3PLs work towards best practices on food safety; need government to better understand supply chain

by Canadian Shipper

WOODBRIDGE, Ont. — The International Warehouse Logistics Association’s Canadian chapter held its 5th annual spring conference in Woodbridge, Ont. April 16.

A major theme at the event was the current regulatory climate covering foods and chemicals and implications on warehousing and 3PLs.

Peter Wilson, president and CEO of Sunwill Distribution Center, in Buffalo, N.Y., and a member of the IWLA, said that the warehousing and 3PL will be greatly affected by regulations such as those coming under the US Food Safety and Modernization Act, which was signed into law in 2011.

In the US, he noted the Food and Drug Association said it is committing more staff over the next several years to roll out the requirements.

But Wilson said that the wording in these regulations “is not very precise” and in his opinion FDA does not yet have a good idea of how the whole supply chain works and how to implement these laws so they make sense.

Stakeholders such as 3PLS, warehouses, and the various food associations are currently working with the FDA on the verbage of the compliance requirements, said Wilson.

“The IWLA started its Food Security Council as a platform for promoting the 3PL value proposition: the safe, secure, and responsible handling of food,” he said.

Increasingly, he said, the large food processors expect 3PLs to work with them on policy solutions.

The IWLA aims to develop a ‘best practices’ document, as they have with respect with to C-TPAT, on how to handle the Food Safety Modernization Act.

One wording issue has been to define what is meant by ‘solely’ engaged in the storage of packaged food, noted Wilson, as those who are ‘solely engaged’ in this are generally exempt from preventive controls requirements.

“There is also a modified exemption for warehouses with refrigerated food,” he said.

The FDA tentatively concludes “it would be rare for a facility solely engaged in the storage of unexposed packaged food to not have infrmation regarding whether a food requires time/temperature control for safety and if so what specific temperature controls are necessary for the safe storage of the food,” he said.

Wilson said the 3PL and warehousing industry, along with food suppliers, are banding together to help FDA to create more exemptions.

“Six months ago there were few exemptions,” he said.

“We are also working with the FDA to figure out what temperature controlled storage is. The verbage on ‘solely’ has been put through but the comment is still open on the refrigerated processes,” said Wilson.

Another issue under consideration is the determination of when product is considered to be ‘transferred’ in a warehouse.

The FDA position is that a transfer occurs when transfer of physical possession takes place, but the IWLA has submitted comments to FDA that transfer occurs upon change of ownership, not a change in physical possession or control

Dave Saucier, Manager of Regulatory Government Affairs, with the Canadian Association of Chemical Distributors, stressed the importance of food safety in both Canada and the US.

“There’s a great opportunity for a responsible warehouse code of practice. We hope to see responsible warehousing implemented at least on the chemical side. Responsible warehousing should be adaptable to all your products,” he said, pointing out that even chemical cleaners used in a facility would be affected.

Canada’s Food and Drug Act, at almost 100 years old, is outdated and has undergone “lots of patchups,” said Saucier.

New iterations of IWLA’s code elements are now under way, with security adopted as a new and 8th code element requiring members to conduct risk assessment, develop or implement a security plan, train employees, and complete audits on continuous basis, he said.

In the US, meanwhile, the CFAT or Chemical Facility against Terrorism regulations are now under development.

“Transport Canada will have their version of this. We will have Transport of Dangerous Goods regulations as early as this year and enacted within a couple of years,” said Saucier. “In Canada we are 46 members importing up to 10,000 products going out to 100,000 customers. It’s very important to maintain the safety of our people, and the environment,” he said.

Securing product through the 3PL is currently “very challenging”.

“You don’t own that product, your customer doesn’t own the facility,” said Saucier.

So getting a unified safety standard is another one of the major challenges industry faces.

“From a lobbying perspective we’re starting to work toward getting regulatory harmonization in the chemical sector, in nanotechnology and in food ,” said Saucier.

Shipping and receiving are critical control points, he added, and weather is one of the top factors affecting the warehousing industry.

Over the next few years, Saucier said industry can expect there will be a lot of regulatory activity, coming from various levels of government, that will directly or indirectly affect warehousing and 3PL, including federal legislation like the Transport of Dangerous Goods Security Regulations, a Globally Harmonized System that will replace Health Canada’s Workplace Hazardous Materials Information System, Good Manufacturing Practices for pharmaceutical active ingredients, and Emergency Response Assistance Plans for public warehousing.

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