• Requirements for vehicles, transportation equipment, operations, training, and records are all addressed in the STHAF rule.
• Though the shipper is ultimately responsible for transportation operations, those responsibilities might be assigned to the carrier.

The Sanitary Transportation of Human and Animal Food (STHAF) rule is found in 21 CFR Part 1, and covers vehicles and transportation equipment, transportation operations, training, and records.

Vehicles and transportation equipment

Vehicles and equipment (totes, bins, tanks, pallets, pumps, hoses, etc.) used to transport food must be designed and maintained to be suitable for transportation of food products and cleanable. The trailer and equipment must be kept sanitary at all times to prevent food being transported from becoming unsafe, contaminated, or adulterated.

If the food being transported requires temperature control, the equipment used must be designed, equipped, and maintained to provide adequate temperature control during transport.

Finally, the vehicle and other equipment must be maintained and stored to prevent the harboring of pests (bugs and rodents) or becoming otherwise contaminated. For example, any exposed insulation or other interior damage must be repaired immediately. Wooden floors and walls should be avoided due to sanitization and cleaning issues, as well as splinters.

Transportation operations

If food being transported fits into one of the categories requiring compliance, such as food not completely enclosed in a container or food requiring temperature control, the shippers for which a carrier or driver routinely hauls food must be contacted to see what procedures are required. Current practices will need to be reviewed to see how they compare with what the regulations and shippers require.

Also, be prepared to develop one’s own procedures and driver training related to inspecting and cleaning the inside of vehicles that transport food, avoiding contamination and cross-contamination of food shipments, precooling vehicles, and monitoring and recording temperature-controlled shipments.

The shipper is ultimately responsible but can assign responsibility to the carrier to ensure that:

• Shipper requirements for cleaning and sanitation are met.
• The vehicle and equipment meet the shipper’s specifications and requirements.
• Precooling the vehicle or equipment occurs before loading, if required (the shipper should verify that the temperature is correct before loading).
• Effective measures are taken to avoid contamination or cross-contamination.
• Food is isolated or segregated to avoid contamination by raw food products or non-food products that are part of the same shipment.
• Temperature control and monitoring requirements provided by the shipper are met throughout the trip and proof is provided, if requested. The proof (mechanical temperature tracking, a temperature log completed by the driver, etc.) must meet the shipper’s requirements. Avoid loading two different foods with separate cooling requirements for an extended period.
• Information is provided to the shipper about the previous product carried in the vehicle, if the vehicle is a “bulk vehicle” (a vehicle that carries bulk shipments that are in direct contact with the inside of the vehicle) and the shipper requests the information.
• Proof is provided as to the most recent cleaning of a bulk vehicle, if requested.

Loaders and drivers should never reuse dunnage that is likely to contaminate food and should practice good hygiene habits. These include washing hands, wearing beard nets, and wearing sanitary clothing as required by the customer.

Loaders must inspect the vehicle and transportation equipment to ensure sanitary conditions and that the trailer has been adequately precooled.

Receivers must do the following upon receipt of temperature-sensitive foods:

• Determine if there was any temperature abuse in-transit,
• Check the food and vehicle’s temperature, and
• Smell for odors.

Carriers must also have written procedures covering:

• Cleaning, sanitizing, and inspecting vehicles and equipment;
• The process to monitor and record temperature of a shipment; and
• The process to maintain and provide records related to the last shipment and most recent cleaning of bulk vehicles.

Notification of possible unsafe food

If the shipper, loader, carrier, driver, or receiver becomes aware of a failure in the measures to protect the food (such as a temperature deviation or cross-contamination), and the failure caused the food to be rendered unsafe, that party is responsible for notifying the other parties involved. The shipment can no longer be sold or distributed as food. The only exception is if a qualified individual can determine that the temperature deviation or other problem did not actually render the food unsafe.

Training

The shipper is responsible for training drivers transporting food, unless the shipper’s written agreement with the carrier requires that the carrier provide the training, which must include:

• An awareness of potential food safety problems that may occur during transportation,
• Training on basic sanitary food transportation practices,
• Instruction on requirements of food safety regulations, and
• Training required upon hire and then as needed thereafter. The carrier will be responsible for maintaining records of the training, and records must include the driver’s name, the date, and the topic.

Records

Shippers and carriers are required to create and maintain specific records related to food shipment. Carriers must maintain records of:

• Any written agreements related to procedures or responsibilities assigned to them by shippers. These must be kept the entire time they are in effect, and then for an additional 12 months.
• Procedures that a carrier is required to have under the regulations, or required by a shipper to have and/or follow under terms of an agreement. These must be kept the entire time they are in effect, and then for an additional 12 months.
• Individual driver training records, which are to be kept the entire time the driver is involved in food transportation, and then for an additional 12 months.

The records can be paper or electronic. They must be made available within 24 hours if requested by an authorized individual. However, procedures related to cleaning and inspecting vehicles and equipment must be available at all times onsite where the vehicles are loaded.

It is advisable to review driver training and processes for compliance with the regulation. Also, contact major shippers to understand their requirements for inspection, cleaning, contamination avoidance, precooling vehicles, and recording temperature of shipments.