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Wes Kline
By now everyone has heard about the cyclospora outbreak. You may be thinking that it has no impact on me since there has been nothing traced to a New Jersey farm. It is all Mexico why are we bringing lettuce or anything from Mexico? Part of the answer is the market demands the same fresh fruits and vegetables in the supermarket for 12 months a year. Also, it can be grown cheaper in some other countries than we can grow it here.
The impact that cyclospora will have on every wholesale grower is traceability. The implementation of the Traceability 204 Rule under the Food Safety Modernization Act has been delayed until July 2028 at the request of the industry. Considering Cyclospora I am sure there will be no further delays. If you have not started working on a traceability system for your operation time is getting short. Yes, it is July 2026, which means it is two years away, but this is not an easy process, and you need time to test whether your plan will work. Start out by talking to your buyers about systems they are using or recommend. Do not talk to just one buyer, but all if possible. There is probable differences among some of your buyers. That is why it is important to start now! After getting the opinions of the buyers start looking at computer software and programs. There are several companies that have developed programs, but know how it works and the cost? There may be an initial charge and an annual fee for updates. Make sure you know the total costs before signing any type of agreement.
The Food and Drug Administration (FDA) has developed a list (Food Traceability List) https://www.fda.gov/food/food-safety-modernization-act-fsma/food-traceability-list that covers the crops that must be traced. However, larger buyers are probably going to require a grower to trace all the produce whether it is on the FDA list or not.
For growers who fall under the rule a traceability plan is required which includes:
• How the records are maintained, including the format and location of the records
• Description of the procedures used to identify foods on the FTL list
• Description of how traceability lot codes are assigned
• Contact person who manages the records
• Farm map showing the areas where commodities are grown and name of each field
including coordinates
• Plans must be retained for 2 years.
Records must be maintained for every “Critical Tracking Event (CTE)” which is an event in the supply chain of a food involving the harvesting, cooling or initial packing, shipping, receiving or transformation of a raw agricultural commodity. Along with the CTE are “Key Data Elements (KDE)” which is the information which must be maintained. So what records are required?
• The commodity harvested
• Quantity and unit of measure of the food harvested (e.g. boxes, pounds, etc.)
• Name of the field or growing area including GPS map coordinates
• The date of harvest
• Farm name, address and phone number of the operation
Lot codes will need to be assigned when the commodity is packed. The same lot code will be used throughout the marketing system. These lot code numbers do not need to be attached to each box or container. They do need to be on a bill of lading, invoice, etc., but don’t be surprised if the buyer wants the lot code on each box.
When a product is shipped there must be an identifier either through a bar code or on an invoice which lists the
• Traceability lot code
• Quantity shipped (cases, boxes, etc.)
• Product description (e.g. cilantro 12 bunches)
• Receiver of lot
• Location from where shipped
• Date shipped
There are some exemptions to the rule:
• A farm with sales of less than $25,000 on a three-year average adjusted for inflation based on the year 2020
• Food sold or donated directly to consumers
• Food packaged on the farm to prevent contamination, but a label must be attached that has
the name and complete address with a phone number
• Note: clamshells or vented containers are not exempt
• Food delivered directly to a restaurant, school, institution or under USDA food programs
• Commercial processing that reduces a public health risk
For anyone who wants more details go to: https://www.fda.gov/food/food-safety-modernization-act-fsma/fsma-final-rule-requirements-additional-traceability-records-certain-foods.