Elements of an Approved Arrangement

Your products must:

• Be transported under appropriate temperature controls at all times, including during their overseas journey. Consideration should be given to ambient products and their maximum or minimum temperatures during international freight. For further information around temperature control during transport, refer to Export Control Rules (Milk and Milk products) section 5-16 & the AFGC's Australian Cold Chain Guidelines.
• The containers must be built so they will prevent any contamination during transport.
• Fixtures within the containers should not be protruding which could damage packaging and pose a threat to your milk product.
• The container floor and any vents should be checked and the container should be free of odours, taints and any other toxic substances which could adversely affect your product.
• Documented procedures must be in place to ensure that any air or sea freight containers to be used for transport are clean and there are no residues or extraneous matter.  It should be pest and insect free and no evidence of any sources of contamination, for example; dirt, rust, algae growth, flaky paint, chemical smell or residues, or water/moisture.
• Any food contact surfaces in the transport system containers must be constructed, insulated and equipped to be able to maintain your export product at the required temperature.

Your document should highlight and ensure where temperature control is required, all temperature monitoring instruments are checked to ensure that required temperatures are being maintained. The container being used must be  capable of maintaining the required set temperature during transport. For refrigerated container units which require their own power source, you should discuss these requirements with your transport supplier and consider checks (manual or automatic) to ensure the unit is continuously connected to a power source during transport, including at docked wharf and during shipping. Failure to maintain the set refrigerated temperature could interfere with product quality and most importantly, product safety.

The Australian Food and Grocery Council (AFGC) has implemented an Australian cold chain guidelines document to assist the industry understand the requirements and importance of conducting the correct checks at loading of products for dispatch, to ensure cold chain compliance during storage and transport.

You must keep a record for all the container loading checks you have conducted and ensure they meet the specified criteria.  If checks fall outside the specifications, then appropriate corrective action must be taken and recorded. It may be necessary to reject a container from use if it does not meet functional, structural or hygiene requirements.

Personnel responsible for the checking of air and sea freight containers should be appropriately trained.

When documenting and reviewing your procedures, you should consider the following:

• Do you have a checklist to ensure that the transport containers you will use, whether sea or air freight, are cleaned, inspected and approved before loading?
• Does your documentation include all relevant areas to check as per your approved arrangement covering legislative or importing country requirements?
• Has your supplier of containers been included in your approved supplier program?
• Have you considered assigning someone to conduct inspections before loading, and if so, who will be responsible for this and how will they do it? Should you include photos as a record of container inspections and correct loading?
• Do you have a plan for corrective action to be taken if there is an issue with any of the containers?