On low-volume shipments the load is never one kind of thing. Cheese, detergent and packaging material go into the same vehicle. Turkey's Food Hygiene Regulation devotes a single seven-paragraph article to this.
Seven paragraphs, in order
- Vehicles and containers used for carriage are kept clean, maintained in good condition, and where necessary designed and built to allow adequate cleaning and disinfection, so as to protect food from contamination.
- Receptacles inside vehicles and containers are not used for carrying anything other than food.
- Where necessary, when food is carried at the same time as non-food materials or as different foods, the products are adequately separated from one another.
- Non-prepacked food in liquid, granulate or powder form is carried in receptacles or containers reserved for food, marked clearly and indelibly with the words meaning For Foodstuffs Only.
- Where vehicles or containers are used for different materials or different foods, they are effectively cleaned between loads and disinfected where necessary.
- Food is placed and protected so as to minimise the risk of contamination.
- Where necessary, vehicles and containers must be capable of maintaining food at appropriate temperatures and of allowing those temperatures to be monitored.
Two obligations in the seventh paragraph. The final paragraph asks for two separate things: holding the temperature and allowing it to be monitored. A container may keep a load cold, but if it offers no way to read the temperature inside, the second obligation is unmet.
The separation rule is the first place to look when planning low-volume chilled shipments.
What adequately separated means
The text does not prescribe how the separation is done; it requires the result to be adequate. In practice, adequacy is defended on three grounds: a physical barrier, the integrity of the packaging, and the order of loading. A closed container provides all three. A sheet thrown over the load provides none.
| Method of separation | How well it holds up in an inspection |
|---|---|
| Closed, marked container | strong |
| Separate compartment or curtain | depends on the case |
| Loading order, food first and chemicals behind | weak on its own |
| Cover sheet or stretch film | weak |
The article also reaches beyond the vehicle
Paragraphs three and seven use vehicles and containers together. The regulation writes the container in beside the vehicle, and the obligations on contamination and temperature are defined identically for both objects.
The equipment article completes the picture. Article 14 requires equipment in contact with food to be effectively cleaned, to be made of material that minimises the risk of contamination, and to have a suitable control device fitted where needed. Non-returnable transport receptacles and packaging materials are separately excepted in that article.
