Introduction: traceability rule checklist FDA

According to the Food and Drug Administration (FDA), a stringent new food law will go into effect on November 7. The new law applies to the following food traceability list, which includes “high- items” linked to food-borne

Cheeses other than hard cheese
Cucumbers
Finfish
Fresh
Fresh-cut fruits and vegetables
Leafy greens
Melons
Mollusks
Nut butters
Peppers
Ready-to-eat deli salads
Shell eggs from domesticated hens
Sprouts
Tomatoes
Tropical tree fruits

The traceability rule by the FDA

Read the article here.

The rule mandates a complete account of food origins and movements throughout manufacturing, processing, and transportation to make these foods safer. This applies even when these foods are changed into other food or are mixed with other foods. 

Based on the article, keeping vast records is nearly impossible with the means of pen and paper or even simple spreadsheets, as many foods are traced back through several processing stages. Thus barcoding has never been more necessary. Barcode systems provide cost-effective, dependable, and user-friendly solutions for tracking origins and destinations from start to finish.

An is when a whole salmon is processed into filets and afterwards salmon cakes. Each step of the process must be traceable back to the and the boat from which it was caught. Similarly to other products such as fresh fruits end up in salads. 

Key Data Elements and Critical Tracking Events

These essential data points are referred to as Key Data Elements (KDEs), in the new FDA rule. Furthermore, Critical Tracking (CTEs) are steps in the manufacturing process. The article highlights the Critical Tracking Events and their mandatory KDEs, as seen in table 1.

CTEsKDEsDetailsDetails
GrowingFor produce; the grower generates a lot of code for the grown food.
ReceivingAt the arrival of any food, the lot code must link the following information:Location identifier and location for the food’s immediate preceding source (other than a transporter)
Entry number assigned to the food (if imported)
The location identifier and description of the site where the meal was received, as well as the date and time the item was received
The food’s quantity and unit of measurement (e.g., 6 cases, 25 returnable plastic containers, 100 tanks, 200 pounds)
Food traceability product identification and traceability product description
Traceability lot code generator location identification, location description, and point of
Reference type(s) and reference record number(s) (e.g., “Invoice 750A,” “BOL 042520 Y ”) for the records relating to the receipt of the food
The sender’s name who delivered the food to the recipient
The proposed rule will include the initial receiver designation, which will necessitate extra information. A first recipient is the first person (other than a farm) to buy and physically possess a listed food. Only foods that are originated (i.e., produced, raised, captured, or harvested in the of a non-produce commodity like eggs) can have a first receiver. Stated items that are created do not have a first recipient. *First Receiver (except for seafood obtained from a fishing vessel)Traceability lot code, if not previously established
Location identifier and location description of the originator of the food
Business name/phone number/ point of contact of the harvester of the food + date and time of harvesting
Location identifier and location description of the place the food was cooled, + date and time of cooling (if applicable)
Location identifier and location description of the place where the food was packed; + date and time
First Receiver of Seafood Obtained from a Fishing VesselTraceability lot code, if not previously established
Harvest date range and
TransformationChanging a food on the Food Traceability List, its package, and/or its label (in relation to the traceability lot code or traceability product identification), The food transformer would be e pected to establish and maintain records containing and linking the food’s new traceability lot codeTraceability product identifier and traceability product description
The quantity of each traceability lot
Location identifier and location description for where the food was transformed and the date
The new traceability product identifier and traceability product description
The quantity and unit of measure
Reference record type and number for records
CreationMaking a high-risk product, such as peanut butter, from non-risk ingredients, such as peanuts. Whoever creates a listed product in this manner must establish and maintain containing and linking the food’s traceability lot code.Location identifier and location description of where the food was created, + the date
The traceability product identifier and traceability product description
The quantity and unit of measure
Reference record type(s) and reference record number(s) for records
ShippingWhen food is transported from a defined location to another defined location at a different farm, a first receiver, or a subsequent receiver, the proposed rule would require persons who ship a listed food to establish and maintain records containing and linking the traceability lot code.Entry number(s) assigned to the food (if imported)
The quantity and unit of measure of the food
Traceability product identifier and traceability product description
Location identifier, location description, and point of contact for the traceability lot code generator
Location identifier and description of the immediate subsequent recipient of the food
Location identifier and location description for the location from which the food was shipped + date and time
Reference record type(s) and reference record number(s) for documents relating to the shipment
Transporter’s name
Table 1: The Critical Tracking Events and their mandatory KDEs. Source: adapted from Food News and FDA.

* The first receiver rule’s objective is to trace product movement within or between organizations prior to sale. Depending on whether the food was received from a fishing vessel or not, first receivers must maintain distinct KDEs. Furthermore, the proposed rule would require each first receiver, in addition to the records of receipt of food (receiver KDEs), to establish and maintain records containing and linking the traceability lot code of the food received.

Moreover, the shipper would be required to deliver all of the records listed above, with the exception of the reference record type, number, and transporter’s name, to the next-in-line receiver in addition to preserving all of the records listed above. If the shipper is a farm, they must also provide the following details to the next-in-line receiver, if applicable:

  • ‘’A statement that the shipper is a farm
  • Location identifier and location description of the originator of the food (if not the shipper)
  • The business name, point of contact, and phone number of the harvester of the food (if not the shipper), and the date(s) and time(s) of harvesting
  • Location identifier and location description of the place where the food was cooled (if not by the shipper), and the date and time of cooling
  • Location identifier and location description of the place where the food was packed (if not by the shipper), and the date and time of packing’’ (Sorce: Food Safety News, 2022)

Full details of these can be read at the FDA site.

The FDA recognizes that this will compel a shift away from traditional paper-and-pencil record keeping, but the financial gains will significantly surpass the expenses due to the up to 84 percent reduction in traceback time.

Check our iMIS Food platform and tracking system here.

References:


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