The Tanker Wash Oversight Gap:

The beverage industry depends on the safe movement of bulk liquids every day. Citrus juices, concentrates, teas, sweeteners, flavor bases, dairy products, and other sensitive beverages travel long distances in food grade tankers. Most people assume these tankers are washed in facilities that are inspected or certified by a government agency. They are not. This is one of the most overlooked gaps in the entire food and beverage supply chain.

Tanker wash facilities operate without direct federal or state oversight. There are no routine government inspections, no licensing requirements specific to tanker sanitation, and no standardized national audit program. The only people truly checking behind tanker washes are the companies that order them. This creates a system where safety depends on customer requirements rather than regulatory enforcement.

Why This Matters for Beverages

Beverages are especially vulnerable during transportation. Some are ready‑to‑drink, meaning there is no kill step after unloading. Even small lapses in sanitation can lead to contamination, allergen cross‑contact, chemical residues, or flavor changes. A tanker that previously carried dairy, nut beverages, acidic juices, or flavorings can easily compromise the next load if the wash is incomplete or poorly documented. The beverage industry relies heavily on consistency, and this oversight gap introduces real risk.

The Oversight Gap: Who Actually Checks Tanker Wash Facilities?

In my 50 plus years of experience, I have never seen a government agency visit food grade tanker wash stations. In some rare instances, a state affiliated department may have completed an on-site evaluation, but if this is happening, it is rare.

The FDA’s Sanitary Transportation of Human and Animal Food rule (21 CFR Part 1, Subpart O) went into effect on September 12, 2018. This sets broad expectations for cleanability, maintenance, and contamination prevention. This regulation, as part of the Food and Drug Administration's Food Safety Modernization Act (FSMA), established federal requirements to ensure motor and rail transport do not render food unsafe. However, to date, we have, through our food grade tanker wash evaluations, have not seen evidence of any regulatory audits either state or federal. Personally, we feel this is an excellent and timely regulation, but government agencies just don’t have the resources to monitor compliance. 

This means:

• There are no or limited federal inspections of food grade tanker wash facilities.

• There are no licensing or permitting requirements specific to food grade tanker sanitation.

• There is no standardized national audit program.

• There is no regulatory body verifying wash procedures, water quality, or documentation.

So, who checks them?

Only the companies that hire tanker wash facilities; beverage manufacturers, juice processors, carriers, and brokers. I did experience years ago a company that was receiving supplies in bulk tankers that received a minor nonconformance to a food safety standard because the facility had not audited the supplier that was performing the tanker washes. When the facility audited them, they found them using non-approved chemicals.

Each company that receives bulk supplies sets its own expectations, its own documentation requirements, and its own verification process. Typically, these companies have their own inspection criteria and audit team that visits the wash source for their bulk tankers. Some have strong programs. Others rely on trust. The result is a patchwork system with significant variability in safety, consistency, and compliance.

Why Tanker Wash Recalls Are Rarely Documented

One of the most misleading aspects of food grade tanker wash safety is the apparent lack of documented food or beverage recalls linked directly to tanker sanitation. At first glance, this might seem reassuring. It reflects a gap in how investigations are conducted and how root causes are recorded.

When a contamination event occurs, investigators focus on the product, the processing environment, the ingredients, and the immediate supply chain. Transportation is often reviewed only at an elevated level of the recall process. Unless there is unmistakable evidence of residue, cross‑contact, or chemical contamination inside the tanker, the wash facility is rarely identified as the source. Most investigations do not include a detailed evaluation of the food grade tanker wash process, water quality, or prior load history. As a result, transportation‑related contamination can be missed or classified under broader categories such as “unknown,” “environmental contamination,” or “supplier failure.”

This creates an unrealistic statistical picture. The absence of documented food grade tanker wash recalls does not mean the risk is low. It means the industry has not historically looked closely enough at tanker sanitation during root cause analysis.

There are ways companies can uncover potential tanker wash issues even when they are not formally documented:

• Reviewing wash tickets, requiring that the last three loads prior to the food grade wash recorded and comparing them to prior load histories.

• Ensuring that no prohibited substances were hauled in the prior three loads. Or, if there were, steps have been taken to ensure the tanker meets food grade standards 

• Verifying water quality test reports and wash temperatures

• Checking for inconsistencies in documentation

• Conducting supplier audits or requesting third‑party verification

• Performing specific tests depending on the bulk load prior to receipt

• Investigating flavor defects, allergen traces, or unexplained microbial findings that appear after transportation

These steps often reveal gaps that would not appear in public recall databases. They also help companies strengthen their preventive controls and demonstrate due diligence under FSMA and Global Food Safety Initiative (GFSI) expectations.

It must be noted that recalls related to bulk tanker supplied ingredients have not been totally without incidence over the years.

