The FDA today announced the final rule for Food Traceability that was required by the Food Safety Modernization Act law.  We will explore this is future blog posts, but let's start with the high level: 

Food Safety First: In the words of the FDA, this rule is "designed to facilitate faster identification and rapid removal of potentially contaminated food from the market, resulting in fewer foodborne illnesses and/or deaths" It has nothing to do with fraud, sustainability, fisheries management or any of the other reasons folks implement traceability systems. 

Most fresh foods are covered, including:  fresh cut fruits and vegetables, shell eggs, and nut butters, as well as certain fresh fruits, fresh vegetables, ready-to-eat deli salads, cheeses, and seafood products.  

In the seafood world, the exemptions include: Scallop Abductor muscle, and Catfish.

In a change from the original law is: Raw bivalve molluscan shellfish that are covered by the requirements of the National Shellfish Sanitation Program...are exempt from the requirements of the rule.  A good thing since the rules for shellfish are already tighter than this new rule.  

The rule is all about record keeping: In particular most firms are required to supply information to the FDA in a "sortable spreadsheet" within 24 hours of request. The records must cover: Critical Tracking Events (CTEs) and required Key Data Elements (KDEs).

Traceability Lot Code: These records must be linked with a Traceability Lot Code (TLC) that does not change unless the product is transformed. TLCs can only be assigned by either the First Land Based Receiver or a Processor who is Transforming the product.  

You Have time: The rule will take 3 years to be fully implemented.  In other words, take a breadth, explore the rule and then think about what needs to change.

Here is a video from the FDA using an example of a Tuna.

Many thanks to the Gulf of Maine Research Institute for putting together an amazing 4 minute video introducing BlueTrace.    Enjoy.

Our latest release introduced inventory labels. Why?  

Clients were telling us about the challenges of managing that fast-moving cold room. What is there? What should I pick? They confront challenges like packers taking the newest product (what's on top) rather than the oldest product with the shortest lifespan.

An inventory label is designed to print out when you receive product. It has the harvest date, product name, and quantity front and center. Folks add it to the top of a bin, a clipboard, a whiteboard, or even in a wet storage bin so everyone knows what that product is. That QR code links to all the information about the product and can be used to add product to orders. 

The takeaway: Saving time and reducing errors has a huge impact on your bottom line. 

Inventory Labels work well on a vat or in a tote :

1. Reduced Emissions. Both wild-caught seafood and aquaculture produce less CO2 than most other traditional sources of protein (Oceana 2021, Nature 2021). For every gram of protein we consume from wild-caught fisheries instead of beef, we are reducing the CO2 impact by 82% (89% for aquaculture). Comparing to beef yields the most dramatic difference, but even moving from chicken to aquaculture would reduce CO2 per gram by almost 50%. Aquaculture produces over 50% of the seafood we consume today.
   
   Although going vegan would be the best option in terms of greenhouse gas emissions, convincing folks to switch out a steak for oysters and salmon is a lot more realistic.
   
   
2. Substituting Seafood. Recent research also indicates that beyond the CO2 impact, more seafood would also be critical for feeding a growing population a healthy diet. According to the journal Nature:
   
   "Globally, we find that a high-production scenario will decrease [seafood] prices by 26% and increase their consumption, thereby reducing the consumption of red and processed meats that can lead to diet-related non-communicable diseases while also preventing approximately 166 million cases of inadequate micronutrient intake. 
   
   

   In other words, more seafood represents a win for the planet and for the people most at risk from malnutrition. Of course, not all seafood is equal, so traceability will matter — and is indeed critical to making this transition successful (Monterey Bay Seafood Watch).

3. Less Waste. What about waste? An estimated 39% (USDA) to 50% (Gunders, 2012) of seafood is wasted (harvested but not consumed). That loss is massive, equating to enough protein to feed 12.4 million women for a year (or 10.1 million men).  Much of the waste is outside our purview (bycatch on fishing boats or disposed of by restaurants/consumers). But a significant portion occurs within the distribution system. Seafood is more prone to wastage than meat since:
   
   "Fish spoil quickly due to digestive enzymes, microbial spoilage, and oxidation, which change the odor, flavor and texture of fish (Ghaly et al., 2010); (iii) the different microbial and chemical food safety risks from seafood than from other meats, including histamine or scombroid food poisoning due to spoilage; (iv) strong odors that are not always associated with food safety risks, but may raise safety and quality concerns among retailers, food service providers and consumers."
   
   Even a 10% reduction in wastage would deliver major benefits (Global Environmental Change, Sierra Club).

