Supermarket Perimeter - March 2021 - 53

FOOD SAFETY

TRACEABILITY
by Andy Nelson

NOMAD_SOUL - STOCK.ADOBE.COM

DELI CHEESES, several produce
commodities, fresh seafood and
deli salads are among the foods
that will be subjected to a more
thorough traceability protocol
under new proposed federal
government regulations.
The US Food and Drug
Administration wants to
establish additional traceability
recordkeeping requirements
(beyond what is already required
in existing regulations) for
persons who manufacture,
process, pack, or hold foods
the agency has designated
for inclusion on its Food
Traceability List.
The proposed rule,
" Requirements for Additional
Traceability Records for Certain
Foods " (Food Traceability
Proposed Rule), is a key
component of the FDA's New Era
of Smarter Food Safety Blueprint
and would implement Section
204(d) of the FDA Food Safety
Modernization Act (FSMA),
according to the agency.
The proposed requirements
would help the FDA rapidly and
effectively identify recipients
of those foods to prevent or
mitigate foodborne illness
outbreaks and address credible
threats of serious adverse health
consequences or death.
At the core of the proposal
is a requirement for those who
manufacture, process, pack

or hold foods on the Food
Traceability List (FTL) to establish
and maintain records containing
Key Data Elements (KDEs)
associated with different Critical
Tracking Events (CTEs). While the
proposed requirements would
only apply to those foods on the
FTL, they were designed to be
suitable for all FDA-regulated
food products. FDA said it
will encourage the voluntary
adoption of these practices
industry-wide.
" (This is) an important, critical
step forward in the US Food and
Drug Administration's efforts
to bring about farm-to-table
traceability in our food supply, "
said Frank Yiannas, the FDA's
deputy commissioner for food
policy and response. " When we
say traceability, what we are
really talking about is the ability
to track a food at every step of
the supply chain. While limited
to certain foods, this proposed
rule would create a ﬁrst-of-itskind standardized approach
to traceability recordkeeping,
paving the way for industry
to adopt and leverage more
digital, tech-enabled traceability
systems both in the near term
and the future. "

Building on FSMA's
foundation
Congress recognized the need
for greater traceability, Yiannas

said, in the FDA Food Safety
Modernization Act (FSMA).
FSMA section 204, Enhancing
Tracking and Tracing of Food
and Recordkeeping, instructs
the FDA to develop additional
recordkeeping requirements for
certain foods to help establish
clear tracing of a food product's
source when needed to address
food safety risks. The proposed
rule, when ﬁnalized, would
implement this key component
of the landmark food safety law.
" We recognize that to fully
realize the public health beneﬁts
envisioned by FSMA, we need to
continue to improve our ability
to rapidly and accurately identify
foods that may be causing illness,
and this rulemaking is part of
that, " Yiannas said. " When FDA
Commissioner Stephen Hahn
and I announced the New Era of
Smarter Food Safety Blueprint
in July, this proposed rule was
presented as the ﬁrst step in our
work to advance traceability. We
want to help protect consumers
by more quickly identifying the
source of contaminated products,
limiting the scope of recalls,
and reducing the risk of illness
or death. "
Advancing traceability, he
added, will also greatly facilitate
timelier root-cause investigations
to learn more about how
contamination occurs in order to
prevent future outbreaks.

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Consumers don't normally
think of food traceability as being
a means of preventing foodborne
illness, Yiannas said, but like
many of the improvements in
food safety over the years, such
as whole genome sequencing,
the proposed rule will have a
direct impact on preventing
foodborne illness.
" More comprehensive
traceability through access to
records of key data elements
associated with critical tracking
events in food production and
distribution has the potential
to help us pinpoint the exact
sources of foods involved in
outbreaks, " Yiannas said. " Not
only does this help us to remove
potentially unsafe products
from the market more quickly,
preventing additional illness
or death, but it also helps us to
conduct root cause investigations
to ﬁgure out what went wrong
leading to the outbreak. "
Without knowing the source
of a contaminated food, he
added, it's extremely hard, if not
impossible, for the FDA to fully
diagnose the problem and work
with industry to develop and
implement strategies to prevent
similar issues in the future.
Recent outbreaks of foodborne
illness tied to fresh produce like
leafy greens and papayas, he
said, highlight the importance of
this work.
MARCH 2021 - 53
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Supermarket Perimeter - March 2021

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