In 2019, FDA announced its “New Era of Smarter Food Safety” approach for which it is developing a strategic blueprint to outline how it intends to leverage technology and other tools to create a more digital, traceable, and safer food system. In late 2019, FDA held a public meeting at which it sought public input on specific areas of the blueprint. One of these, tech-enabled traceability, elicited a wide range of input from participants, with suggestions for both FDA and the industry; statements on the inevitability of whole-chain traceability and the need to prepare for it; and ideas for specific methods of implementation — from whole-industry application of the Produce Traceability Initiative (PTI) model to blockchain. The following details some of the most prominent points from the sessions along with interviews with three key experts who attended.
With the question of regulation vs. self-policing an undercurrent of the session, QA asked the experts whether traceability should be mandated and regulated beyond the currently required one forward/one back. Both BLloyd Consulting President and Owner Barbara Lloyd and Procurant Food Safety Solutions General Manager Ian Duffield agreed that it should be regulated. “Traceability costs money and someone must pay; inevitably this means the consumer,” Duffield said. “If some suppliers and retailers are allowed to opt out of the program, then that will create unfair market conditions. So I believe federally regulating traceability is the only way we will get 100% coverage across the perishable food supply chain.”
The industry tried to implement traceability with the voluntary PTI initiative, but it failed to be fully adopted, particularly by retailers, he said. “Until we get more direct regulations, there will continue to be stragglers who will not adopt full traceability, and that creates a major weakness in the program that could lead to gaps in traceability where we’re unable to identify where a product has been bought and sold.”
“The current processes for tracebacks for foodborne-illness events require multiple contacts to make the needed linkages to get to the source details of a product,” Lloyd said. By having access to the products’ origins (including supplier, applicable date, and lot number) at each step in the supply chain, the process can be jumpstarted at the starting point and end point in tandem to diagnose issues much faster, she said. “As an industry we cannot continue to be seen as fumbling in trying to get to this data quickly and efficiently.”
While ripe.io President and Co-Founder Phil Harris does expect traceability regulation to increase, he sees it as a Pandora’s Box — bringing with it as many issues and questions as potential solutions and answers. “Traceability is a big word in regards to a regulatory framework,” he said. “But in the context of product recall, it’s not good enough.” Whether talking food safety, sustainability, animal welfare, or any other value concern, it has to go deeper. As such, he said, “I have a lot of faith in the industry, but if the anvil does drop, we’ll likely see more regulation.”
“The hardest part of the implementation of a traceability system is the beginning and the end,” Duffield said. There is a lot of knowledge about the middle, such as that listed on an advance shipping notice, or inbound delivery record, but, he said, “You have to collect the data in the field and track it through the cooler, through to the distribution, all the way through the process to the store. If that doesn’t happen all the way through the process, having the data in the middle doesn’t help you.”
Part of the challenge that FDA would have in regulating traceability is the implementation and maintenance of a system from the beginning to the end, he said. “But I believe that unless there are more regulations about managing the implementation of traceability, then we’re going to be talking about this in another 13 years.”
So, is end-to-end traceability inevitable? If so, what does it mean to food manufacturers? “It’s going to happen. It’s inevitable,” Harris said. “The food industry has to digitize; it has to do it fast; and it has to get going now.” Harris’ background is in finance, an industry which has been made significantly more efficient through digitization. “Look at other industries and how much more efficient they have become when they embrace digitization. Things like waste and fraud and inauthenticity are all manifestations of a supply chain that is very analog and inefficient.” It’s all about data, he said. “Going from apple stock to real apples is not that much of a leap.”
STEP BY STEP. So how does a food business get started? What are the first steps? What do the first 90 days look like?
“It is definitely a multi-step process that needs an organized and coordinated approach across company functional groups,” Lloyd said. “There are multiple work streams to complete, but there is a logical sequence to tackling this initiative.”
The first step is to agree with your supply chain and partners on how to identify items and facilities; ensure you are all speaking the same language and work together to set a traceability framework and standards; then identify, capture, and share the product movement data at specific points in the supply chain. “We keep looking for the perfect, and we’re ignoring the possible,” she said. “There are technologies today, base technologies; they’re not sexy, but you can do traceability from the fields.”
