Previous 3 Cargoes?

From the coming FSMA regulation:

(4) A carrier that offers a bulk vehicle for food transportation must provide information to the shipper that identifies the three previous cargoes transported in the vehicle. The shipper and carrier may agree in writing that the carrier will provide information that identifies fewer than three previous cargoes or that the carrier need not provide any such information if procedures have been established that would ensure that the bulk vehicle offered will be adequate for the intended transportation operation, e.g., if the carrier by contract, will only offer vehicles dedicated to hauling a single type of product. The written agreement is subject to the records requirements of § 1.912(b).

What does this mean?

As a carrier, you’ll be required to disclose the last 3 things you’ve hauled in your trailer to a shipper. Your record keeping must improve. How can you improve your record keeping for this? This can easily be tracked in most dispatch softwares. If you’re not currently using dispatching software, you could use a simple spreadsheet solution. There are a variety of them that are free such as OpenOffice Calc, or even Google Docs.

Another way to have help would be using a GPS Tracking Solution. Using historical data for pickups and deliveries, you could easily tell which product was last hauled in a trailer and send that information to the shipper when requested.

Agreeing In Writing

The other solution to this is to agree in writing to be able to provide fewer than the last three previous cargoes to be transported. If transparency is key to your business, this may not be the best solution. But, you do choose to agree in writing, make sure that it’s not only via e-mail. That you have the agreement signed and delivered so that there’s no questions.


While this seems like a new hassle, we’re sure that you agree that food safety is a valid concern and something that should be tracked appropriately. It protects not only those served by your responsible deliveries, but also protects your own family and friends from irresponsibility of other carriers who are forced the comply with these new regulations.