can establish and maintain records
  specified in the rule themselves, including
  information on the immediate previous source
  (IPS) and the immediate subsequent recipient
  (ISR).

OR
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Options for recordkeeping

• Transporters can establish and maintain records
  currently required by any one of the following
• Roadway bills of lading (FMCSA)
• Rail and water bills of lading (STB)
• Airway bills (Warsaw Convention)

OR
8
Options for recordkeeping

• Transporters can enter into agreements with
  non-transporter IPSs or ISRs located in the
  United States to establish and/or maintain the
  required information.

9
Retention periods
Food having a significant risk of spoilage, loss
of value or loss of palatability within
60 days 6 months gt60 days 1 year Animal feed,
including pet food 1 year
10
Additional resources

• FDA QA on recordkeeping www.cfsan.fda.gov/dms/r
  ecguid4.html
• FDA overview on recordkeeping www.cfsan.fda.gov/
  dms/fsbtac27.html
• For meat/poultry/egg transport, see
  www.fsis.usda.gov/PDF/Transportation_Security_Guid
  elines.pdf