According to our customers, BlueTrace's tracking technology reduces loss and improves the safety of seafood. Even something as simple as giving folks alerts about the date seafood was harvested can have a huge impact.  

Wild seafood has a lower carbon footprint than red meat, cheese, and chicken, according to latest data, Oceana: 2021

Receiving docks are chaotic—and incredibly important. Receiving is a regulated "Critical Tracking Event" in which the buyer is supposed to transcribe the "Key Data Elements" and ensure that the product is what they ordered and that the cold chain has been maintained. Having observed many receiving docks, we understand that the time wasted, the errors introduced, and the money lost can be significant.

There are obvious ways to improve this process, some of which the best companies have implemented. In particular, they get information about a shipment before it arrives and have the product properly labeled with a link to the digital record so receiving involves only scanning—not trying to read someone's handwriting.

Historically, this sort of tool has been available only to the largest companies. But BlueTrace has developed a system accessible to the vast majority of the market. 

Our platform is inexpensive and works with existing CRM/ERM/WMS systems. We can get a company up and running in less than an hour.

Here's how it works:

1. Suppliers Print & Affix Label: Your suppliers download the BlueTrace app, enter in information about the shipment, and print a label that includes a QR code. It takes less than a minute and minimal training.  The cost is ~$750 for the printer.  Our existing Harvest Tagging clients can already do this.
   
   
   There is no subscription fee for your suppliers, and labels are designed to stick to wet wax boxes.
   
   
2. Receiver Gets Shipping Notification: When the supplier prints out a tag, we send the buyer Advanced Shipping Notifications with all the key information. This communication can occur in-app, or if needed, we can pass the information into an existing system (NetYield, Seasoft, Innova, etc.). If the buyer is not our client, they get an email with all the information.
   
   
   
   
3. Buyer Scans Tag: At the receiving dock, the label is scanned using an existing iPhone or iPad (no new hardware needed). The buyer confirms the product is in good shape and records the temperature. The buyer has thus  created a HACCP log and a digital traceability chain. The supplier receives automatic notification that the product arrived—saving time, reducing errors, and improving your margins.

In many shellfish-producing states, May 1 marks the beginning of Vibrio season. For those who don’t know, Vibrio is the most common food-borne illness caused by raw oyster (and other foods). The key management strategy: Keep it cold.  

Vibrio rules are some of the most dynamic pieces of shellfish regulation, as environmental conditions change continuously and our collective understanding of the risks and effective treatments evolves along with them.

This is a good time to revisit one of the most useful features we've built into both our Harvester Tagging and Distributor apps, RETEMPING. On the log screen, you can tap into any lot and hit the "Temp" button:

Add a temperature and confirm the date and time, both of which are pre-filled:

You can also attach an employee to this record for accountability and HACCP compliance, so make sure you have employees loaded into your Settings. Hit Done in the upper right and this temperature record is saved. It will now show up in the app (by re-opening the Temp page) and in your Harvest or HACCP Log when you export. 

Of course, this is in addition to fields for Harvest, Cooling, and Receiving temperatures on the main tagging screen, which satisfy most temperature recording requirements.

If you have any questions or feel that this capability doesn't completely satisfy your particular requirement, please let us know.

Happy harvesting!

With the resumption of shellfish trade with the EU, the U.S. oyster industry is rightfully concerned about the introduction of OsHV-1 into our waters. Although this virus does not affect humans, it has been linked to mass oyster mortalities all across the world. Not every imported oyster is carrying the virus, but they all must be treated as such since we can’t know which ones are carriers, and the stakes are just too high.

The threat is very real, but it’s manageable with knowledge and vigilance. Best practices in general should be that if you aren't sure where your oysters came from, keep them and their shells out of the water. Domestic pathogens can be circulated in similar ways, so it’s better to err on the side of caution.

The only way an issue could arise is if tainted oysters or their shells make it into (or near) the water. Here are some realistic scenarios that must be avoided:

• After enjoying the oysters, somebody tosses the shells into the water.
• Somebody buys oysters and hangs them off their dock to "refresh" them.
• A dealer holds oysters in a wet storage or depuration system that drains into the water.
• Oysters get mixed up and get put out on a beach.

Each of these situations is avoidable, but the industry and the public need to be aware of the threat. Shellfish from New Zealand and South Korea should be treated similarly, as they may also carry the virus. 

Bottom line: If you don't know where the oysters came from, keep them (and their shells) out of the water!

Shellfish harvesters and dealers, please see and distribute this letter penned on behalf of the major regional associations. The East Coast Shellfish Growers Association has also compiled useful resources for industry and the public at ecsga.org/oshv. In addition, the ECSGA is also offering FREE informational tags to anyone dealing in imported oysters. These are an important tool in minimizing the risk of tainted oysters affecting our local stocks and industries. If you would like a stack of the tags, please reach out to your BlueTrace rep, and we'll make sure you're flush.

