The FSMA will focus on preventative measures which means traceability will become part of standard industry audits. The implementation of FSMA will happen in phases over the next three years.
Retailers, however, are driving traceability compliance at a much faster pace. In fact, some leading retailers have notified growers regarding a late 2011 compliance date.
Successful grower-shippers must proactively respond to this new business reality.
So, what should you be doing right now to prepare for traceability compliance?
Here are five important action steps:
- You should understand and take action on the seven Produce Traceability Initiative milestones.
The PTI was created by a diverse group of industry leaders that had the vision to see this requirement coming. The group created the PTI as an industry-designed solution. The FDA has publicly stated that it supports the PTI and considers it a model for other food groups to investigate.
In essence, the PTI is a plan to adopt an effective, industry wide Whole Chain Traceability program by combining the use of technology and common standards to link internal traceability programs.
Detailed information about the PTI can be found at www.producetraceability.org. This is the definitive source for up-to-date PTI information including milestones and a host of action items to move you forward with implementation.
- You should define which products you’re going to use for testing.
Perhaps you’ve already identified your GTINs, but you haven’t acted on moving these into your process. This is the time to take action. Start small, identify which products to test on and place these into your existing process.
You must also start active conversations with your customers to better understand their specific expectations and timelines. Communication is vital as this process unfolds.
Some retailers, for example, might not expect you have all products fully compliant by the end of the year, but may expect you to be working toward compliance. Other retailers have finalized their plans and have already issued official compliance letters.
- Communicate with your peers about their process and experience.
You can gain a tremendous amount of insight from talking to operators who have already made progress toward compliance.