Track & Trace Requirements – Food Safety Modernization Act: 2013 Revisited

(Following the release of important new food safety data, we’re rolling out a five-part series of posts related to progress on the Food Safety Modernization Act and the importance of track-and-trace.)

The Centers for Disease Control and Prevention (CDC) reports that 1 in 6 Americans, or 48 million people, gets sick from foodborne illnesses each year. In addition, 128,000 Americans are hospitalized, and 3,000 die each year from foodborne diseases, according to CDC estimates. These figures are the most accurate to date due to better data and methods used.

In January 2011, the Food Safety Modernization Act (FSMA) was signed into law. The bill increases the Food and Drug Administration’s (FDA) authority over food recalls, allows the FDA to require food producers to have safety plans, and enhances the FDA’s ability to improve the safety of imported foods. The bill, however, does not include any funding provisions to implement the law, estimated at $1.4 billion over five years.

Some of the major provisions that will impact logisticians in the food and beverage value chain.

  • The FDA Commissioner now has the authority to order a mandatory recall when the agency determines there is a reasonable probability that a food poses a health hazard. Previously, the agency could only recommend voluntary recalls of food products resulting from possible outbreaks. The FDA would have to negotiate with the manufacturers of the recall and this delayed the recall process. The law allows the FDA to suspend the registration of a food facility associated with unsafe food, thereby preventing it from distributing food.
  • The Act expands on registration requirements first implemented by Congress in the 2002 Bioterrorism Act. The Bioterrorism Act required facilities that manufacture, process or pack food to register with the FDA, but exempted retail food establishments and farms. The new legislation only exempts family and smaller growers. Initially, however, these smaller companies are only exempt for one and two years after the law is implemented.
  • Imported foods will be inspected and subjected to the same standards in place for US foods. The FDA now has the authority to block foods from facilities or countries that refuse FDA inspections.  The FDA will also increase its inspection of foreign facilities that produce foods imported into the US.
  • The FDA is required to establish, as appropriate, “a product tracing system to receive information that improves the capacity to effectively and rapidly track and trace food that is in the United States or offered for import into the United States.”

The idea of prevention is not new.  The FDA has established prevention-oriented standards and rules for seafood, juice, and eggs, as has the U.S. Department of Agriculture for meat and poultry.  In addition, many organizations in the food industry have pioneered “best practices” for prevention. What’s new is the recognition that, for all the strengths of the American food system, a breakdown at any point on the farm-to-table spectrum can cause catastrophic harm to the health of consumers and great disruption and economic loss to the food industry. So, we need to look at the food system as a whole, be clear about the food safety responsibility of all of its participants, and strengthen accountability for prevention throughout the entire food system – domestically and internationally.  The new law meets these needs in numerous ways.

A provision of the FSMA also requires companies to enhance their track and trace capabilities – rapidly tracing back from where a product was received and tracking forwards to where it was sent. This will create massive amounts of information that companies will have to manage and integrate to provide complete traceability across the supply chain.

The purpose of the discussion in this paper is to examine

a)      Existing track and trace systems to manage food safety

b)      Emerging technologies like RFID and telemetry to mitigate the food safety risks proactively

c)      Explore the opportunities to enhance the food safety, track and trace analytics leveraging data warehousing and ERP systems.

Our next blog in the series will focus on the need for a safe food supply chain.


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