The Food and Drug Administration (FDA) is seeking comments on an advance notice of proposed rulemaking (Docket No. FDA-2010-N-0013—Implementation of Sanitary Food Transportation Act of 2005), in regards to the safety of foods during transportation. The FDA is also requesting data and information on food transport practices, contamination of transported foods and any associated outbreaks. FDA is taking this action as part of its implementation of the Sanitary Food Transportation Act of 2005, which requires the issuing of sanitary regulations to be followed by shippers, carriers by motor vehicle or rail vehicle, receivers, and others engaged in food transport. This action is also part of a larger FDA effort to focus on prevention of food safety problems throughout the food chain.
Recent US incidents involving food transport as a source of contamination include:
a) The contamination of corn gluten used in dog food while transported in a rail car in 1974. The corn gluten was determined to have been transported in a rail car that had been previously used to transport lead monoxide. Samples taken of the dog food in which the corn gluten was used revealed that it was contaminated with lead monoxide at levels ranging up to 28,000 parts per million. This case was investigated after FDA received reports of several sickened dogs.
b) The contamination of soybean hulls (used as animal feed), contaminated by barium carbonate in 1989. The aforementioned chemical is used in rat poison and paint. The contamination occurred in a rail car that had previously been used to transport barium carbonate.This incident resulted in the deaths of dairy cows in herds from both Louisiana and Texas, and high levels of barium carbonate were detected in milk from two of the affected herds by the State of Louisiana.
c) Several reports of some trucks that hauled garbage from the New York/New Jersey area to Midwestern landfills, and that were used subsequently to carry meat, poultry, and produce.
d) In 1994, a large multi-state outbreak of salmonellosis was associated with an ice cream mix that became contaminated during transport in tanker trucks that had previously hauled raw liquid eggs.
e) In 1999, an outbreak of Salmonella Muenchen occurred in 15 States and 2 Canadian provinces with more than 300 cases reported. The product was fresh orange juice, a portion of which was imported. Several serotypes of Salmonella were isolated from tankers used to carry the juice .
f) In 2007, the Motor Carrier Division of the Michigan State Police reported 22 cases of illegal and unsafe food transport on Michigan highways during 2006. The findings included:
-Raw poultry hanging from the roof inside the cargo area of a truck, with juices dripping onto open boxes of produce below, and with juices from the raw poultry dripping out onto the pavement from under the rear cargo box doors. The food was being transported in an unrefrigerated truck with an internal temperature greater than 21 degrees celsius;
-Truck(s) with no refrigeration unit;
-Truck(s) with the refrigeration unit turned off or not working; and
-Truck(s) with a working refrigeration unit that was not set at the correct temperature
g) In 2009, peanut butter and peanut paste were confirmed as the source of a large multi-state outbreak caused by Salmonella Typhimurium.The firm recalled a large number of its products, including products distributed in 1,700-pound tanker containers, because the products had the potential to be contaminated with Salmonella.
Although there are no less than 15 FDA regulations and guidance document that include points to be considered in the transportation of foods, there are only three guidance documents that specifically address the transport of foods: 1)Guidance on Bulk Transport of Juice Concentrates and Certain Shelf Stable Juices; 2) Guidance on Food Security Preventive Measures for Dairy Farms, Bulk Milk Transporters, Bulk Milk Transfer Stations, and Fluid Milk Processors; and 3) Guidance on Food Security Preventive Measures for Food Producers, Processors, and Transporters.
A few of the questions posed by FDA to the industry are:
-What are the amounts and percentages of foods that are transported completely enclosed by packaging, not completely enclosed by packaging (e.g., grain, some fresh produce items), or in bulk tanks (e.g., juices, oils)?
-What proportion of vehicles is exclusively dedicated to transporting foods? What proportion of vehicles transport both food and non-food products?
-What industry standards exist for the cleaning of food transportation vehicles?
-How is the adequacy of cleaning vehicles (including bulk vehicles and non-bulk vehicles) assessed?
-What procedures and practices are in place to prevent contamination of foods not completely enclosed by packaging during transport?
-How are the physical integrity and physical security of a food transport vehicle ensured during its run?
-What procedures and practices are in place to ensure temperature control for time/temperature control for safety foods?
-What types of food products are typically transported simultaneously?
Having performed some assessments in perishable supply chains that require answers to these questions, I think that the task of FDA is huge.
In Australia, there are no reliable statistics on food poisoning outbreaks caused by unsafe transportation. Of particular concern are imported ingredients and products: for many of these, the supply chain is so complex that no effective trace back is possible. For example, 14 outbreaks of foodborne disease were linked to imported foods between 2001 and 2007. In 2009, a multi-state outbreak of hepatitis A was associated with semi-dried tomatoes. Trace back of semi-dried tomatoes consumed in Victoria revealed a complicated supply chain with multiple suppliers to multiple brands and imported product that may be mixed or re-packaged for sale. The OzFoodNet Working Group suggested improvements to the documentation of the supply and distribution chain of tomatoes and other components used for the production of semi-dried tomatoes in Australia.
Naturally, an integrated electronic traceability program would be much more effective than simply improving documentation flows. A full example of implementation for fruit and vegetables is given in the PMA website.