The article from the New Yorker is devastating:  A huge Chinese fleet, manned with at least some slave labor destroying the global squid fisheries to put calamari on the plate of US consumers.  

In a deeply researched article, the authors follow calamari harvested illegally off the the coast of the Galapagos, where at least one crewman died, back to China and then on to "at least 62 American Importers" who sold on to Costco, Kroger, Safeway and others.  

Obviously every industry has bad actors and not every bad act can be stopped.  But the industry needs to move to a new system that prioritizes understanding the chain of custody from boat to plate.  There are a lot of government, NGO and commercial efforts to address this challenge.  But fundamentally, the handwritten paperwork driven by well intentioned regulations is letting bad things happen--while killing productivity.  

A digital first system could help expose challenges a lot earlier and make this type of fraud much harder.  To use a couple of example:

1) The Seafood Import Monitoring Program is a really well intentioned program, but the reality of just uploading documents to a government database is not helping weed out IUUs.  And as of this date, squid is not covered by the program.

2) The MSC/BAP/ASC certification programs all rely on in-person monitors who show up once or twice a year.  And even if we think those are effective, certification programs cover less than 40% of the worlds fisheries.

3) The complexity is huge: 80%+ of US seafood is imported.  Seafood is the most traded protein in the world (3x beef).  The number of products is massive (we often see 1,500+ SKUs at a mid-sized distributor).  

So what are the solutions? Having worked with 100s of seafood operations, I would propose a few things. 

1) Mandate digital data in near real time:  Structured data like (time/location of harvest, fishing vessel, size of catch, species caught) that is then passed through the supply chain lets us find bad actors more easily.  For instance, if a ship reports landing 10,000lbs, but buyers report buying 100,000lbs that should  trigger a follow up.

2) Align FDA's Food Safety Modernization Act (FSMA) and the Seafood Import Monitoring Program (SIMP) so they capture the same data in the same format. Making it easier on all the participants. This includes applying a Traceability Lot Code from the beginning of the chain--even on imported products. 

3) Mandate Labels with Key Information: The labeling of seafood with crayons on wet wax boxes makes it way too easy for bad actors.  Some variation of shellfish tags would be a good start.

4) Lean into DNA/RNA testing: Modern tests can tell the location of a catch--if there is a good underlying database to match to. Sample testing key lots to see if the DNA matched the digital record would be highly effective in rooting out bad actors.

5) Keep it Simple and Inexpensive: Make it easy for folks to comply.  This should not be a mandate that costs the entire chain.  Paired with a simple system, should be a reduction of other regulatory paperwork that maybe isn't as important. 

Government, NGOs and the industry all have roles to play, but we should agree that we want to cover 100% of seafood with an easy to use system that gets everyone on the same page.  Stories like that above hurt the entire industry--even though the vast majority is doing the right thing. 

Below are the details of a recall published on August 11, 2023--for oyster harvested in June 2023!!  I sure hope these are not still in circulation.  We checked with our clients and they are all clear. Hopefully no one got sick, but it clearly cost the folks involved a ton of time and hurt their reputation.   

The regulators are doing their job and making sure we all stay safe--and our industry stays healthy.  Let's all help make their jobs easy.  

Bottom line: Pay attention to those rain closures. 

The Virginia Department of Health, Division of Shellfish Safety and Waterborne Hazards is reporting 10,000 oysters were harvested on June 28, 2023, from lease # 20655 in Pungoteague Creek when a rainfall closure was in effect, and therefore, the product which was harvested is deemed unfit for human consumption. The original harvest date is 6/28/2023 and was wet stored until 7/3/2023 and/or 7/5/2023, when the shellstock oysters were shipped and entered into
interstate commerce. Records obtained indicate that the affected product was sent to Texas and Washington DC on 7/3/2023 and to Massachusetts on 7/5/2023. It is not yet known where the product was subsequently shipped and no illnesses have been reported involving this lease and harvest date.

A recall is being conducted. As more information becomes available, updates will be provided.
__________________________________________
Interstate Shellfish Sanitation Conference
4801 Hermitage Road, Suite 102
Richmond, VA 23227
Phone: 804-330-6380
Email: issc@issc.org

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.

