Some concerns have been raised regarding the Food Traceability Proposed Rule announced by the U.S. Food and Drug Administration (FDA). The official rule, Requirements for Additional Traceability Records for Certain Foods, establishes enhanced recordkeeping standards for foods on the Food Traceability List. Produce Marketing Association (PMA) Vice President of Supply Chain and Sustainability, Ed Treacy said the proposal is a step in the right direction. However, there are some areas within the rule that could be improved upon, particularly as it relates to the issue of ‘First Receiver.’
“The FDA deems that the ‘First Receiver’ must capture, and store, and share if asked by FDA, information around the harvest, the cooling, storage, and processing. If the first receiver gathers this information from the shipper, they have no way of validating it,” said Treacy. “No one has the facility created or the system to capture that information. That’s not something that’s ever shared in the industry today. It would require everyone to reprogram their systems to allow somewhere for this information to reside.”
The Food Traceability Proposed Rule is a component of the FDA’s New Era of Smarter Food Safety Blueprint. Treacy said that increasing traceability abilities is widely supported by industry members, but there may be a more efficient way to accomplish it. Using a Global Trade Item Number and lot numbers could prove to be a more effective method for traceback activities. “It’s one phone call and you bounce right over the supply chain, right back to the originator of the product; the person who was responsible for the growing, harvesting, and packing. You get all the information you want from them,” Treacy explained.
During the comment period for the Food Traceability Proposed Rule, PMA provided feedback on areas that could be improved. Along with concerns about the requirements for first receivers, PMA also outlined areas that could be better defined. Treacy noted that increasing food safety and traceability is a worthwhile cause, so long as it is done in a manner that makes sense. FDA is required to finalize a version of the rule by November 2022.
“We applaud FDA for coming up with this rule, it is very good. It’s just not perfect and we’re trying to help them get closer to it,” said Treacy. “Other than ‘First Receiver’ and a couple of other additional fields of information they think they need, it aligns very nicely with the Produce Traceability Initiative, which is great news for our industry.”
Listen to the interview below.