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The FSMA sanitary transportation rule for reefer carriers

Helm PartnersUpdated Oct 29, 2026Sources checked Oct 29, 2026

This guide is general information, not advice on any policy.

Short answer

When your contract with a shipper makes you responsible for sanitary conditions, FDA's rule asks you to meet the shipper's equipment specifications, pre-cool the trailer as specified, and show you held the set temperature if the shipper or receiver asks. You also need written cleaning and temperature procedures, trained drivers, and training records kept for 12 months after a person leaves those duties.

In this guide
  • Who the rule covers
  • What a carrier must do
  • Bulk food loads
  • Training and records
  • Why it matters for cargo claims
  • A checklist
  • FAQ

FDA's sanitary transportation rule is part of the Food Safety Modernization Act rules. It sets duties for each party in a food shipment. For a reefer carrier, most duties start when a written agreement with the shipper makes you responsible for sanitary conditions. Here is what that means, with the rule text.

Who the rule covers

  • Shippers, loaders, receivers and carriers moving food, whether or not it crosses state lines (21 CFR 1.900).
  • A carrier with less than $500,000 in average annual revenue, adjusted for inflation, over the prior 3 years is a non-covered business (21 CFR 1.904). Your shipper may still ask you to follow its specifications by contract.
  • Parties can reassign duties in a written agreement, and that agreement is a record you keep (21 CFR 1.908(a)).

What a carrier must do

When your agreement makes you responsible for sanitary conditions, 21 CFR 1.908(e) says you must:

  • Provide trailers and equipment that meet the shipper's specifications.
  • Pre-cool each refrigerated compartment as the shipper specified, before you offer the trailer.
  • Give the receiver the operating temperature the shipper set, if asked, and show you held it, if the shipper or receiver asks. Readings at loading and unloading, or time and temperature data from the trip, can do that.
  • Keep written procedures for cleaning and inspecting equipment and for how you meet the temperature duties.

Bulk food loads

  • If the shipper asks, a carrier offering a bulk vehicle must say what the vehicle carried last and describe its most recent cleaning (21 CFR 1.908(e)(4) and (5)). For milk tankers in Michigan, see milk tanker hauling in Michigan.

Training and records

  • Train personnel at hiring and as needed after on food safety problems in transport, sanitary practices and your duties under the rule (21 CFR 1.910).
  • Training records show the date, type of training and who was trained. Keep them 12 months after the person stops those duties. Keep written procedures 12 months after you stop using them (21 CFR 1.912).
  • Records can be electronic and must be available promptly when an authorized person asks.

Why it matters for cargo claims

  • A temperature claim turns on records: the set point, pre-cool, readings during the trip and at delivery. The same records the rule asks for are the ones that settle a claim.
  • Underwriters often ask about cargo loss history for reefer fleets. Clean, documented temperature records help you show it. See motor truck cargo insurance.

A checklist

  1. Find out which of your shipper agreements make you responsible for sanitary conditions.
  2. Write down your cleaning, inspection and temperature procedures.
  3. Pre-cool to each shipper's spec and log it.
  4. Keep trip temperature data you can hand over on request.
  5. Train drivers and keep the training records.

General freight lanes too? See dry van insurance requirements.

Building a claim file: a reefer cargo claim file checklist.

Bulk tankers: food-grade tanker wash and cleaning records.

Michigan, Ohio and Indiana: reefer state notes for Michigan, Ohio and Indiana.

Records: reefer unit maintenance records and loss runs.

FAQ

Does the FSMA transportation rule apply to my reefer company?

It applies to shippers, loaders, receivers and carriers moving food by motor or rail vehicle, whether or not the food crosses state lines (21 CFR 1.900). A business with less than $500,000 in average annual revenue, adjusted for inflation, over the prior 3 years is a non-covered business (21 CFR 1.904).

Do I have to give temperature data to the receiver?

If the receiver asks, you must provide the operating temperature the shipper specified. If the shipper or receiver asks, you must show you held that temperature, for example with readings at loading and unloading or time and temperature data from the trip (21 CFR 1.908(e)(2)).

Do I have to pre-cool the trailer?

Yes, when the load needs temperature control for safety and the shipper specified pre-cooling. You must pre-cool each refrigerated compartment as the shipper specified before you offer the trailer (21 CFR 1.908(e)(3)).

What training does the rule require?

When your written contract makes you responsible for sanitary conditions, your personnel need training on food safety problems in transport, basic sanitary practices and your duties under the rule, at hiring and as needed after. Records must show the date, the type of training and who was trained (21 CFR 1.910).

How long do I keep FSMA records?

Training records for 12 months after the person stops doing those duties, and written procedures for 12 months after you stop using them (21 CFR 1.912). Electronic copies are allowed.

Does this rule cover reefer breakdowns?

The rule says food that may have become unsafe from a temperature failure may not be sold unless a qualified person decides it is safe (21 CFR 1.908(a)(6)). Whether a policy pays for spoiled freight depends on its terms, so read the cargo and reefer breakdown sections of your policy.

This guide is general information, not advice on any policy.

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