The OsHV-1 threat makes yet another case for a robust traceability system. Knowing where imported product ends up is critical for consumer awareness and proper handling practices. And in the unlikely event of an introduction, we will definitely want to know where the oysters went in order to identify and isolate the danger as soon as possible.

Keep on shuckin'!

Oysters are a safe food, and very few people get sick from eating them. When something bad does happen, though, news stories get out of control, and the whole industry is harmed. A recent oyster recall in British Columbia illustrates the challenges. Here is what we know so far (this is an ongoing story, so more details will likely emerge):

1) On Sunday, March 20, 2022, the Canadian Government found norovirus in oysters from BC and issued the first of what became a series of six overlapping recalls on oysters. The majority of the product was harvested between March 7 and March 14.    

2) Many of the oysters were shipped well beyond BC, including to distributors in Washington state and California. Washington issued a health advisory for specific BC oysters on Friday, April 1 — 13 days after the first BC recall notice. California issued a recall on Sunday, April 3 — 16 days after the first BC recall.  34 people in California got sick from the BC oysters by the time of the advisory in CA.

3) By April 1, media stories begin to appear in Washington, Florida, Massachusetts, California, New York, and elsewhere about people getting sick.

4) Meanwhile, we heard from our distributor clients who were working hard to track these oysters and get them out of the system. One client even had to call its trucks in NYC to stop delivery of these specific oysters.

5) Food Safety News (written by a leading food safety attorney) reports on Thursday April 7th that over 103 people in California, Colorado, Florida, Hawaii, Illinois, Maine, Minnesota, New Jersey, Nevada, New York, Oregon, Texas and Washington are confirmed sick from this particular batch of oysters.  

6) Meanwhile back in BC, major farms are shut down (probably for 2+ months) and are suffering huge financial losses.  While the CFIA reports 328 illnesses from this norovirus outbreak across Canada, including in: British Columbia (293), Alberta (3), Saskatchewan (1), Manitoba (15) and Ontario (16).

My takeaways:

1) Good people worked really hard to make sure this didn't get worse. Distributors and regulators spent hundreds of hours trying to get this product out of the system.  So far, there are no deaths reported--a huge win. 

2) The recalls were too manual and slow--there should have been a more automated system for making sure different jurisdictions acted more quickly. 

3) The liability risk is probably large. I'm no lawyer, but clearly everyone is concerned about lawsuits.  

4) The entire industry is the loser:  We have heard anecdotal stories of folks avoiding all oysters after coming across the stories circulating.  

There are a lot of ways this process could be improved, including better/faster communications and a true digital traceability chain. The regulators in the U.S. should have been able to issue faster recalls/advisories. Thirteen days was too long.

A farmer or distributor with a recall should be able to notify all their buyers with a couple of keystrokes. And restaurants should be able to scan a QR code and confirm there are no recalls prior to serving that product.  

Nothing will ever be foolproof, but we can do better, and there is a clear path to improvement. 

Below is a letter to the editor of Carteret County News-Times in North Carolina from Chris Matteo of Chadwick Creek Oysters.  Chris is writing in response to a classic NIMBY article. A retired judge moved to town and wanted to "protect" his view by telling the locals what they could do.  Chris' response is thoughtful and deserves a wide audience.  Thank you Chris.

-----------------------------------------------------------

March 2, 2022

I am Chris Matteo, current president of North Carolina’s Shellfish Growers Association. I am not a retired district judge, but I am an oyster farmer with an Ivy League education (one of two in our state) and this evening I’m here to help you learn something new, Mr. Bentley. My background is not in law, but in finance and entrepreneurship. I used to invest money for large institutional clients, including pension funds, university endowments, and sovereign wealth funds. I understand a bit about economics. I too came here from somewhere else, yet I have earned the respect of many locals. I am asking the citizens and visitors of North Carolina to not fall prey to the hyperbole and fearmongering you have so generously supplied.

First off, oyster farming is not an unthinkable interference for boating and fishing. In fact, we have the support of recreational and commercial fishing organizations in North Carolina, as well as almost all environmental non-profits and universities. Wild oyster populations sit near 5% of historic levels. Educated people understand that without oysters, you have fewer fish and lower water quality. Oysters are a keystone species. Most aquatic species depend on the humble oyster. Heavily populated areas like Indian Beach are most vulnerable to water quality issues in their bordering estuaries because of developmental impacts. We (oyster farmers) are actually enhancing and restoring the ecological treasure of which you speak. You’re welcome.

