Hitching a ride is as old as conveyances. From haycarts and horses to cars and trucks, an extra rider here and there has long been carried.

Riders include more than people trying to spare their feet for a bit. Transport goods from one place to another by any method and expect to also carry everything from cockroaches and rodents to microorganisms.

Cleaning ensures that conveyances are inhospitable to the riders no one wants, but it doesn’t make them sterile. The U.S. Food and Drug Administration (FDA) has enforcement responsibility for the transportation of human and animal food (21 CFR Chapter 1). And the FDA requires that vehicles and transportation equipment (e.g. freight trailers) be built and maintained in a way that prevents food from becoming unsafe.

Contamination, temperature fluctuation, and pest infestation are among the things that maintenance must prevent. Obviously, cleaning is part of the protocol.

The FDA derives authority for rules about transport from the Food Safety Modernization Act (FSMA), which builds on the Sanitary Food Transportation Act (SFTA) of 2005. Other rules also build on SFTA.

That’s the nugget account of the FSMA, which we will detail a bit more in the next section. Everything written about the key requirements here is up to date through October 17, 2023, which is the last CFR update to the rule available as we write.

It’s not only the FDA that takes an interest in clean freight trailers. The Environmental Protection Agency (EPA) regulates aspects of cleaning, for instance. In the next section we will also consider some of the rules from the EPA that have relevance.

With or without regulations, customers would want to keep their freight trailers clean. No one wants to send a load of anything in a soiled space.

So cleaning is a given. Which part of the job is most challenging—type of soiling, scheduling, etc.? “From what our customers say, the number one challenge is the labor to do this type of cleaning,” says Jason Rhoads, director of marketing at Whiting Systems in Alexander, AR.

“Even if the best employees are hired, you will often still have inconsistent wash methods,” explains Rhoads. “Washing and cleaning are different than the sanitizing or disinfecting that these refrigerated haulers are mandated to achieve.”

It takes a member of a cleaning and sanitizing team with a commitment to a methodical approach to achieve the best results possible. That alone, though, might not be enough.

“The current wand-style pressure-wash process just has not been capable of being consistent,” says Rhoads, and that’s where his company aims to provide a faster and more reliable option.

“Our autonomous interior trailer washout gives food haulers constant quality every time,” says Rhoads. The system combines “documentation, automation, and consistent quality that reduces labor cost.”

The system Rhoads cites gives fleet owners the wherewithal to do their own cleaning. That’s a boon to many because “outsourcing has its own set of challenges, including scheduling, dependency, and cost.”

With its decades of experience in helping owners of tractor trailers with cleaning and sanitizing, Rhoads’ company knows that there are differences of opinion on best approaches.

For example, Rhoads’ company offers a disinfecting system that is state of the art. “The unit has the ability to fog/mist the entire trailer at 15–20 microns with a newly developed misting system. It also has the ability to “old school” apply the much more aggressive Quats [quaternary ammonium compounds] and ClO2 [chlorine dioxide] on the floor as our competitors do.”

“Autonomous has become the word that is being adapted in every industry with huge acceptance,” says Rhoads. That includes the industry that his company serves.

“The interior trailer washout—‘SmartWashout’—developed by our company is patented technology that assists with every aspect of consistently keeping the inside of a freight trailer clean and sanitized,” explains Rhoads.

“The Food Safety Modernization Act requires documentation, and our system assists in taking that workload off of safety directors,” says Rhoads. “The system is metered, also showing a huge efficiency over the ‘old-school’ method.”

The autonomous system Rhoads describes does more than produce an excellent outcome. “We have seen a reduction in power, water, and labor with business case studies. These reductions in cost and increased efficiencies improve bottom line savings year over year.”

Rhoads’ company designs its equipment with the needs of the end-user in mind. To ensure the longevity of its systems, it uses food-grade T304 stainless steel. It formulates chemicals in adherence with all environmental regulations. And, it ensures the most accurate chemical delivery with sophisticated control systems. The systems offered by Rhoads’ company can handle semi-truck trailers and more (e.g., flatbeds, tankers).

