While the 2028 enforcement deadline looms for the food traceability final rule under the Food Safety Modernization Act Section 204, representatives from Church Brothers Farms, Classic Yam and The Nunes Co. sat down with The Packer to share their companies’ individual journeys toward digital traceability.
Early Lessons From the Frontlines
Traceability has been a standard at Church Brothers Farms since 2016. It was an early adopter of the Produce Traceability Initiative label, says Arlin Valenzuela-Reyes, food safety quality director of recall, customer response and document control with the Salinas, Calif.-based fresh vegetable grower and processor.
“We were a few of the initial companies that implemented that since the initiative came out,” she says.
Valenzuela-Reyes says Church Brothers’ work in PTI has set the company up well for FSMA 204 implementation.
“We have a very organized system as far as inventory and block ID creation, how we enter that into our system and how it follows the supply chain from planting all the way to shipping,” she says.
Church Brothers shares data based on customer requirements. For some, it’s electronic data sharing, but for others it’s sending traceability data through the bills of lading. Valenzuela-Reyes says this includes block ID for field direct commodities and run numbers for processed items that run through the company’s facility.
“We created a page in our company website where our customers can reach out directly to us in case of any regulatory inquiry or internal inquiry regarding the lot code source or the lot code of the item that they are requesting,” she says.
She says one surprising part of adding PTI labels has been the cost of labor. This included buying the equipment, the labels, test labels to find the best option that works with the company’s cartons and RPCs. Valenzuela-Reyes also says the company customizes the information based on the customer, as they have different requirements.
“We basically do what our customer wants, but it definitely adds that complexity to our system,” she says. “The main wish is for all of our customers to have the same requirement as a standardized traceability request.”
Another challenge, says Valenzuela-Reyes, is how the company handles entering the traceability information from purchases from a broker to fill either something that Church Brothers is a little short in or doesn’t grow. This challenge is amplified when sourcing from outside suppliers who may be somewhat behind technologically or track information differently than Church Brothers.
“How are you going to enter that information into your system, and then how are you going to continue to pass it on to the next end user?” she says.
Valenzuela-Reyes stresses that produce industry businesses need to be thinking ahead to prepare for FSMA 204 compliance. Even for those businesses already on the traceability journey, now is the time to check to make sure systems work as they should.
“You might think that you have everything to the dot, but as you dig deeper, and as you double-, triple-check your systems, there’s always going to be something,” she says. “Waiting till the last minute, it’s going to be chaotic.”
Why Classic Yam Isn’t Waiting for 2028
Dodie Gauger never expected to be working in food safety. After starting at the front desk of grower-packer-shipper Classic Yam in Livingston, Calif., she transitioned to sales and then began working in food safety. She says it’s a challenge to wear two very different hats for the company and keep up with meeting the ever-changing food safety requirements of retailers.
Gauger says her and Classic Yam’s journey into traceability started with PTI. As she read through the goals and milestones, she realized it was a lot to undertake and sought help.
“That’s why we chose to go to a company and say, ‘Look, these are their goals. This is what they want. We don’t want to stretch it out. We want to do it now,’” she says.
Classic Yam focuses on key data elements, or KDEs. Some of Classic Yam’s customers require advanced ship notices sent through electronic data interchange.
Classic Yam uses iFoodDS Trace Exchange to generate pallet labels and send ASNs via EDI. Gauger says she still hand-logs everything with a columnar pad, but she sees the potential for digital reports to bridge the gap in the future.
“Just the thought of there being a report where I could go, ‘OK, this lot number, this date, right here, where did all this product go?’” she says. “Right now, I do all that by hand. I don’t have a spreadsheet on the computer. I can’t queue up a report like I need to, but I’m happy that it’s heading my way because it’ll take a little bit of that stress off.”
She says it’s difficult to keep up with when retailers add new requirements, especially for a company that grows a low-risk food item, as sweetpotatoes aren’t on the FSMA 204 list. However, she says she understands why retailers often have the same requirement for all fresh produce.
