by Steve Warshawer

The Food Safety Modernization Act (FSMA) requires the Food and Drug Administration (FDA) to improve methods for tracing products in the food system, especially for high risk foods.  Prior to developing rules and regulations on traceback, Congress is requiring FDA to conduct pilot projects on these traceback methods.  FDA has chosen to conduct these traceback pilots through a cooperative agreement with the Institute of Food Technologists (IFT), a nonprofit scientific society consisting of professionals engaged in food science, food technology and related professions.

Two pilot projects will be carried out by IFT, one in coordination with the processed food sector to demonstrate the tracing of a processed food, and one with the produce sector to explore the tracking of fruits and vegetables.  According to FDA, the organization will conduct mock tracebacks that reflect the diversity of the food supply and are practical for facilities of various sizes, including small businesses.  Researchers will assess the costs and benefits of the methods for rapid and effective tracking and tracing of the selected foods and key ingredients.

After the pilots are completed and additional data are gathered, the FDA will initiate rule making on record-keeping requirements for high-risk foods to facilitate tracing.  The FDA will hold three public meetings during the comment period on the proposed rule.

“Traceback” is an essential element in protecting public health in the event that contaminated product has entered the food system.  Industry has been pushing technology-intensive solutions on a “one size fits all” basis.  In practical terms, traceback is very simple for farm identity preserved foods and for direct marketed foods.  The technology-based solutions, if universally applied, would place a cost burden on many operations who can meet traceback requirements with simple, manual systems.

In the Food Safety Modernization Act, NSAC and NSAC member organizations worked closely with Senator Sherrod Brown (D-OH) and other Senators to secure an exemption from broader traceback requirements for farm identity-preserved foods and for  food directly marketed by the farmer to the consumer or to a grocery store, provided the store keeps a simple record of the source farm.  The Brown language also authorizes FDA, in consultation with USDA, to modify any future traceback requirements with respect to farm to school or farm to institution sales.

The IFT has set up a webpage on the tracing pilot programs.  It includes information on how to send IFT responses to a set of “stakeholder input questions” as well as dates for upcoming stakeholder input sessions in Seattle, Washington, DC, and Chicago, plus a FAQ and other background information.