ORLANDO, Fla. — Speaking at the International Fresh Produce Association’s Global Produce & Floral Show, Carol McMillan, senior director of IT for Naturipe Farms, says the industry was almost ready for implementation of the Food and Drug Administration’s Food Traceability Final Rule, or FSMA 204, while calling the last mile the most challenging.
“It’s like getting one more tenth of a second in a swimming race,” she says.
McMillan says adding traceability lot source wasn’t the Naturipe’s biggest challenge. She says it’s the influx of EDI onboarding, or electronic data interchange, in sharing that traceability data. Long-standing retail partners who previously rejected advance shipping notices, or ASNs, are now requiring them, complete with strict, highly specific parameters.
“Every customer has their own unique requirements when it comes to EDI,” she says, noting that while some buyers demand a full listing of every lot code on a shipment, others strictly enforce a rule allowing only one lot code per pallet.
She says some retailers have indicated plans to audit physical Produce Traceability Initiative, or PTI, labels against digital ASN data upon arrival, and that could create an operational bottleneck.
“You scan a label, and a case was moved from one pallet to another, and next thing you know, they’re rejecting an entire load because a sticker didn’t match,” she says.
McMillan says Naturipe’s strategy has been to establish a framework first, then onboard customers and fine-tune the details.
“We have to be realistic, but the framework is in place, and we’re continuing towards that 100% accuracy on the delivery of the information,” she says. “In the meantime, our back-end information, the information we can provide in a traceback, is rock solid, and I think that one of the key factors is there is a lot of work yet to be done. The pace, I think, now with that extra extension is a lot more manageable.”
Other parts of the business, such as purchasing and reselling produce to fill market gaps, remain works in progress regarding how companies collect and pass along FSMA 204 data.
“A lot of different nuances need to be worked out, but the progress has shed a lot of good light on where we are today versus what it was when the ruling first came out,” she says. “It was a mad rush, and now I feel like it hasn’t tapered off, but there’s been more structure around it.”
FDA Guidance on Produce Location Tracking
Andy Kennedy, chief traceability officer for iFoodDS, says FDA has published guidance regarding Traceability Lot Code, or TLC, source. Under this new guidance, produce growers can use a headquarters location instead of an exact geolocation for where an item was packed.
“As long as your headquarters can provide that information to FDA immediately based on the [Global Trade Item Number] GTIN and lot, you get away from having to provide a geolocation for an exact field where you packed produce,” he says. “Not necessarily having to provide the exact location where something was packed, which for field packers is kind of a godsend.”
Kennedy says FDA is also considering a methodology similar to a three-way match at receiving to compare warehouse management system, or WMS, data; first-in, first-out (FIFO) records; and purchase order, receipt and payment data. He says this could be particularly helpful for foodservice distributors.
“How can those three data sets reinforce each other? How can we use AI to improve and enrich those data sets? And then how do we come up with the concept of right now you have pick-rate accuracy in a warehouse? So, if I use pick-rate accuracy, that’s the perfect order concept,” he says. “Did I pick the right quantity, the right product? Did I deliver it on time? How do we add into that concept lot code and source information? So, when I provide the lot code and source to my customer through that order selection process, how close is it to reality?”
Leveraging AI and WMS Data
Erik Larsen, director of supply chain for IFPA, says the organization has sponsored a pilot testing the WMS probability model from supplier to retail and supplier to restaurant.
“There’s a ton of interest in it in the industry right now, because it’s going to save huge amounts of labor, and it’s going to be a great intermediary step between now and full case level traceability,” he says. “Our industry needs to take an iterative approach to this, and this is going to be a great way to prove out that that model actually really works. We’ve done some informal calculations and tests, and it’s surprisingly accurate.”
Larsen says IFPA is working closely with the FDA to ensure this WMS probability model will be FSMA 204 compliant.
Kennedy says the pilot originated in the Produce Traceability Initiative’s Working Group, where distributors expressed how challenging lot code tracking would be in the final mile.
“It’s influenced the conversation to say, maybe we can use predictive models as opposed to direct capture,” he says.
Actionable Advice for Suppliers and Distributors
Kennedy says growers, packers and shippers need to be engaged with customers. Now is the time to ask questions about how customers expect to receive traceability information.
“It’s really important that from a receiver perspective, from a distributor perspective, that they understand how you’re going to communicate with them,” he says. “We have this window of opportunity where we can digitize the produce supply chain. Let’s get it right and not have it be a cost. Rather, let’s see it as a benefit.”
Kennedy also emphasizes taking stock of the technologies and capabilities a company already possesses. He notes that when faced with a new compliance mandate, a company naturally tends to purchase new solutions before fully understanding its specific needs.
“Really understand where you sit today, and put yourself in the shoes of your customer,” he says.
Kennedy notes from personal experience auditing distribution centers that when inspecting case labels and receiving processes, “honestly, most of the labels out there are straight garbage.”
For example, for companies printing PTI labels and building pallets, verifying that physical lot codes match the outbound ASN is critical. Kennedy cites common real-world errors: misaligned barcodes cut off at the label edge, smudged barcodes from poorly maintained printers and preprinted GTINs or lot codes printed directly on boxes. Additionally, repackers often put new labels on without removing the originals, forcing receivers to guess which barcode to scan.
“Walk around your own shop, pretend you’re the customer receiving that nonsense, and see if you can figure it out,” he says. “From a distributor perspective, do the same thing. Walk around a warehouse and look at what you have in inventory and decide, if I had to scan everything inbound and outbound, could I do it today? And then have some heartfelt conversation with your suppliers.”
McMillan says Naturipe has recommended label checks as part of the company’s quality control inspection.
“If the PTI label isn’t scannable, if the ASN isn’t received, you’re most likely starting to get charge-backs for those,” she says. “So, in order to prevent those, we’ve recommended our growers include it as part of the QC.”
She points out that while only a small portion of Naturipe’s portfolio falls under FSMA 204 and the FDA’s Food Traceability List, “the message we’re getting from our customers is they aren’t going to sort through the FTL.”
As retailers send out surveys asking which items fall under the FTL, McMillan expects buyers to continue pushing for broad compliance across all produce categories.
“Many of them are still pushing for this because they don’t want to deal with it,” she says. “They want to say all produce has the same information. So, they want consistency; that means us as suppliers need to be able to provide it. And that is much better than having to scramble.”
