Insights - November/December 2017 - 28

Intermodal also is being helped because its largest refrigerated intermodal providers have accelerated the replacement cycle
for their equipment, Turner said.
Several executives said FSMA didn't require significant changes in their operations.

'Very Smooth Transition'
"We support FSMA. It was a very smooth transition," said
Zach England, chief operating officer of C.R. England, a carrier
that operates a fleet of 1,600 refrigerated containers. "Everything
that went into the final rule is quite similar to how we operated
before. We worked with the FDA. There was very little change,
only some minor tweaks for training."
Turner agreed. "We haven't had to do much differently because a lot of the necessary protocols were already in place with
our service providers," he said. Those protocols included internal
monitoring of temperatures, a running record of them, electronic
monitoring of door security, geo fencing and established relationships with food safety directors at the individual intermodal
providers.
Greg Sargis, who manages refrigerated shipments for 3PL
SunteckTTS, said, "FSMA was supposed to be a big deal. But
there has been nothing different." The company's export and domestic freight patterns haven't changed, possibly because shippers have made adjustments for any operational cost changes.
Consultant John Ryan, whose company does food safety audits and training, said a key issue under FSMA is traceability, over
and above cargo location tools. For example, there should be
records such as when a truck last was washed, what was carried
and what temperature variation there was during transit.

"We need to continue to educate
shippers, especially the small to midsized ones, about the value that exists
with refrigerated intermodal."
- Geoff Turner, CEO, Choptank Transport
"A lot of companies think having refrigeration is enough," Ryan
said. "But that doesn't necessarily give people access to data in
transit. It's easy to put tags on a container so people can monitor
freight condition."
However, he said there is still a significant lack of information on some international freight that is subject to FSMA. On
the other hand, he said, "Companies were way ahead. They have
procedures in place and are not impacted too much."

Still Some Concerns
There are particular concerns, Ryan said, from some, mostly
small, freight brokers who aren't aware of their responsibilities.
FDA decided during its review that brokers were considered to be
carriers because they were responsible for managing shipments
of perishables and other temperature controlled freight.
There still are gaps in compliance, Ryan said, because some
parties ignore the law, and anyone whose average annual revenue
is below $500,000 isn't subject to FSMA until April 2018.
Another challenge for intermodal is the fact that drayage carriers often don't want to handle produce shipments because the
pickup might consume four to six hours in loading and waiting

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28 Intermodal Insights | November/December 2017

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