A group set up to develop an industry response to the FDA's proposals on food traceability has laid out its wish list for a workable, pragmatic system.
The Food Traceability Leadership Consortium (FTLC) – a group of food retailers, wholesalers and suppliers formed in March – has challenged its technology partner ReposiTrak to come up with a platform that offers three fairly challenging characteristics.
First and foremost? It needs to be cheap to implement, so that food industry margins won't be cut, placing upward pressure on prices to the consumer – and that means it should rely on "existing processes and documentation."
The FTLC says the system should be compatible what any format of existing documents or records used in the food supply chain, not require any changes in inventory management practices, and should also be simple to "adopt, use and verify" to encourage broad take-up.
Finally, it must meet or exceed the FDAs proposed regulations, and be able to track product movements through each node of the supply chain with a data exchange system that can "universally accept all forms of data from any participant."
The FDA's proposals for 'farm-to-table' traceability for 'higher-risk' foods require the capture of batch/lot and similar shipment level data for a wide variety of fresh produce, seafood and dairy products as they move through the supply chain.
FDA is expected to push for a final rule to be ready this year, with implementation in 2022, with full compliance anticipated two years after the effective date, according to The Acheson Group (TAG), a food safety and public health consultancy.
The FTLC is focusing on FSMA requirements for last leg of the supply chain, retailer and wholesaler distribution to the stores.
"We have also confirmed the biggest challenges caused by the FSMA regulations, notably capturing shipment level data as product moves through the supply chain and traceability from the distribution centre to the store," said Randy Fields, chairman and CEO of ReposiTrak.
The company is "now determining the capabilities needed to address them," he added.
"We've made great progress in understanding the needs of the industry in a short time by sharing both pain points and successes. The FTLC will now work to see if there is a solution that addresses the FDA requirements while not interrupting supply chain operations or negatively impacting consumer costs."
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