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FDA's Food Traceability Final Rule - Are Your Traceability Systems Ready?

Part 1 of 3

In the current digital age, our shopping patterns have shifted away from brick-and-mortar to online retailers. Purchasing products is easy, efficient, and we do not even have to leave our homes. And if we want to know where our package is in real-time, we go online, enter our tracking number, and voilà, we have a pretty accurate picture on where that package is and when it will get to us. If only food traceability were that easy, efficient, and effective.

Traceability and the Telephone Game

As good as we might think we are, the fact is, food traceability systems are not as robust as they should be. A few examples:

  • Many operations perform traceability exercises that are less aimed on challenging their systems and more focused on “passing the test” for an audit. The easier you make the challenge, the better chance you have at achieving your goal.

  • Company’s often record their traceability-related data on paper forms, Excel spreadsheets, or a combination of systems, proving opportunity for human error.

  • Supplier Approval Programs have become “boilerplate” documents with a list of required documents but no requirements on assessing the suppliers’ internal traceability programs.

  • Development of Foreign Supplier Verification Programs (FSVPs) is still in its infancy with smaller and middle-market companies not always comprehending when they need them in place at their operation. The FSVP may be an integral component to being compliant with the FDA Food Traceability Final Rule.

Remember the Telephone Game? The rules were to whisper a sentence into a person’s ear, then they would whisper it in the next person’s ear, and so on. By the time you got to the last person, the message was often completely different than what you started out with. Like passing verbal information from person to person in that game, our traceability data often becomes less detailed, muddled, or lost as the food product moves along the supply chain. As an industry, we have been so focused on the one-step-forward, one-step-back approach that we are losing visibility along the span of the food chain.

FDA is releasing the FSMA Final Rule: Requirements for Additional Traceability Records for Certain Foods (FDA’s Food Traceability Final Rule), as part of FDA’s New Era of Smarter Food Safety Blueprint. They are applying this Final Rule to companies that manufacture, process, pack or hold specific high-risk food items on the FDA’s Food Traceability List (FTL). These include fresh leafy greens, fresh-cut fruits and vegetables, nut butters, shellfish, ready-to-eat deli salads, among others.

Why does this matter? Because FDA’s Food Traceability Final Rule is scheduled to be published on November 21st, 2022 and go into effect January 20, 2026. The rules of the traceability game will be changing. IMHO, for the better.

It is not effective until 2026 – so why worry now?

Yes, everyone has 3 years from this coming January before the Final Rule takes effect; however, time flies, dates are forgotten, and sometimes the necessary systems take more time to put into place than we might think.

  • Either electronic systems will need to be implemented, OR current systems may need updating to ensure you are collecting the appropriate pieces of data.

  • Communications will be required with your suppliers, brokers, and/or importers.

  • A Traceability Plan will require development and implementation.

Personally, we are a big proponent of being proactive.

Contact Kidder Consulting Services at (800) 918-8788 or to start the development and implementation process for your new traceability recordkeeping procedures, Traceability Plan, and supporting documentation.

See FDA’s website for further details on FDA’s Food Traceability Final Rule.

Kidder Consulting Services

Kidder Consulting Services works with food companies and private equity firms (clients in the food industry) to bring a strategic, risk-based, proactive approach to food safety challenges. With over 20 years in industry, our experience includes food safety, regulatory compliance, supply chain management, operations, and due diligence work. Call or email us today to find out how we can help you address your food safety needs.


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