During last week's Regulatory Update webinar, attorney Jeni Lamb Rogers demystified The Food Traceability Rule and laid out the priorities every specialty food maker needs to know before the final rule is issued during the fourth quarter of 2022.
“The Food Traceability Rule is the last mandatory rule from the Food Safety Modernization Act requiring additional traceability recordkeeping requirements for people who manufacture, process, pack, or hold foods on the Food Traceability List,” said Rogers, associate general counsel, supply chain for Branded. “The requirements will help the FDA quickly identify recipients of those foods to prevent or mitigate foodborne illness outbreaks and address credible threats of serious adverse health consequences.”
Rogers provided an overview of the rule, including affected foods and parties, and rule structure. Here’s are the key takeaways:
The proposed rule covers 15 foods/categories, including:
• Soft cheeses
• Ready-to-eat deli salads
• Eggs
• Nut butters
• Certain fish and shellfish
• Certain produce
• Products that contain any food on the list as an ingredient (e.g., peanut butter cookies, salad dressings)
It affects all persons in restaurants and retail establishments that handle listed foods, such as:
• Producers (produce growers)
• Manufacturers
• Brokers
• Distributors
• Third party logistics providers
• Retailers
This rule requires Key Data Elements to be collected during all Critical Tracking Events, including:
• Growing
• Receiving
• Creating
• Transforming
• Shipping
Additional Traceability Records on top of KDEs are:
• Description of the reference records
• List of all Food Traceability List foods shipped
• Description of how traceability lot codes are assigned
• Supplemental information necessary to understand the firm’s traceability system
• Record retention, form, and availability requirements (e.g., electronic and sortable spreadsheet available within 24 hours of request, maintained for two years)
For more information about how this rule will impact retailers, restaurants, manufacturers, and growers throughout the supply chain, watch the webinar on demand in SFA’s Learning Center.
Related: Consortium Explores Solutions to Proposed Traceability Regulations; Digital Tracking Added to Parmigiano Reggiano.