• Schwan’s ice cream had a nationwide Salmonella recall that began in October 1994 with legal and investigation issues into several months of 1995. This was due to the bulk tanker having previously carried raw eggs, the tanker was damaged inside and not inspected and washed properly such that it caused cross contamination between the raw eggs and the next load which was pasteurized ice cream mix.   The result was a massive outbreak of Salmonella enteritidis which affected an estimated 224,000 people across the United States.

  
  

The lack of documented food grade tanker wash recalls should not be interpreted as evidence of safety. It should be seen as a sign that industry must look more closely at transportation as a potential source of contamination. This is exactly why structured guidelines, independent audits, and strong customer requirements are so important.

Where the Juice Products Association Steps In

During the inception of FDA’s Juice Hazard Analysis Critical Control Point (HACCP) regulation (2001), top Juice Processors along with the University of Florida joined together to perform an intense evaluation to determine what the best process would be to wash food grade bulk tankers prior to carrying a juice product. This resulted in the Florida Citrus Processors Association (FCPA) managing a standardized tanker wash/sanitation program. In 2006, the management of this program was transferred to the Juice Products Association (JPA) releasing and monitoring the Model Tanker Wash Guidelines identifying 3 private companies to be approved to perform these audits. However, the Model Tanker Wash Guidelines are publicly available, and any auditing company can use the guidelines to conduct tanker wash facility audits.

These guidelines identified several requirements that any food grade tanker that was destined to carry a juice product had to be audited to. Each food grade wash facility was to be audited a minimum of annually to these guidelines with a recorded audit report stating findings and compliance status. Each juice facility was to confirm the approval of the wash station online prior to loading a clean bulk tanker. Paperwork would travel with load such that the receiving location would also confirm that the wash station was included on the list of tanker wash facilities that had been audited and received a “meets expectations".

D.L. Newslow & Associates, Inc., is proud to have been one of these approved companies. As of 2026, we annually perform over 33 Food Grade Tanker audits to these criteria.

The guidelines included a multi-page list of items that are typically transported in food grade tankers and requirements for washing these items. Dairy products and other fatty ingredients require an extra chemical wash compared to bulk tankers that only carry juice. It also requires that the last three loads be submitted prior to the wash. If these last three loads include any items not allowed, then the tanker is to be turned away from the wash station. This goes a long way in preventing cross contamination and cross-contact (allergens).

These guidelines are respected throughout the beverage industry, but they are voluntary. In most instances, a food grade tanker wash facility may only incur the extra cost of this audit if a customer requires it. As mentioned previously, these guidelines do address the required wash if the last load has carried a dairy product. We recommend also reviewing the current Pasteurized Milk Ordinance (PMO) which also defines requirements for washing and sanitizing milk tanker trucks and bulk transports.

On a positive note, in recent years we have seen more and more facilities asking for their food grade bulk tanker wash facilities to be audited to meet these criteria. This by no means guarantees that every food grade bulk tanker is food safe when leaving the facility, but it does add a positive oversite and opportunity to provide an understanding of the requirements. This is a rare distinction and a major advantage for beverage companies seeking assurance that their tankers are washed effectively.

Each wash station as part of the criteria is required to have their wash tickets reviewed and signed by an individual that has been trained in a basic International HACCP Alliance approved course (preferably a Juice HACCP course). During the past two years we have also provided a 3–4-hour HACCP awareness course for the operators.

Our team provides objective, standardized oversight in an area where government oversight is limited at best. This criterion strengthens sanitation programs, improve documentation, verifies wash effectiveness, and can build customer confidence. For beverage companies, your audits and consulting services offer a positive step forward to verify that food grade bulk tankers have been washed to defined requirements. Records are provided to both the loading facility and the receiving facilities.

A Safer Path Forward

Until federal oversight evolves, the beverage industry must rely on strong customer requirements, voluntary standards, and trusted auditors. The JPA guidelines provide the structure. Your organization provides the expertise. Together, they help close the gap and protect the beverages consumers rely on every day.

The path forward is clear:

• Stronger industry‑driven standards

• More consistent audits

• Better documentation and traceability

• Increased adoption of JPA guidelines

• Collaboration between tanker washes, carriers, and beverage companies

• Expert support from organizations like D.L. Newslow & Associates

As these pressures grow, the oversight gap around tanker washes becomes more dangerous and more visible.

Companies that rely on tanker transportation must demonstrate that they have verified, not just assumed, that their tankers are effectively washed and sanitized.

For more information on these guidelines, please visit https://tankerwash.org/  and for Grade A Dairy transport  visit https://www.fda.gov/food/milk-guidance-documents-regulatory-information.

Please contact us if you have questions or would like additional information.

To reach us please contact me directly at debby@newslow.com or visit our website at www.newslow.com 

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