Food Traceability MattersThursday, November 19, 2020
As part of the New Era of Smarter Food Safety Blueprint, the United States Food and Drug Administration (FDA) has proposed a Rule for Food Traceability. This rule was issued September 23, 2020 and is seeking to implement traceability record-keeping in addition to the requirement of current regulations. The full name is Requirements for Additional Traceability Records for Certain Foods. It is now open for public comment for 120 days; comments must be submitted to the FDA by January 21, 2021.
Why is it of importance to Jamaica? It is important because North America is one of Jamaica's largest export markets and the products under the influence of this regulation are classified as food and beverage. This means that Jamaican manufacturers who intend to export to the United States, either directly or indirectly, must comply if their food item is on the FDA's Food Traceability List (FTL).
The FTL is a register of high-risk foods that was generated from the FDA's risk ranking model. It currently contains 16 food categories and their descriptions. Unless there is an exemption, it should be noted that it is applicable to not only the food itself (eg melon) but to the product if the food is an ingredient (eg fruit juice containing melon). Will the current FTL change? This is dependent on the result of the proposed Rule for Food Traceability.
According to the FDA's website, the new proposed Rule for Food Traceability is applicable for those who manufacture, process, pack or hold foods on the FTL. One of the known weaknesses of Jamaican food business operators is good record-keeping. This will have to be improved/strengthened, as they are required to establish and maintain the Key Data Elements that is linked to different “Critical Tracking Events”. In the proposed rule, growing, receiving, transforming, creating and shipping are identified as Critical Tracking Events that will require Key Data Elements. Food business operators will want to find out which Key Data Element is applicable to them; this information can be found at https://www.fda.gov/food/food-safety-modernization-act-fsma/which-key-data-elements-would-apply-me.
Commonly, food business operators use the “one step back, one step forward” approach to food traceability. However, the approach to record-keeping for this is not standardised. The FDA is proposing that through this new rule there will be a standardised approach with the same or similar ways of capturing the data. As put forward in its New Era of Smarter Food Safety, the FDA intends to capitalise on digital technology to streamline traceability from farm to fork.
Why does traceability matter? It matters to manufacturers, processors, exporters and consumers as it is a critical element to the entire food chain. Traceability is the visibility of products from farm to fork inclusive of process traceability. The FDA summarises its intention as:
“The proposed requirements are intended to help the agency rapidly and effectively identify recipients of foods to prevent or mitigate foodborne illness outbreaks and address credible threats of serious adverse health consequences or death resulting from foods being adulterated or misbranded. We are issuing this proposed rule in accordance with the FDA Food Safety Modernization Act (FSMA).”
Food business operators who manufacture, process, pack or hold foods on the FTL are being encouraged to find out more about this proposed rule at https://www.federalregister.gov/documents/2020/09/23/2020-20100/requirements-for-additional-traceability-records-for-certain-foods.
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