5 Traceability Challenges Retailers and Foodservice Operators Must Overcome

Proposed FSMA Rule 204 has raised many concerns among retailers, distributors, and foodservice operators. The current draft of the rule poses significant challenges for enterprise-level brands who need to ensure compliance across a broad supplier network. Here are 5 of the biggest traceability obstacles for large companies with complex supplier networks.

1. Limited Visibility from One-Up, One-Back Traceability

The current draft of FSMA Rule 204 requires Key Data Elements (KDEs) to be collected during Critical Tracking Events (CTEs) in the supply chain, such as growing, shipping, receiving, and transformation or creation. In the event of an outbreak investigation, the FDA requires all this traceability data within 24 hours. 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 original traceability lot code 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? As a receiver, you can record the data yourself, or you can ask your suppliers to send it to you in advance, then verify it upon receipt of the product. If you choose to go the manual route and record the KDEs yourself, your suppliers must, at a minimum, provide you with the lot code for the product. Visit the FDA’s resource page on KDEs 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, most traceability platforms don’t talk to each other – they lack interoperability and data ingestion capabilities.

Interoperability means two platforms are compatible and can pass data between them, while data ingestion means that a platform can take in data from multiple sources and store it in one place. The technology industry is currently working towards better data sharing capabilities. This is the only way we can make meaningful progress on food safety and traceability issues.

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. This could be as simple as requiring SSCC pallet labels and case labels that meet PTI standards. You could also 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 is where a traceability vendor can help. However, 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.

Learn More about Network Traceability from iFoodDS

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.

iFoodDS understands the needs of enterprise-level retailers, distributors, and foodservice operators. We designed our traceability solution to manage transparency across a vast supplier network. With tools like a simple web portal to onboard suppliers, traceability dashboards, and ongoing technical support, we make it easy for enterprise-level organizations to gain a real-time view of their supply chain.

5. Uncertainty about the Traceability Requirements for Retailers and Foodservice Operators

Perhaps the biggest challenge retailers and foodservice operators face is uncertainty around future Rule 204 requirements. The final rule will be published on November 7, 2022, and a question that hasn’t been answered yet is whether the FDA will mandate traceback from the store/restaurant. In other words, will DCs be considered shippers, and will stores and restaurants be considered receivers? It will be exceptionally difficult for retailers and foodservice operators to record the shipper/receiver KDEs given labor, space, and time constraints.

If the final rule does mandate KDE collection during shipment and receiving from your DCs, then technology can help collect these KDEs more efficiently. For example, Voice Pick Codes, which are already on every PTI case label, were developed to increase order picking efficiency at distribution centers. KDEs can be tied to the unique GTIN and lot number, and your team can use the Voice Pick Code to quickly pull that information.

Lastly, shipper KDEs are almost identical to receiver KDEs, so your distribution and retail/restaurant teams can share data to facilitate KDE collection.

Where Do Retailers, Distributors, and Foodservice Operators Start?

While FSMA Rule 204 hasn’t been finalized yet, you can take steps to prepare for Rule 204 now. Start by understanding how exposed you are with your current supplier network. Ask yourself:

• Do you know which suppliers are using SSCC pallet labels and/or case labels that meet PTI standards?
• 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.