Traceability rules might be daunting, but they don’t have to be. So went the advice of one food safety expert to the mango industry
On Sept. 24, Sergio Nieto-Montenegro of Food Safety Consulting and Training Solutions, LLC, laid out the ABCs of abiding by the U.S. Food and Drug Administration’s Food Traceability Rule, known as FSMA 204, for the mango industry.
His main message was to not panic over the rule. Most members of the mango supply chain are already doing most, if not all, of the new rule’s requirements, he said. It’s just a matter of getting a plan together.
“Sometimes we get scared and feel that we have to fulfill every single requirement in the standard,” he acknowledged to his audience. Attendees came from at least a half dozen mango-growing countries and represented all points along the mango supply chain.
But then he listed out information mango growers have to supply according to the rule — details such as mango variety, date of harvest, quantity of harvest, orchard and field name and location, and who the mangoes go to after harvest — and asked: “all of this information, this is something you are already collecting, yes?”
The participants overwhelmingly answered yes.
“But then we hear ‘FSMA regulations’ and we panic,” Montenegro continued. “But it’s just about how we organize the information.”
The ABCs of FSMA 204 for mangoes
Montenegro overviewed the numerous acronyms of the FSMA 204 for the mango industry, focusing mostly on CTEs — critical tracking events. According to the rule, fresh produce CTEs are harvesting, cooling before initial packing, initial packing, shipping, receiving, and transformation (including repacking) of a fresh produce item.
Not everyone within the fresh mango supply chain will deal with all possible CTEs however, Montenegro explained. For example, the chilling CTE that might apply to other fresh produce doesn’t usually apply to the fresh mango supply chain.
However, given the complexity of the mango supply chain — with mangoes often coming from small suppliers in various countries, being repacked and changing hands many times via transportation middlemen and brokers — it can come with many, sometimes repeated, steps.
Repackaging, which counts as a transformation under FSMA 204, is one of those points of potential complexity for mangoes. They will receive a TLC, traceability lot code, upon initial packing. But each time the mangoes are repackaged, they are effectively a new product, thereby requiring a new TLC.
Montenegro gave the example of lots of mangoes that are initially processed and given a TLC, that are then sent to another warehouse that repacks them into size-specific pallets according to client desires. Those pallets of large mangoes from mixed original lots are new products requiring new TLCs.
He also offered an example of the many hands mangoes can pass through as an area of complexity for the industry.
“Imagine that I have mangoes coming from Michoacán,” he said. “They were packed in Michoacán and then went to McAllen. Then the person in McAllen sent them to a broker in Dallas. And then the broker in Dallas sends them to a broker in Minneapolis.”
Those brokers’ activities would represent both receiving and shipping CTEs, and each would be required to keep track of the relevant receiving and shipping KDEs (key data elements) such as product description, location information of where the mangoes had just been and where they will be going next, dates and so on.
“So you will have a bit more information here,” Montenegro said.
Don’t reinvent the record-keeping wheel
Compliance with the FSMA 204 comes down to organizing your (probably already existing) information, Montenegro advised his mango industry listeners. He noted the record-keeping requirements will vary depending on where a person or company falls in the supply chain.
Regardless, he recommended industry members not try to reinvent the wheel in preparation to comply with the rule, which takes effect July 20, 2028. Instead, he recommended people start by taking stock of what records they already collect and compare it to the record-keeping needs of the new rule.
“Maybe, you already have everything, or maybe you’re only missing two little details,” he said. “Even if you’re missing two details, that doesn’t mean you have to transform your whole [record-keeping] system. You just need to make those two additions.”
He added that the process of adding to an existing record-keeping system doesn’t need to be complicated. He showed participants example record documents that fit different links in the mango supply chain offered by the National Mango Board.
“At the National Mango Board, we have plenty of tools at your service to help you create a plan in compliance with this rule,” Montenegro said.