REGULATIONS

Phoresy may or may not sound menacing. The word comes from the Greek word phorein (to carry). In the biological sphere, phoretic organisms are those that link themselves to others in a casual or serious way to move from place to place.

Each of us carries other organisms around, particularly microorganisms. Our dogs carry fleas, and so on. It’s just a given that any container or palletized load put in a freight trailer is going be carrying something besides what’s being shipped, whether it’s an errant mouse, an insect, or a virus.

Regulations derived from FSMA are designed to keep phoresy from getting out of hand. A few phoretic organisms are to be expected. A great number are a problem for health and safety.

The FSMA covers shippers, receivers, loaders, and carriers who transport food in the United States by motor carrier or rail. It does not cover carriers that only transit through the United States (e.g., Mexico to Canada) without distribution.

Parameters for temperature inside trailers, structure of trailers (e.g., must be amenable to appropriate cleaning), training for carrier employees, and records to be kept are all delineated as requirements of the FSMA. But, again, the FSMA does not apply to all carriers.

Carriers of food that is imported for future export, for example, are not subject to the same regulations as carriers that transport food for U.S. consumption. Certain categories of food, such as meat, poultry, and eggs, are regulated by other acts and departments in a manner that supersedes FSMA rules.

Moreover, waivers are granted under FSMA. The explication for a waiver (section 1.914 of Subpart O of 21 CFR) is a little vague—i.e., whatever regulators determine deserves exemption.

Complicated? Yes. The most recent (October 17, 2023) update of the rule runs to nine printed pages.

Think of it in reverse. The regulations stemming from the FSMA do everything possible to configure a food carrier sector that inhibits the tag-alongs or phoretic organisms.

In September 2023 the FDA took another step in promoting food safety that will eventually tie to carriers. It issued a draft of guidance for hazard analysis aimed at preventing risk to human foods. Those who manufacture, process, pack, and hold food must have a written safety plan and implement hazard analysis and preventative controls, as well as monitoring and verification. And to be sure, keep records.

The FDA draft guidance states explicitly that the most scrupulous effort will not result in a “zero-risk” system. It’s all a matter of reducing risk to as near zero as possible.

The essential point is that we can expect reciprocity in the way carriers and food plants evaluate each other. Neither carrier nor manufacturer wants to be responsible for a food safety failure. As such, they will each expect the highest standards from the other.

The EPA also takes an interest in freight carriers. The EPA began a three-year initiative in December 2022 labeled the Clean Trucks Plan. We mention this because one objective is to have new greenhouse gas emission (GHG) standards in place for vehicle model year 2030, standards that EPA writes will be “stringent.”

Carriers are dealing with so many regulations that anything members of our industry can do to simplify and shorten the time for cleaning will be well received. As it is, EPA plans to have “stringent” emission standards in place for nitrogen oxide (NOx) beginning with truck model year 2027.

EPA attributes 29 percent of GHG emissions to transportation with a quarter of that amount coming from heavy-duty trucks. And its commitment to reduction is nothing less than ardent.

In addition, the EPA takes the lead in implementation of rules to reduce effluent. That means it looks closely at the use of water in cleaning transportation vehicles, especially the composition of wastewater.

Automated facilities and contractors cleaning freight trailers must be sure their plan for wastewater generated meets guidelines for transportation equipment under the National Pollutant Discharge Elimination System (NPDES). The EPA rules apply not just to contaminants removed from the outside and inside of freight trailers, but also the inside of tanker trailers used to haul food-grade material.

The FDA and the EPA—is anyone else interested in the condition of freight trailers? Yes, of course—U.S. Department of Transportation (DOT) for one, and OSHA [Occupational Safety and Health Administration] for another.

Freight trailers in 2024 are efficient, necessary, highly regulated, and cleaner than ever.