Are you familiar with all the acronyms in the food safety world like FSMA, STHAF, FMCSA, DOT HOS, ELD?
Do any of these make you feel good about your business or do they raise concerns? Do any of these acronyms create a concern for your business operations and your ability to control costs, supply chain levels, etc.?
In fact, most food businesses we work with on a daily basis seem to become more frustrated with some or all of these topics because everyone interprets them differently. These acronyms all lead down the same road of ensuring the safety of the food supply, from farm to fork. These items all have the same goal in mind, safety. Every one of them seems to become more difficult when implemented in the daily activities of business operations, yet, it is our obligation as business leaders to navigate these struggles and find the best alternative solution for each specific business.
Before we continue on this topic, the common acronyms should be explained.
FSMA – Food Safety Modernization Act; an exceptional change when it comes to the safety of the food supply and it has constrained or opened areas for interpretation. In principle the FMSA is a starting point, it was created to ensure the chain of custody for the food supply, and is responsible for holding every party accountable for understanding the proper process and creating standards for safe food handling. This act further guides the process in which carriers, brokers, shippers and receivers must manage food supply throughout the supply chain.
STHAF – Sanitary Transportation of Human and Animal Food; another step in ensuring farm to table food safety while in transit for over the road or rail within the United States.
FMCSA – Federal Motor Carrier Safety Administration enacted several recent regulations constraining the hours of operations for truck drivers, it has implemented electronic logging devices within each vehicle and allows officers and regulators to view drivers time behind the wheel in real-time. These constraints reduced the number of hours that drivers were behind the wheel vs what some drivers stated they were behind the wheel. Impacting the supply chain, these items compressed the further concerns of driver shortages within the trucking industry. Driver’s times have affected how long drivers can sit at any given location or to begin to charge accessorial fees for detention and layovers. These costly accessorial charges have been passed around from carriers to brokers to shippers and back to the buyer of the goods.
DOT – Department of Transportation; this is the department that has direct oversight of the FMCSA. DOT officers, state troopers, and highway patrol officers are those who inspect the drivers, their logbooks/ELD logs, review drivers’ scales ensuring drivers are not carrying too much product for roads and bridges as well as reporting and inspecting vehicles for safety throughout the US.
HOS – Hours of Service; this is the rules by which carriers and drivers must operate by. The HOS dictates when drivers may drive, when they must be on break (after 6 hours of consecutive on duty states but not longer than 8 hours), when drivers must shut down and reset their clock by resting a minimum of 10 hours per shift, and upon completing 70 hours drivers must reset for 34 hours consecutively or they are in violation. This has been tweaked over time but has been used and is not new. These rules are meant to keep the driver from being forced into driving tired or pushing themselves too far and causing serious accidents. The ability for drivers to be properly rested and not forced or stressed to be somewhere without proper rest is the focus of HOS rules. What is new is the electronic logs that are in real-time. This has been the game-changer for drivers and some smaller carriers.
ELD – Electronic Logging Device; the device installed in the truck and collects actual data from the truck cab that enables drivers and carriers to view their hours of operation in real-time. This has limited drivers from running multiple logbooks and cheating the system. Some or most of drivers/owner-operators of smaller carriers usually had their own interpretation and was different from company to company along with drivers who really didn’t use logbooks.
So how do all these acronyms play a part in the supply chain and how does this affect the safety of transportation? Recently, while getting back into the industry, as I was a consultant for trucking companies over the past 3 to 4 years, I have found all these seem to roll out within a few years of each other and are high priorities by each governing body. Food safety has been at the forefront of the transportation industry for several years to ensure there is no contamination or potentials for tampering with the food supply while food is in transit. Again, all these different regulations are meant to make safety the priority regardless of the area of focus; SAFETY is key in all areas. What are food shippers being impacted by today if every measure is to ensure that each segment of the industry is safer? Simple, it is time and pressure! Why pressure? The pressure is being implemented on all parties. When the driver shortage began carriers refused to stay at any place for long durations when there is an average of 10 loads per truck in any given market. So, carriers not being loaded or unloaded within a regular 2-hour time limit began to strain the market place by raising detention charges/ layover charges so high that shippers pressured warehouses to improve processes. This pressure also goes the other way, when trucks are running behind because of loading delays, weather, etc. then shippers and receivers are less accommodating to the drivers because they can’t get off track with the carriers/drivers who are on time. This process further compounds with food safety when you have the perfect storm of food commodities that have loading concerns; trailers not properly cleaned, not properly sanitized, trailers with odors, etc. An example of the perfect storm is a driver that hauls a load of fresh meat, they must clean and sanitize their trailer before being loaded with another food product to protect from cross-contamination or some sort of loading prohibition. Shippers who receive a driver and trailer that does not meet their specifications will reject the trailer and send the driver to the wash to attempt to clean the trailer or sanitize the trailer again. We have seen trailers sanitized 3 to 4 times before meeting some shippers requirements due to odors or some other issue. There is nothing wrong with doing the right things right, but due to the pressure of the companies trying to stay in compliance, it is easier to reject the trailer. This also compounds because drivers are so tight on time from one load to another that trailer cleanings have become less likely as shippers times and deadheads have played significant roles in the process. When time is everything and timing is becoming more costly it is critical that communications also improve.
So, what is the answer? It seems that these regulations are all in place to make things safer, yet they are more costly to our bottom line and are increasing our accessorial charges and pass-through costs. The answer to me is the ability for companies to effectively communicate and work together. Food Shippers of America is continually using their association to promote Shippers of Choice. What is that you might ask – That is any shipper who is using these data metrics and implementing processes and procedures to work with real-time information and make adjustments to ensure that we are continually changing and adapting to things in real-time. At Becker Logistics our CEO Jim Becker has a saying, “If Nothing Changes, Nothing Changes.” This is true with all regulations, we have to adapt together and work together, not draw lines in the sand and continually penalize each other, but work together to ensure that safety (one of our core values) is met and achieved by all parties. Using data allows shippers to see a truck is running late, and instead of refusing to load them they move a truck into their slot who might be earlier and continue to do so till that carrier arrives. Some of our customers are beginning to use similar processes but not all understand the importance of working together. We still see companies drawing lines in the sand and stressing drivers and carriers on time because they feel they are wronged by the driver or carrier. In today’s industry, with the increase of regulations and safety at the forefront, we must all begin to step back and ask how can we work together and not point fingers or assign fault. We are in logistics and it is our ability to adapt and overcome because if “Nothing changes Nothing changes.”