Calling coastal North Carolina an economic miracle is a bit of a stretch. Yes, tourism in the Outer Banks is an impressive revenue generator. Those tourists/visitors can’t seem to get enough of the wonderful oysters grown locally. Just because one retires to coastal NC and lives off savings or a pension does not mean everyone lives that way. Home price appreciation recently has been impressive also. It’s not due to any economic miracles. It also prices locals out of their home markets.

The first item you mention on your list of reasons to move to coastal North Carolina is “good food.” Let’s focus on that one, since oysters are arguably the “greenest” and most sustainable form of protein production on Earth. Growing oysters is a regenerative farming practice that improves the environment, as shellfish filter our estuaries. Oysters have a negative carbon footprint. Gram for gram, oysters are the most micronutrient-dense food on the planet, second only to beef liver. Not only are oysters nutrient-dense, they are full of vitamins and minerals in which Americans are most deficient, namely Zinc, Iron, and Vitamin D. Oysters contain all three major classes of omega-3s: ALA, DHA, and EPA and fall within the top-ten most omega-3-rich sources of popular seafood, with about as much omega-3 as swordfish and bass, but with significantly less mercury. For a country that is overfed and undernourished, and a world that’s experiencing a crisis in ocean health and marine pollution, oysters are one of the best crops you can grow. Did I mention they are delicious?

You say that oyster farms in this state could possibly take up “thousands of water acres.” That would be wonderful! Back of the envelope, there are 1,900 square miles (1,216,000 acres) of water contained within North Carolina estuaries. If we grew our industry to 10x where it is today and farmed 10,000 acres, we would be using less than 1% of our estuary to filter the remaining 99%. Water quality and fishing would return to levels not seen since the early 1800’s. So you know, one adult oyster filters up to 50 gallons of water per day.

Everyone consumes what farmers produce, yet many folks complain about what farming looks like. Some people think oyster farms are beautiful. Most are below the surface, and very little protrudes from the water column. Nearby oyster farmers may view your house, your boat, or your dock as visual pollution. Those items certainly take away more from a natural landscape that an oyster farm. If one buys a piece land that is surrounded by acreage that one did not purchase and then someone builds a farm next door, one’s view changes. C'est la vie. There’s always Alaska.

Just for the record, no oyster farm anywhere generates “sewerage (sp)”, even when spelled correctly. Oysters are often consumed raw and fecal coliform bacteria from development runoff and wildlife is monitored by the Shellfish Sanitation Division of DEQ. If it rains a half inch in some densely populated locations, oyster farms become polluted temporarily because of what is coming from developed land. So while you and others complain about visual “pollution”, we as an industry suffer from actual pollution.

Also for the record, most obstructions and storm debris that end up in our estuaries post-hurricane come from boats that have come untethered, poorly constructed docks, and the junk most people keep in the flood zone under their homes and around their property. If our grow-out gear leaves our leases after a storm, we are very eager to get it back. Our livelihood depends on that gear and the oysters inside. How many people that you know who own houses in a flood zone track down the debris that leaves their property and ends up in our estuary? How many recreational fisherman you know dive overboard to retrieve a lure that snapped off a line? I’m guessing that if you multiply those two numbers together, you get 0.

No oyster farmer is wanting to ruin a sunset view. In fact, we love them too. But here’s the thing… you don’t own the viewshed. You don’t even lease it. In fact, the shellfish industry made a good faith effort to negotiate some parameters with DCM for floating structures before that effort was blown up by ignorant NIMBY folks. At any time, an oyster farmer could have simply purchased an old rusty barge of any size and anchored it on ones’ lease and conducted farming activities aboard. Still can. If you were a judge, read up on maritime law. If you’re bold enough, I suggest you try to change it. Good luck! (Basically, there is nothing you can do to someone anchoring in your viewshed, even if they keep smelly shrimp heads on board baking in the sun, just to spoil your sunset cocktails).

North Carolina will not “lose thousands of jobs in sales, services to homeowners, rentals, hotels, and restaurants” because of shellfish farming. To the contrary. For every oyster grown locally and shipped out, more money flows into the local economy, and twice as much money flows into the areas in NC where they are consumed. If we don’t do something to protect and improve water quality (like growing oysters) as more development occurs at our coast, we will eventually ruin it. Tourism, fishing, and real estate values are all negatively impacted if water quality goes down. We are here to help. For free, for now (in some states, oyster farmers are eligible to receive money in a nutrient credit program that offsets developmental impacts).

