5 Traceability Challenges Retailers and Foodservice Operators Must Overcome

Note: This content has been updated to reflect the final version of FSMA Rule 204.

FSMA Rule 204 has raised many concerns among retailers, distributors, and foodservice operators. The final Rule poses significant challenges for enterprise-level brands who need to ensure compliance across a broad supplier network. However, working together with trading partners can help alleviate the burden. Here are 5 of the biggest traceability obstacles we’ve identified from talking with our industry partners and some ideas for navigating them.

1. Ensuring the Accuracy of Supplier Information

FSMA Rule 204 requires Key Data Elements (KDEs) to be collected during Critical Tracking Events (CTEs) in the supply chain, such as shipping, receiving, and transformation. In the event of an outbreak investigation, the FDA requires all this traceability data within 24 hours (with some exceptions). Although each supply chain participant is required to keep their own records, you will need information from your suppliers to accurately record your KDEs.

For example, when you receive a shipment of produce at your DC, this is considered a receiving Critical Tracking Event. It is the receiver’s responsibility to establish and maintain records containing and linking the traceability lot for the food to “receiving Key Data Elements.” This may sound like a daunting task, but did you know that the receiving KDEs are essentially the same as the shipping KDEs? Additionally, shippers are required to send their KDEs to the receiver, which will make it easier to record your KDEs. To ensure the accuracy of the information, you can ask your suppliers to send it to you in advance through an ASN, CSV, or some other file format, and then verify it upon receipt of the product. Visit the FDA’s resource page on FSMA Rule 204 to learn more about the data you’re responsible for capturing.

2. Lack of Interoperability and Data Sharing Between Different Platforms

The reality is that growers, packers, shippers, and processors use many different food safety and traceability platforms, which can pose a challenge when you’re trying to get an overview of all your suppliers’ practices. How do you receive KDEs and traceability lot codes from these suppliers when they’re using different traceability solutions? Unfortunately, many traceability platforms don’t talk to each other – they lack interoperability and data ingestion capabilities.

Tech solutions in the fresh food industry are currently working towards better interoperability so that companies can better pass data between them and store this data in one place. In the meantime, there are workarounds available such as using an API to exchange information with your suppliers. Your suppliers can also export data in a CSV or other acceptable file format so you can import it into your own system.

3. Lack of a Single Source of Truth

Due to the issue of interoperability that we just discussed, it’s difficult to ensure a single source of truth for your food safety and traceability programs. Different label formats only compound the problem since you may not be receiving all the information you need from suppliers.

One potential solution is to create a formal set of guidelines for your suppliers’ labeling practices. You could create documentation that specifies the Key Data Elements required on each label (regardless of format) and start rejecting any shipments that lack this information.

Once you’ve collected the right data, you need to get it all into one platform to ensure a single source of truth. This leads us to the next obstacle: the complexity of setting up a platform for your supplier network. You need a vendor that can manage this high volume of suppliers.

4. The Complexity of Onboarding All Suppliers

Your suppliers vary in size and capabilities. How do you find a solution that fits every budget and is easy enough for everyone to use? Furthermore, how do you deal with suppliers who are resistant to or confused by all the traceability options available? There needs to be a balance between enforcing consequences for those who choose not to participate and providing ample support for those who are simply overwhelmed.

Go beyond setting requirements for your traceability program and offer active assistance to your suppliers. For example, give them low-cost options for recording their KDEs and provide multiple ways to submit the traceability data you need. To accomplish this level of support, you need more than a traceability vendor. You need a partner who can assist your suppliers during the process and offer ongoing technical support. This partner should have a tracking system so you can see in real time which suppliers have met your traceability program requirements and which ones need an extra reminder. Ideally, the vendor will create a seamless onboarding experience that will make it easy for your suppliers to participate.

5. Traceability Requirements for Last-Mile Delivery

Perhaps the biggest challenge retailers and foodservice operators face is the requirement to collect traceability data during last-mile delivery from the DC to the store or restaurant. The FDA has clarified in the final Rule that DCs are considered shippers, even if they are owned and operated by the retailer or foodservice operator. This means DCs need to record shipping KDEs and send them to the store/restaurant, and the store/restaurant must record receiving KDEs.

These new requirements are complex and place an additional burden on retailers and foodservice businesses that are already struggling with labor shortages and supply chain issues. However, the right technology can help you efficiently collect your KDEs. You may already have a system that is collecting KDEs, but you should confirm it collects all of the required data and gives you the ability to pull that data within 24 hours. A traceability software solution with enhanced reporting capabilities will enable you to access your traceability data whenever you need it. Digital solutions can help ease the burden of compliance for enterprise-level brands.

Learn More about Network Traceability from iFoodDS

Where Do Retailers, Distributors, and Foodservice Operators Start?

Now that FSMA Rule 204 has been finalized, you should take steps to prepare for its enforcement. Start by understanding the current state of your supplier network. Ask yourself:

• Do you know which suppliers are properly labeling their shipments with labels that contain a GS1-128 barcode? This can be used to easily verify the accuracy of shipment data.
• Are you tracking which suppliers currently send you the necessary Key Data Elements (KDEs)?
• Have you educated your supply chain partners on the importance of traceability and the need to capture Key Data Elements?

At a bare minimum, you should think about doing an audit of your supply chain. From there, you can understand the areas where you may be exposed to food safety risks. If you’d like to start taking proactive measures to get your suppliers’ information into one platform, reach out to iFoodDS for a consultation. We can provide more information about our Network Traceability solution and answer any questions you have.

This material is for informational purposes only and not for the purpose of providing legal advice. You should contact your attorney to obtain advice with respect to any particular issue or problem.