FSMA Fridays: Sanitary Transportation Rule (Part Three Of Four)

View the entire webcast and read Part One and Part Two of this series

In part two of FSMA Fridays: Sanitary Transportation Rule, SafetyChain Software’s VP of sale, Dave Detweiler, was joined by The Acheson Group’s (TAG) Founder and CEO Dr. David Acheson to share insight on FSMA's Sanitary Transportation Rule including waivers and what companies should be doing if they are not ready for the rule. Here, in part three, the duo continues the conversation.

Dave: With every rule, there is some grey area. Reviewing them is obviously very important. What about waivers and how they might impact some of the companies as you're talking about whether you should or shouldn't?

Dr. Acheson: To me, the waivers sort of fit in with this new statement that came out of the FDA, this sort of guidance. I would call is a guidance document. It’s fact sheet more than anything else. The original rule did have some waivers in it. This little fact sheet has got again a little section on there about whether or not you're subject to a waiver. I think there are a few key areas to mention.

One is, and let me just to put this in context, is I think these waivers really are not waivers to say well we don't care about whether you're safe. The fundamental premise is if you're moving food and if you don't do it correctly you will create a food safety risk. The waivers are basically saying, "Well, you're actually covered by another rule. You’re not let off the hook for paying attention to food safety.” So the waiver isn't an exemption. I'm not trying to confuse people here. The exemption would be okay you just don't need to worry about that. The waiver is saying, let me just use an example, is grade a milk shipment. So there's a waiver associated with those. That's because essentially they're already under an inspection program from the national conference on interstate milk shipments. So it's not like you're off the hook. It’s like well you're already being covered by something else.