“I have to think about it from their point of view,” she says. “If you think of all the thousands and thousands of categories of different things that they have, I can’t see how they would be able to differentiate between all of these different categories.”
Gauger says it was important to begin the compliance journey early to be prepared.
“If I’m operating a year ahead of a deadline, I don’t care, because I’m not going to be there panicking at the end,” she says. “Because it will come, and it is necessary. People are out there that are not operating above board.”
With the final FSMA 204 enforcement deadline approaching in 2028, Gauger’s advice to the industry is simple: Don’t wait.
“Please don’t put it off, because they’re not always going to push those deadlines out the way they have,” she says. “It’s going to come. And the thing is, do it. Do something. Take it apart. Do something, do a little at a time [and] at least start moving toward the goal.”
And don’t be afraid to say you need help and seek assistance from companies that specialize in compliance, Gauger adds.
“You have to know your limits,” she says. “I’m not familiar enough with the traceability — all of the necessary aspects of that — so I’m not afraid to reach out. The company I work for is not afraid to reach out and say, ‘Hey, this is a little bit beyond us.’”
Gauger says ask neighbors, ask competitors and collaborate to move toward food safety compliance.
“You’ve got to work together, because it doesn’t matter if it’s low risk,” she says. “We’re all in this industry, and we’ve got to keep it moving forward.”
Nunes Co. Builds on PTI Foundation to Secure FSMA 204 Compliance
It was around the 2006 spinach recall when The Nunes Co., which grows and markets vegetables and leafy greens, first began to work on traceability.
“Spinach was pulled off every shelf, and there were millions and millions of dollars lost to the industry because we couldn’t identify to a level of detail the source of the outbreak,” says Johnny McGuire, director of information technology for The Nunes Co.
McGuire, who has been with the company for eight years, worked with a startup company that created the first field-pack labeling system aligned with PTI. He says Nunes took traceability seriously and began labeling cases in the field, which was a part of PTI’s seven milestones. While those last-mile steps were never picked up by buyers, growers helped create the standard and work toward continual improvement, he notes.
“For a company like Nunes, looking at the FSMA 204 key data elements and the critical tracking events and what we need to in terms of record keeping and interoperability with our trading partners and suppliers, a lot of that work that we did for the on the PTI is aligned with what the FDA [Food and Drug Administration] is bringing down in FSMA 204.”
McGuire says it’s important throughout the journey to traceability that the produce industry understands the why behind these requirements. It’s not just an additional checkmark or audit; it’s about public health.
“We’re all on board with the one goal of keeping consumers healthy and safe,” he says.
McGuire points to how Nunes’ work with PTI and how the FDA has aligned much of the FSMA standards to PTI requirements have positioned the company well for compliance in 2028.
“Case labeling, SSCC [serial shipping container code], pallet labeling, advanced ship notices through EDI, bill of lading — a lot of that groundwork is in place so with two more years to kind of get it done, we feel fairly confident that we can do that,” he says.
While the work isn’t finished in Nunes’ journey to traceability and FSMA 204, McGuire says the rallying call of the spinach outbreak really pushed Nunes and other fresh produce industry businesses to improve traceability.
“We’ve still got some work to do,” he says of the company. “We’ve got a few blind spots here and there. That kind of foundation that we set almost 15 years ago is serving us well now.”
And it’s only one part of Nunes’ food safety efforts.
“We layer on top of that world-class food safety professionals and systems and processes and people ... with that view of keeping that consumer happy, safe and enjoying our product,” McGuire says.
For companies still waiting to embark on the FSMA 204 compliance journey, McGuire says it’s important to get the data organized. This includes assigning GTINs [Global Trade Item Numbers], global location numbers and more; then, look at interoperability and EDI integrations to share that data with the next step in the supply chain.
“Do you have those integrations in place?” he says. “Because that’s going to be your key method of sharing that shipping key data elements.”