The Global Seafood Alliance (formerly the Global Aquaculture Alliance) publishes one of the best seafood podcasts.  The team of Shaun O’Loughlin, Justin Grant, and Maddie Cassidy are awesome.  We were lucky enough to be interviewed recently.  Always fun to talk seafood and innovation with smart and knowledgeable folks.  You can listen on your favorite podcast app or download from their website. 

The New Era of Smarter Food Safety represents a new approach to food safety, leveraging technology and other tools to create a safer and more digital, traceable food system.

-New Era for Food Safety: Blueprint for the Future, FDA, 2021

The Food Safety Modernization Act is not new.  Congress passed the law in 2011 to give the FDA the ability to initiate mandatory recalls and a host of other powers over the food industry.  In 2020 the FDA issued a major proposed update to the rules: “The New Era of Smarter Food Safety.”  Although the final rules will not be published until 2022, the outlines are clear.  

The rule builds on four core elements: Tech-Enabled Traceability, Smarter Tools, Food Safety Culture, and New Business Models. Lots of words and implications. You can read more on the FDA website, but here is our take on what this means for the seafood industry.  

The key update is Section 204 designed in the words of the FDA to “harmonize the Key Data Elements and Critical Tracking Events for enhanced traceability.”  The goal is to have end-to-end traceability that can enable tracebacks in seconds--instead of the current system that often fails and generally takes weeks. Here are some of the implications for seafood companies:

1. Seafood gets special attention:  The FDA ran risk-models on what foods lead to the biggest food safety issues, all seafood (except scallop adductor muscles and catfish) ended up on the list along with leafy greens, eggs and numerous other products. 
2. New Acronyms (KDE and CTE) get added to HACCP: For most distributors, the system will build on their existing HACCP program by mandating the tracking of Key Data Elements (KDEs) through Critical Tracking Events (CTEs).
3. Digital is Required:  The mandate is for nearly every participant to provide a sortable spreadsheet to the FDA within 24 hours of request--essentially meaning that most companies must have a digital record.
4. Lot Codes are Key:  Harvesters are required to put a unique identifier (lot code) on each harvest and that information should travel with the product through the supply chain. 
5. The First Mile will be the hardest: Harvester/Growers are expected to collect and pass key information (including a lot code) about every harvest to the first buyer.
6. Interaction with other regulations is unknown: Most notably the shellfish regulations which already require very similar information and tracking (minus the digital pieces). 

As the diagram below describes, the expectation is that Key Data Elements are passed from one step to the next--so there can be a rapid traceback if there is a problem. 

Although the goal of safer food is a good one and the specific rules are under final revision, the impact on the seafood industry could be far reaching. Here are some of the biggest challenges we see for adoption: 

1. Small non-technical suppliers:  
   1. Fisherman/growers are great at a lot of things. Technology is generally not one of those things.  From that oyster farmer in a Carolina skiff to the lobsterman or the long liner, most harvesters are not using a lot of technology. 
      
2. Long Supply Chains: 
   1. Five plus stops in a chain is not unusual.  Passing information between all those players seamlessly is a big task.  This requires new protocols and standards.  
      
3. Fast turn around:
   1. No one wants rotting fish. Inventory churn is measured in minutes/hours, not days and weeks.  
      
4. Employees turnover is a real problem and there are often language problems
   1. There is little appetite for hiring tech folks or spending large amounts training new employees.  
      
5. Data Sharing: 
   1. Most companies do not want to share who they buy from and who they sell to with others in the chain. Traceability challenges that business practice. 

Anyone who has spent time on a fishing vessel or seafood processing plant, knows that most companies still use a lot of paper and don’t have the systems needed to meet the FDA’s vision of, “food traced to its source in seconds.”  Not to mention, “alerting consumers in real time before contaminated or misbranded foods are consumed.”

There is a lot more to come about this rule, but now is a good time to start thinking about your digital strategy.  How do you collect, store and transfer key information about your product?  

There are solutions out there (including BlueTrace) and you should look at a few.