By THE PACKER STAFF | September 30, 2024
In a recent webinar hosted by Alan Siger, president of the Produce Distributors Association (PDA), two food safety and traceability experts discussed the significance of robust plans for produce distributors to comply with the new guidelines set by the Food Safety Modernization Act (FSMA).
The session, held on September 24, focused on the complexities of FSMA 204(d), emphasizing the urgency for distributors to understand and implement the Food Traceability Final Rule before the January 2026 deadline established by the Food and Drug Administration (FDA). While the FDA will not begin routine enforcement until 2027, experts Jennifer McEntire, founder of Food Safety Strategy, and Dave Donat, principal at DRD Produce Consulting, stressed the importance of readiness.
“This is a big deal,” Donat noted. “Many customers are starting to take notice. They may not require compliance yet, but they are asking distributors, ‘Where are you with FSMA?’ It’s the law, and customers expect action. Approaching this with a positive mindset can lead to success.”
FSMA 204(d) increases traceability data-keeping requirements for those involved in the manufacturing, processing, packing, or holding of foods on the Food Traceability List. The FDA aims to streamline processes for responding to and tracking potential contaminants.
Distributors must prepare and track Key Data Elements (KDEs) and Critical Tracking Events (CTEs). While the FDA may offer some flexibility, McEntire highlighted the importance of timing during outbreaks or recalls. “The FDA recognizes that the food industry needs time to adapt, but if they request data, companies must be ready to provide the key data elements for critical tracking events in an electronic, sortable format within approximately 24 hours,” she said.
Produce items included in the Food Traceability List and the new FSMA rule consist of fresh cucumbers, tomatoes, sprouts, tropical tree fruits, melons, peppers, leafy greens, and herbs. Fresh-cut fruits, vegetables, and leafy greens are also included. However, certain produce items, like table grapes, do not require compliance. Donat advised distributors to consider future items they may use.
“If produce has been cooked, dried, or dehydrated, it is exempt from the list,” McEntire explained. “However, whole, fresh fruits and vegetables, along with fresh-cut items and those used as ingredients in other products, like salsa, are included, making the list quite extensive,” Donat added.
During the webinar, McEntire and Donat addressed specific scenarios requiring heightened attention and answered questions from attendees. They also discussed common challenges in meeting new standards, such as managing missing data and inconsistent naming conventions. Donat emphasized the importance of having a detailed compliance plan, recommending the following steps:
- Collecting inventory data, including product descriptions, lot codes, quantities, locations, and receiving dates.
- Establishing a method for assigning lot codes.
- Being organized and meticulous in data collection.
- Tracking the flow of products throughout the supply chain.
- Providing data to customers and the FDA upon request.
“You need to provide easily accessible data to your supply chain partners and be prepared to supply it to the FDA on demand,” Donat stated. “Additionally, a documented traceability plan is essential to explain how you are complying with FSMA.”
The “FSMA Myths vs. Facts” webinar is now available online as a resource for PDA members seeking guidance on critical industry issues. The PDA, which has evolved from its origins as the National Association of Perishable Agriculture Receivers, will also participate in the upcoming New York Produce Show and Conference, where it will hold its annual meeting on December 10.
