Keep on Truckin’ : Transportation is often the missing link in the food safety

April 20, 2006
FOODLAW
Ronald L. Doering

With all the talk about food safety systems from farm to fork and traceability all along the food chain, it’s surprising how little attention has been devoted to one key part of the food chain - transportation. We now have on-farm HACCP and traceability systems in nearly all food processing facilities, in warehouses and in many retail distribution outlets.

Whether produced in Canada or abroad, food travels hundreds or thousands of miles and passes through many hands to reach our grocery store shelves. But what do we really know about food safety standards as the product travels from the producer to the processor, from the processor to the distributor, from primary processor to secondary processing, from distribution to retail, or in the delivery van from retailer to consumer? Fragmentation of jurisdiction is one reason for the absence of a coherent regulatory regime. Canada’s constitution does not allocate transportation to any specific level of government, and court decisions have resulted in a veritable patchwork of regulations. Municipal, provincial and federal regulations oversee different aspects of transportation systems across all modes, but there has been little attention devoted to food safety.

Domestically, the most coherent regulatory regime we have is for live animals, particularly rules relating to the humane transportation of animals. The Canadian Food Inspection Agency (CFIA) has a very comprehensive regime that is currently undergoing significant reform, but there is also a confusing array of provincial rules relating to the transportation of animals to provincial slaughter facilities. There are detailed regulations relating to bringing live animals to federally registered facilities, but very few regulations for the meat leaving the same facility on its way to secondary processors or retail outlets.

In addition, Canada now imports food from over 100 countries, all of which must be transported here by boats, planes, trains and trucks. But recent food security concerns have highlighted how little actual control or knowledge there is about transporting agricultural products and food across borders. At the same time, the U.S. Bioterrorism Act has created major new requirements for products going into that country.

It won’t surprise anyone who travels our major highways to le- moving within Canada and North America. In fact, every day Canada gets 6,000 truckloads of food from the U.S. alone. Happily, the trucking industry has not yet been identified as a significant source of contamination of food-borne illness. However, the Canadian Trucking Alliance (CTA) is being proactive by developing with the CFIA an innovative HACCP-based Trucking Food Safety Program that meets the food safety requirements of food industry shippers. The CTA’s approach has been to develop a "core program" with the food safety building blocks relevant to all trucking companies, and then develop a series of commodity-specific modules depending on the needs of individual carriers. The core program has very specific food safety prerequisites and detailed standard operating procedures, as well as rigorous annual audits.

"HACCP is the wave of the future," says Ron Lennox, the CTA’s vice-president of Regulatory Affairs. "We wanted to ensure the trucking industry was ready to meet the increasing demands of our clients." Baden, Ont.-based Erb Trucking was one of the first companies to sign up. "It’s a further service to our customers, assuring them of the finest possible protection for their food shipments," says owner Wendell Erb, explaining the benefits of the program. Other benefits of the Trucking Food Safety Program include: being able to show your customers that you have taken all reasonable steps to ensure food safety within your transportation systems; cost savings from reduced risk of recalls and product destruction, streamlined procedures, and fewer expensive food safety incidents; the ability to demonstrate best practice policies and procedures with clear, comprehensive, yet easy-to-use documentation; minimizing your exposure and liability by identifying and controlling your food safety risks using scientifically established and operationally proven control points; and improving your ability to transport food products across the Canada/U.S. border.

It’s clearly an idea whose time has come. To date only a few trucking companies have been approved, meaning there is a real opportunity for those trucking and food companies that want to be industry leaders. Kasar Canada acts as the program registrar. For more information, see Kasar’s website at www.kasarCanada.com.

Ronald L. Doering, BA, LL.B, MA, LL.D, practises food law in the Ottawa offices of Gowling Lafleur Henderson LLP. He can be reached at: ronald.doering@gowlings.com