Loading of sea and air freight containers

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Does the company load directly into sea/ air freight containers?

If so, a documented procedure must be in place to ensure the containers are:

  • Fit for purpose.
  • Clean and free of extraneous matter and residues.
  • Free of objectionable odours, taints and other toxic substances.
  • Free of dirt, rust, flaky paint, algae growth and moisture.
  • Free of insects and other pests.
  • No protruding fixtures which could penetrate and damage packaging containing milk and milk products.
  • Floor is sound, vents are checked and where temperature control is required it is checked and working.
  • Records in place for these checks.

For the relevant legislative references in the Export Control (Milk and Milk Products) Rules 2021, please refer to the department’s, Approved Arrangement Checklist.

You must have clearly documented procedures for the controls you have in place if you load your product for export directly into air and sea freight containers. Your procedures must describe the checks you undertake on the containers and the associated records that must be kept.

Your products must be protected from any contamination during its handling and loading and must be controlled as stated in your documented procedures. 

The containers you are going to load your prescribed milk products into must be kept in a condition fit for their purpose.  This may include factors such as being kept at the correct humidity or atmospheric condition to ensure that your product is fit for human consumption and is not adversely affected.

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?


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Self Assessment

How much do you know about Loading of sea and air freight containers?

Take this short assessment to find out.

Question 1

Elaine is a warehouse manager and works at a dairy facility. She is responsible for loading dairy products destined for export into an air freight container. Elaine believes the procedure for loading of air freight is the same as loading for local transport.

Is she correct in her assumption? 

Question 2

Brian works in dispatch at a dairy facility and is responsible for loading refrigerated export product into sea freight containers. As the site is new to export, Brian is tasked with creating a checklist to ensure the export container is inspected and approved, before loading the products into the container.

What items should Brian include in the container inspection checklist?

Click all that apply.