Smart Steps to Peak Traceability

According to Monitor Deloitte, to understand the impact from FDA’s Food Traceability Rule, companies should consider taking four deliberate steps toward compliance:

1. Data Readiness. Unlocking value with traceability should start with a system-wide focus on standardization, digitization, and unique identification. Since data becomes less reliable and more expensive to maintain the further it moves from its source, standardization practices should begin in the first mile. Consider:

• Do you currently use standards or frameworks to manage your supply chain data?
• Do you understand the source of existing data and where it is stored? Is it in a central repository or scattered across multiple source systems?
• Which KDEs are not captured to date? How will you begin capturing this data?

2. Processes Readiness. The physical-to-digital link established by the unique lot code should be maintained for each product as it moves through the value chain. Companies should assess current processes to identify areas where traceability may be compromised. Consider:

• Do you currently capture lot codes for food products?
• Where is the traceability of products lost within physical processes (e.g., transformation)?
• Where are the gaps within your existing physical-to-digital link? Maintaining labeling at the most granular product level of handling (e.g., case, item) is a helpful tool for maintaining traceability in many instances.

3. Stakeholder Readiness. Compliance with the FDA’s Food Traceability Rule requires widespread effort and coordination across a company’s supply chain. Mechanisms to share traceability data may likely need to be agreed upon between supply chain partners to promote the digitalization of traceability data. Consider:

• How will you promote supplier and customer compliance with traceability requirements?
• How will you manage exempt suppliers?
• How will you send traceability data to customers?

4. Technology Readiness. The FDA’s Food Traceability Rule does not stipulate the use of any particular digital technologies. However, the sheer volume of data required to maintain the needed granular level of traceability will be challenging to manage without digital records. While implementing digital systems to achieve lot-level traceability might seem costly, improving current recall processes can have a significant upside. Consider:

• Which supply chain technologies require changes or enhancements to support data capture?
• How will you account for the growing volume of traceability data required to be retained?
• Will you manage the traceability data yourself or outsource to third parties?

Source: FSMA Section 204: Traceability and Tracking in the Food Industry: Using Digitalization to Track and Trace Foods in the Food Value Chain, Monitor Deloitte, 2023.