According to the FDA, about 48 million people in the U.S. get sick every year from foodborne illness, and 3,000 people die. The Food Safety Modernization Act (FSMA) was designed as a preventative measure to reduce these illnesses by designating actions that operators must take to prevent contamination as food travels along the global supply chain.
These rules and programs relate to agricultural water, good manufacturing practices, and food traceability. It also includes the growing, harvesting, packing, and holding of produce as well as transportation. The FSMA went into effect in 2011. In 2020, they released an almost 200-page Proposed Rule for Record Keeping for Food Traceability called FSMA 204.
In 2020, the FDA announced new traceability regulations with the coming of FSMA 204. It’s now collecting industry considerations before finalization, which is expected by November 2022. The final aspect of FMSA 204 will go into effect in 2023, with a compliance date of 2025 for the food traceability record.
It enables the FDA to request a business’s Critical Tracking Events up to two years after the event has occurred and receive a response in one day. Though it seems distant, preparing for this regulation in advance is critical to compliance.
FSMA 204 applies to all food on the FDA’s Food Traceability List. These include fresh cucumbers, peppers, sprouts, leafy greens, melons, tomatoes, and tropical tree fruits. Additionally, all fresh-cut fruits and vegetables, ready-to-eat deli salads, nut butters, finfish, and crustaceans are included.
In essence, Rule 204 ensures farm-to-table food traceability. It requires each participant in the food supply chain to respond electronically to FDA requests regarding food on the food traceability list.
The four data requirements include the following:
- If you are considered the first receiver from the farm, as occurs in farm-to-table establishments, you must keep information on harvesting, cooling, packing, and storing the products before receiving them.
- If the product was imported, you must retain and store the import number through the final point of sale.
- Share and store the person who signed the lot number.
- Retail food establishments must record the lot number of every product they sell on the Food Traceability List.
Restaurants are considered a type of retail food establishment.
In case of an outbreak, this data will be used in both trace forward and trace back events. The FDA will standardize the information companies must record, keep, and send to the next supply chain recipient. To achieve this type of traceability requires RFID technology.
How Restaurants Can Comply and Benefit
Radio Frequency Identification (RFID) labels, also called smart labels, tag and track products and monitor inventory. In the same way that bar codes collect and send data using visual scans, RFID labels use radio waves to collect and transmit information.
RFID labels have been used for years, tracking products through each supply chain step, from shipping to delivering and purchasing. Big box retailers use them to tag and track their products and sales.
RFID tags keep operators compliant with FSMA 204 and also improve inventory management. With this unique identifier and online connectivity, chefs, managers, and owners can see how much product they have, when it comes in and when it leaves. This enables them to maintain the quality of their products and easily follow the first one in, first one out (FIFO) inventory motto.
In addition to efficiency and limiting waste, it also improves traceability and sustainability. With RFID technology, you can verify a product’s journey through the supply chain, from source to destination. It also enables a quick electronic response to the FDA should one be requested and swift action in case of a recall.
This electronic wizardry can limit the scope of recalls and avoid blanket alerts. With vital information at your fingertips, you can respond to an emergency food crisis, helping in the investigation while limiting any liability or damage to your brand, and comply with FSMA 204.