Considerations for Food Grade hauls in a DOT 407

1. NTTC Maintenance Seminar 2010 Considerations for Food Grade hauls in a DOT 407 Steve McWilliams Walker Transport

2. NTTC Maintenance Seminar 2010 Topics Examples of food grade products Determining if it’s food grade hazmat Why the “right” equipment is important Tips for specifying a food grade DOT 407

3. NTTC Maintenance Seminar 2010 Examples of food grade products Alcohols & blends “food grade flammable” Orange Oil Hydrogen Peroxide 50% Food Grade Phosphoric Acid 65-80% Food Grade

4. NTTC Maintenance Seminar 2010 Determining if it’s food grade hazmat Starting point: MSDS typically will have “Food Grade” in the description

5. NTTC Maintenance Seminar 2010 Determining if it’s food grade hazmat CFR 172.101 Hazardous Material Table will not specifically list material as “Food Grade”

6. NTTC Maintenance Seminar 2010 Why the “right” equipment is important Potential regulation : Sanitary Food Transportation Act 2005 It amends section 402 of the Federal Food, Drug, and Cosmetic Act to define unsanitary transport as food “adulteration” Failure to comply with the sanitary transportation practices will be subject to sanctions and penalties

7. NTTC Maintenance Seminar 2010 Tips for specifying a food grade DOT 407 General Product contact material Components Trailer construction Security

8. NTTC Maintenance Seminar 2010 Tips for specifying a food grade DOT 407 General Trailers must, at a minimum, comply with: DOT 407 specifications FDA “indirect food additive” requirements for non-metal material in product contact areas Trailers dedicated to food grade service Put into food grade service the first day the trailer leaves the manufacturing plant Converting trailers that have hauled other material into food grade service should not be done

9. NTTC Maintenance Seminar 2010 Tips for specifying a food grade DOT 407 Product contact material Material should be chosen based on compatibility with the products being hauled Barrel, heads & piping: stainless steel 316L common, other options available Rubber Gaskets: manhole, transfer hose, etc White color for ease of inspection Gasket manufacturers written certification it complies with FDA CFR Title 21, Paragraph 177.2600 “Rubber articles intended for repeated use”

10. NTTC Maintenance Seminar 2010

11. NTTC Maintenance Seminar 2010 Tips for specifying a food grade DOT 407 Product contact material Plastic Gaskets: outlet, vents, valves, etc White color for ease of inspection Gasket manufacturers written certification it complies with the appropriate section of FDA CFR Title 21, Paragraph 177

12. NTTC Maintenance Seminar 2010 Tips for specifying a food grade DOT 407 Components Pump, vent and valve material stainless steel in product contact areas avoid carbon steel and aluminum (pitting) Transfer hoses assemblies Non-metal material in product contact areas must comply with the appropriate section of FDA CFR Title 21, Paragraph 177 3-A certified products, if available, will always meet FDA and are designed for ease of cleaning

13. NTTC Maintenance Seminar 2010 Tips for specifying a food grade DOT 407 Trailer construction No baffles due to cleaning issue Interior weld finish: W4 to W5 Avoid weld finishes that can create product traps Pipe thread connections: Avoid if possible due to a potential product trap Thread lock - Loctite 2046 complies with FDA CFR 21 paragraph 175.300 Thread sealant/anti-seize – PTFE, Teflon, thread seal tapes available meeting FDA requirements

14. NTTC Maintenance Seminar 2010 Tips for specifying a food grade DOT 407 Security Seal points, every opening, need to be substantial Cabinets Dome lid Venting Transfer hose carriers Review everything on the trailer for ways to potentially tamper with the product and eliminate it

15. NTTC Maintenance Seminar 2010 Questions?