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.