In Spring 2016, the FDA released its long-awaited Final Rule on Sanitary Transportation of Human and Animal Food (the “Rule”). The regulation, which constitutes one of seven final rules implementing the Food Safety and Modernization Act (“FSMA”), was closely watched by many throughout the industry—and for good reason. Based on the earlier proposed version of the Rule, many commentators feared the Rule in its final form would be an inflexible regulation with the potential to impact the very way that food transporters operate—and not always in ways that made sense.