Monitoring of the Trucking Industry
As you traverse the highways this coming summer, look out for the liquid bulk trailers crisscrossing the roads. These trucks are not hauling gasoline. They contain edible liquids. They may be containing the high fructose corn syrup that will end in your soda, or the cocoa butter in your chocolate bar. Corn syrup, sucrose, chocolate, cocoa butter, vegetable oil, glycerin or fatty acids, vinegar, wine, various juices, and other liquids are also transported vast distances in this country, usually in trailers.
These trailers present a formidable challenge for Kashrus. Kashrus agencies long ago recognized that they could create a mehadrin supervision at a manufacturing facility only to find that the kashrus of the product it was certifying was, potentially, put into jeopardy because of the trailers that were hauling the product to a customer. What if, for example, a trailer that had been hauling lard was the trailer sent by the trucking company to pick up the kosher certified vegetable oils?
The answer, in a nutshell, is that the vegetable oil is most likely fine (see sidebar). Nevertheless, this conclusion is based on a concept of bittel (nullification) of the ta’am (taste) of the flavor in the walls of the trailer in the kosher commodity being carried. Since most kashrus agencies are not comfortable relying on bittel in certified products, kashrus agencies have been addressing this issue by monitoring the usage of the trailers that transport its certified products.
In addition, kashrus agencies have been certifying liquid bulk trailer companies as well. The certification attests to the fact that the trailer is fit to carry a kosher commodity. The operator of the trailers required to dedicate that trailer to kosher service. The company maintains a list of approved commodities and sources from which they may pick up a load. This list is compiled based on the information the company gives the kashrus agency about its regular business or business that the company anticipates getting once they become kosher.
How to monitor these companies is the next challenge. Unlike a factory, a truck is a moving target. Mashgichim can’t, at any given time, stop a truck and look inside of it to make sure that only a kosher commodity is being carried. Rather, mashgichim check the records that the company keeps for its internal purposes. An organized company will keep an activity log for each trailer. This is a good place to start, but the log can be doctored to cover up information that the company may not want us to see. In order to verify that the log is genuine, a mashgiach needs to compare it with other documents. Every time a truck loads, the driver will receive a bill of lading testifying to the fact that the correct amount of the correct commodity was loaded into the trailer and the date on which it was loaded. Also, every time a trailer comes to load, the driver will have to present a wash ticket to the company whose commodity he is hauling to verify that the trailer has been cleaned properly and is fit to accept the next load. The ticket will state what the previous load had been. This is an important piece of information for the washing company because they will perform different types of washes in order to clean different types of liquids. These documents are usually kept on file at the terminal of the trucking company and can be used to verify the log.
Often, a dispatcher may find one of his trailers has set out on a long haul (trucking language for a distant journey). Since the company charges by the mile, for every mile of dead head (trucking language for riding empty) they will be losing revenue while still paying the driver and incurring wear and tear on the truck. The dispatcher may find it expedient to find a customer in the locale of the trailer who needs a load carried to the area of the home base. This is known in trucking language as a back haul. When a Mashgiach sees a long haul, he should always search the paperwork for signs of a back haul. This can easily be omitted from the activity log, but a bill of lading or a wash ticket can uncover the rest of the story.
The trucking industry is very diverse. There are very large fleets that have terminals in several locations across the country and have a sophisticated computer record keeping system. Some even have GPS tracking to keep tabs on all their trailers all the time. Then there are the Mom and Pop companies where Mom is the dispatcher and Pop is the driver. In every case it is vital to have a paper trail to follow.
When trailers get washed, their kashrus is once again in jeopardy. There are wash facilities all over the country. When a trucker drops off his load and goes to get his truck washed, he will often find that while the trailer is in the bay, he can get a hot shower, do his laundry and play a game of pool. The trailer, meanwhile, is being washed, generally by a CIP (clean in place) system which entails a heating unit or boiler to heat the water, and a high pressure spinner which shoots out water while it spins, thereby covering the entire inner surface of the trailer with water. Usually when a trailer arrives, it receives a pre-rinse, which is meant to wash out the heel (trucking language for the remaining residue left in the trailer after completely unloading). The water from this wash will invariably go straight to the drain since it is dirty. The next cycle is a detergent cycle. A mixture of detergent and water is heated and pumped into the trailer. After the detergent exits the trailer, it is pumped back to the tank and cycles round and round until it loses its effectiveness at which point it is dumped. The third cycle is a hot rinse with fresh water to wash out the detergent and sanitize the trailer. Some washes will also have a cool down cycle where progressively cooler water is pumped into the trailer until it cools down to about 80 degrees.
While most wash facilities use the system described above, each system may vary in some small way. Many operators of truck washes take their business very seriously, both for health and quality considerations. A small amount of bacteria can make people sick. And any left over vinegar in a trailer that could be mixed with the next load of corn syrup could ruin the corn syrup. Some washes are very high tech and have systems for tracking their washes by computer and remotely, by Internet. Others are very low tech where the operator climbs into the tanker and power sprays the truck.
Because water costs are high, and sewage treatment is expensive, many truck washes recycle their fresh rinse water to be used again for pre -rinse. This raises kashrus issues because a trailer that has just unloaded non kosher glycerin or fatty acids that gets washed in a facility, and the water used for the fresh rinse is then recycled to prerinse for the next job, that water being shot into the trailer at 160 degrees will now compromise the kashrus of the kosher trailer undergoing the prerinse.
Another potential problem at the truck wash is that heating systems for the truck washes vary. While some facilities use a boiler to heat the water which then goes through the trailer and out to the drain, others use a heat exchanger, which requires several passes through the machine until it achieves the required temperature. Consequently, in these systems the water will pass through the trailer, exit to a hose, which brings the water to a pump and back to the heat exchanger and round and round until the water reaches the proper temperature. In this kind of system, when a non-kosher trailer is being washed, the water cycling through the system will make all the piping and spray arms and heat exchanger treif.
A third issue is the steam that is created during the very hot washes. This steam hits the spinner and its various parts and can compromise its kashrus status just as a cover of a pot is affected when used for cooking non-kosher food.
Because of these issues, a kosher trailer can only be washed at a kosher certified truck wash. The truck wash must not recycle its water, must have a one pass system and must use, in its smallest wash cycle, a volume of water that is at least 60 times the volume of metal in the spinner system.
Let this be food for thought as those liquid bulk trailers pass you up on the road.