Food & Beverage

3 things to know about FDA’s proposed Food Traceability Rule

Provided

October 19, 2020

By Angela Fernandez, Vice President, Community Engagement, GS1 US

On Sept. 21, the U.S. Food and Drug Administration proposed a critical update to the Food Safety Modernization Act — Section 204(d)(2)(A), the long-awaited food traceability rule. The proposed rule is going through a 120-day public comment period with the FDA issuing the final rule by Nov. 7, 2022.

While it is limited to the foods at the highest risk for foodborne illness outbreaks, the rule outlines potentially revolutionary changes that could finally enable end-to-end food traceability across the food industry. Here are three aspects of the rule that restaurants should become familiar with, as it may impact the way foodservice operators collaborate with distributors, suppliers and solution providers, how they track food from farm to table, and improve procedures for keeping guests safe.

1. The Food Traceability List
Through an extensive risk-ranking and peer review process, the FDA created a list of "high risk" foods, meaning those most susceptible to a foodborne illness outbreak, called the Food Traceability List. From eggs to leafy greens, this list encompasses a wide range of fresh foods commonly served at most restaurants.

These categories have been prioritized after past expansive and deadly foodborne illness outbreaks in many of these sectors. The CDC estimates that each year, about one in six Americans (or 48 million people) get sick, 128,000 are hospitalized, and 3,000 die of foodborne diseases. Also, in our pandemic-influenced world, consumers rank safety as a factor more important than anything else when selecting a restaurant, including sustainability, healthful eating, and affordability, according to recent Datassential survey.

The FDA is proposing that companies in the identified categories enhance their traceability recordkeeping capabilities beyond the limited "one up, one back" traceback procedure in favor of more robust data sharing.
For persons who manufacture, process, pack, or hold" these types of foods, the proposed rule would require the use of Key Data Elements and Critical Tracking Events, which for many partners will mean recording and sharing a host of information in their systems such as batch/lot/serial numbers, and other specific details about where products came from and how they were transformed.

For the most part, restaurants should be prepared to receive this information and align with partners to ensure a mutual understanding of the new requirements, however there are possible exemptions for small retail food establishments that have 10 or fewer employees. During the comment period, the industry will weigh in on either full or partial exemption from the requirements of the rule for these small establishments. Partial exemption would mean electronic spreadsheets to maintain traceability information would not be required, but all other aspects of the rule stand.

2. Harmonization and Standardization
With greater industry collaboration and more efficient processes in place, outbreak reactions can happen faster. In the announcement of the rule, Frank Yiannas, the FDA's Deputy Commissioner for Food Policy and Response, emphasized harmonization of the food system as a critical part of becoming more proactive to prevent issues before they happen.

The focus on harmonization is a continuation of a major 2020 theme for the agency, which promoted standardized data sharing over the summer when it introduced the New Era of Smarter Food Safety blueprint. The New Era is a related initiative that calls for technology-enabled food traceability and trading partner collaboration to fully bring the food system into modern times with the desired supply chain visibility that can be enabled with widespread adoption of standard-based business processes.

For the larger foodservice operators, the use of GS1 Standards to collaborate with suppliers and distributors for greater efficiency is perhaps nothing new. Since the inception of the Foodservice GS1 US Standards Initiative more than 10 years ago, many industry stakeholders are already universally identifying their products, and standardizing the formats in which they record and share data with external partners.

However, FSMA rule 204 and the New Era can help create more urgency among smaller suppliers who are not exempt. Traceability is a shared responsibility industry-wide. When more companies use global data standards for exchanging product data, everyone in the food supply chain can interoperate with their partners' systems, creating valuable efficiencies. Plus, smaller companies can enhance their competitiveness in other areas as a result of improved traceability. They can more easily investigate food fraud, and certify products as organic or other claims increasingly sought by restaurant guests, for example, in addition to participating in more efficient withdrawals.

3. Embracing Technology
The FDA's strong endorsement of the use of electronic data exchange over more manual methods of sharing supply chain data (PDFs, spreadsheets, paper documents) is a sign of the times. While the current economic climate may not allow some to invest heavily in technology now, the rule suggests that over time, the long-term returns in digitization can contribute to an ideal future state of automated, tech-enabled traceability.

Embracing technology means the foodservice industry can stay better in tune with needs of their guests, who increasingly want access to information about food and expect technology to be a part of their restaurant experience. Pre-COVID-19, a survey from OnBuy.com revealed that the majority of respondents (65%) said they felt drawn to try new restaurants that have adopted new technology, such as digital ordering at the table or interactive menus. As the pandemic has certainly interrupted many plans for innovation, foodservice operators should still educate themselves on what will impact the industry as a whole, and collaborate now with trading partners to lay a foundation for enhanced engagement in the future.

For example, to share details of where a fish was caught, or which farm produced their favorite goat cheese, many foodservice operators work with their partners using solutions based on GS1 Standards to record Key Data Elements and Critical Tracking Events for supply chain visibility, as outlined in the rule. The FDA's leaders are envisioning similar transparency, such as consumers receiving alerts about food recalls directly on their phones, and know that collecting and sharing the right information in a consistent way is a key part of making that vision a reality.

When the rule is complete and implemented in 2022, these new requirements and processes will ultimately give customers peace of mind and restaurant operators a boost in efficiency. By collecting more relevant product data for the 21st century consumer, and sharing it in a standardized way leveraging technology, the foodservice industry can become faster and more vigilant to ensure food safety for all.