Think about the minimum scanning that could be done to link a food with each downstream customer with a simple, affordable solution for the restaurant or retailer to capture the data. “We need to talk a single language, and we just need to capture that product as it changes hands, as it skips through the supply chain,” Lloyd said. “Once that is possible, we as an industry can begin to look for the perfect. We can’t get to perfect by the end of the year. We can get to possible by the end of next year. And I think that’s what we need to focus on.”
The most difficult part of implementing traceability is capturing accurate information at the source — which, for many produce growers means in the field, and for processors, means at receiving — then following products through to their final sale. While, in both scenarios, it’s difficult to capture accurate information at the source, it’s far from impossible, Duffield said. “Companies have had field-pack traceability solutions available for 10 years now. It’s more a case of a willingness to take on the responsibility — and, of course, the cost — than it is, that technology is not available.”
As a standard for labeling produce items and a foundational step in traceability, PTI is one of the most noted initiatives currently in use, however it does not address actions that need to occur downstream. Labels with standardized barcodes provide identification for traceability, but unless these barcodes are scanned, assessed, captured/stored, and shared, they are just another element on a case label, Lloyd said. “Traceability initiatives have suffered from siloed actions and investments without coordination with all partners on how to implement to everyone’s advantage.”
Additionally, Duffield said, PTI can work, but it will take some directive from government to essentially force retailers to adopt the technology. “The growers and shippers built some traceability into their processes, but it wasn’t followed all the way through.” Even though some put PTI labels on their cartons, the cartons weren’t scanned at the stores, he said.
BUZZWORDS. While the discussions followed a number of lines during the sessions, there were some keywords and points that continually arose. Following are a few of these, with some further insights from the experts:
- Global Harmonization (e.g., common standards, language, and identification) Lloyd ranked this as the most important of the criteria for a successful traceability initiative, stating, “As an industry, we must begin speaking the same language. Identifying items in a consistent way is the foundation for capturing and sharing usable data.” We cannot continue “talking” in different languages along the supply chain, insisting on our own unique identifiers for items and facilities.
Affordability and Sustainability. Any initiative needs to have solutions for every size business. For most, there are simple solutions to fit their part in the supply chain, “but what I’m seeing is that many companies have gotten quotes for overly complex solutions that look to be unaffordable,” Lloyd said. “I’d urge companies to spend some time understanding exactly what data their partners need, exploring different solutions to meet the need, and getting multiple proposals for implementing.” Additionally, a traceability scheme can’t be “one and done,” she said. It will require ongoing monitoring and testing to assure all is working correctly and accessing good quality data.
“Affordable implementation and cost- effective maintenance and sustainability are key to a program’s success,” Duffield said. High-risk field-packed crops are often the basis of recalls, but they are low margin, so adding any cost for a traceability program may be a problem. In fact, with the low margins of the entire food industry, added traceability costs at any link in the supply chain are likely to be passed along to consumers.
- Federal Regulation and Collaboration. We’re likely at a point where federal regulation may be the needed direction, Lloyd said. “Though it’s never preferred, I’ve been working within the industry for 10+ years, and there still continues to be resistance.” As noted by a session participant, however, this will require that FDA be given enough funding to do so. Noting that FDA already has difficulty enacting and implementing regulations, it was asked how an agency, that is consistently underfunded by Congress and the Administration, implements things that will cost money to do right.
- Incentives. A successful traceability initiative will need to be symbiotic with all parties having some benefit, Harris said. This could be making more money, becoming more efficient, gaining access to more buyers or markets, etc. “All other elements are waterfalls outside of these,” he said.
Harris’ stance was backed by a participant’s statement in the session who said that FDA should collaborate with USDA to make access to some subsidies be contingent on behavior changes at the farm level. He gave the example of a label certifying that the food is safe that would be available only if certain changes were made. In this way, the label could carry a premium in the marketplace.
Despite the challenges and questions that remain with whole-chain traceability, the industry needs to step up to the plate and assume responsibility for the food it produces. As Lloyd said, “We need to stop looking for reasons to resist agency actions during outbreaks and work to find solutions that can quickly get the data needed so we appear efficient and confident in our recordkeeping when faced with these outbreaks.”