Last month, the Food and Drug Administration said it planned to delay compliance of the Food Traceability Rule, known as FSMA 204 by 30 months. In the announcement, the agency indicated the delay gave covered entities — which includes cucumbers, fresh-cut leafy greens, fresh leafy greens, tomatoes, tropical tree fruits, fresh-cut fruits and vegetables, ready-to-eat salads and more — more time to ensure complete coordination across the supply chain.
Wiggs Civitillo, founder and CEO of Starfish, which helps companies share traceability information, joined the “Tip of the Iceberg” podcast to discuss the importance of traceability and some of the challenges for the industry in becoming FSMA 204 compliant.
Civitillo said a major challenge for produce industry businesses is how FSMA 204 calls for full traceability of a produce item from field to retailer and how trading partners share that information.
“This rule requires capturing data key points of your process like harvesting, packing and shipping — many folks aren’t used to tracking that in a structured way,” he said. “On the retail and foodservice side, buyers need that data from thousands of suppliers. It’s coming in every shape and size — some spreadsheet some via EDI and some not at all.”
Civitillo said interoperability, having the ability to have systems share information easily is very important for the future of FSMA 204 compliance and traceability within the fresh produce industry. He said some companies might be reluctant to share data, but FSMA 204 requires fresh produce industry businesses to be more connected and transparent.
As for the compliance date, Civitillo said many retailers have already started requiring full traceability information, and just because the FDA doesn’t require it yet doesn’t mean that a retailer that a grower supplies to won’t.
“We’ve seen many major retailers mandating FSMA 204 requirements for data sharing, some stating how it needs to be shared, additional fields,” he said. “My guess is those expectations aren’t going to go away. Retailers have everything to gain from more visibility and eventually expect this of suppliers and maybe preferential treatment for suppliers who can actually provide this level of traceability after onboarding fewer audits and build stronger long-term relationships.”
Civitillo said one of the worst things a produce industry business could do during the 30-month delay is nothing. He said this isn’t a free pass, but opportunities for produce industry businesses to work toward compliance in a more measured approach.
“It’s a strategic window for businesses,” he said. “Buyers aren’t slowing down and neither are competitive pressures. If anything, expectations for transparency and traceability data sharing, they’re only rising, especially for large retailers, foodservice operators. The reality is companies that use this time to get their data house in order are really going to come out ahead.”
And, he points out, often traceability is overlooked until it’s needed. So, it’s an advantage for a produce industry business to offer traceback data quickly.
“Traceability is one of those things that doesn’t always feel urgent necessarily until something goes wrong,” he said. “It’s almost like an insurance policy for quality issues. Being able to trace your products quickly and accurately can make a difference between a minor blip and a major disruption in the fresh produce industry. We’re dealing with perishables. These are short, half-life, high-volume products that often change hands multiple times before they hit the shelf. When something goes wrong, they don’t have weeks to investigate.”