As head of the North Carolina Shellfish Growers Association, a board member for the East Coast Shellfish Growers Association, and an owner of two oyster farms and an oyster seed nursery, I am a bit of an “expert” and most likely spend more time outdoors on the water than you do. Love that fresh air. When you ask average folks walking Indian Beach who come from Florida, New York City, Chicago, (folks from Seattle know the shellfish industry well and love it, so they get a pass), Los Angeles, and Miami who know nothing about shellfish aquaculture, yes, you will get ignorant responses when viewshed fears are stoked. They don’t understand that shellfish growers are actively repairing the negative impacts they inadvertently caused. I suggest you educate them with the information I have imparted, gratis.

I’m sorry, but this paragraph of yours gave me a good chuckle.

“Is this state initiative for artificial oyster farms about what’s good for coastal North Carolina, and our economy, or what’s good for the business profits in the pockets of a few private individuals - those people who hire lawyers and lobbyists in Raleigh, or ‘know important state officials,’ or make election campaign contributions...those people.”

We’ve never spent a dime on a lobbyist or lawyer for our industry. I don’t know any important state officials personally. I’ve never made any campaign contributions privately or as an association. Every shellfish grower in this state is a small “mom and pop” operation, like many commercial fisherman. We battled and won to keep out industrial scale shellfish farmers (from Canada) who did hire a slew of lobbyists, and who did apply political pressure. They had deep pockets. We still beat them. I have not even spent a dime of membership dues for the several years I’ve been president. Everything I do for this industry is volunteer work. Do you know who originally promoted the growth of the shellfish industry in NC? North Carolina Sea Grant (administered by NC State University), North Carolina Department of Agriculture, North Carolina Coastal Federation, and members of our General Assembly. Why you ask? If you’ve read what I’ve written, you should know by now. If not, please re-read what I have written. It’s important.

To you, I say this. We have had unanimous support from the entire NC General Assembly during a time of extreme political polarization. That’s right, unanimous. Not one member of the House or Senate voted down our bills, and all agreed to expand the shellfish industry. I bet it’s hard enough to get Town Commissioners to agree unanimously on something, right? Anyone who is educated to the benefits of what we do, and the ecosystem services (filtration) our crops supply for free to our State, is more than happy to support the shellfish industry. I suggest you put on the hat of an impartial judge and reconsider your stance in light of the information I have supplied.

Please visit the Chadwick Creek Facebook page and let Chris know how much you appreciate this thoughtful response.  

Comox, British Columbia. The British Columbia ShellfishGrowers Association has partnered with BlueTrace to bring industry-leading traceability technology to BC shellfish businesses. 

“The shellfish growers of British Columbia raise some of the best oysters, clams, mussels, scallops, and geoducks in the world. We are excited to help these innovative farmers continue to develop a safe, and prosperous industry.” says Chip Terry, Ph.D., CEO of Maine-based traceability and food safety company BlueTrace.

For over 60 years, the BCSGA has sought “to advance the sustainable growth and prosperity of the BC shellfish industry.” Their membership includes growers, harvesters, processors, and industry supporters and vendors. 

The Department of Fisheries and Oceans Canada, in line with regulatory bodies the world over, is stepping up its efforts at supply chain traceability to help prevent and react to outbreaks of shellfish diseases such as Vibrio and Norovirus. The initiative involves bolstering and standardizing tagging and traceability requirements for shellfish businesses. With more visibility into the supply chain, regulators will have the ability to quickly and precisely identify the source of any tainted product. This minimizes the extent and duration of costly recalls – while keeping consumers safe.  

“It is important for the industry to stay vigilant in a time of rising temperatures. A digitized traceability system for the entire industry raises the bar on food safety and ensures that our members can build their businesses without drowning in paperwork. We are pleased to be working with BlueTrace, DFO and our members to build a sustainable future for shellfish in British Columbia,” says Nico Prins, Executive Director at BCSGA. 

To help members comply with the new regulations, BCSGA reviewed all existing options in the marketplace and secured funds to help members purchase the best solution for their individual businesses. BlueTrace met all their requirements for flexibility, ease of use, alignment with regulations, and affordability. 

Currently used by over 150 shellfish businesses across North America, BlueTrace develops technology that allows anyone dealing in shellfish to easily comply with federal, state, and provincial regulations. Their combination of apps and printers saves shellfish growers and dealers time by reducing redundant data entry and expediting tagging and logging. Through collaboration with the BCSGA, the company has tailored their solution to specifically address the new regulations in BC.

About BlueTrace: BlueTrace offers the easiest and most powerful traceability solution for shellfish growers, wholesalers, distributors, and dealers. Its streamlined app enables organizations big and small to optimize their activities, comply with regulations, and keep up with their inventory.