The public has its third and final chance on Dec. 2, 2020 to comment on a U.S. Food and Drug Administration (FDA) proposed rule to establish additional traceability recordkeeping requirements for certain foods. The virtual one-day meeting from 11:30 a.m. to 7:30 p.m. EST follows similar meetings on Nov. 6 and Nov. 18. Registration is required to attend the meeting and space is limited.
Almost a decade in the making the FDA’s “Food Traceability Proposed Rule” was published on Sept. 23, 2020. The rule is mandated by Sec. 204(d) of the Food Safety and Modernization Act (FSMA) passed by Congress in 2011. “It’s more important today than ever before in our history to work together to create a more digital, traceable and safer food system,” said FDC Deputy Commissioner for Food Policy and Response, Frank Yiannas.
Tracking and Tracing of Food
The proposed new food traceability recordkeeping requirements are at the heart of the FDA’s “New Era of Smarter Food Safety Blueprint” unveiled on July 13, 2020. Food traceability, the ability to track food products backwards and forwards in the supply chain, is key to a rapid response to foodborne illness outbreaks or contamination events.
The FDA says current regulations that require most of the food industry to track food for just one step – document immediate source and where it goes next -- has proven insufficient to trace shipments of food through each point in the supply chain.
Current regulations also do not apply to restaurants and farms, leaving large gaps in the traceability of food. FDA says,” Simply put, the U.S. lacks a harmonized system of traceability from farm to fork that is universally understood and utilized. This means that during an outbreak investigation, our ability to rapidly track and trace food is often impeded by insufficient data identifying a food as it moved through its supply chain.”
Critical Tracking Events in New Rule
The new rule would require all those who “manufacture, process, pack or hold foods on the Food Traceability List (FTL) to establish and maintain records containing Key Data Elements (KDEs) 
associated with different Critical Tracking Events (CTEs).”
associated with different Critical Tracking Events (CTEs).”The proposed rule has identified the following as CTEs:
- Growing
- Receiving
- Transforming
- Creating
- Shipping
KDEs would vary depending on the CTE.
Proposed Food Traceability List
The new rule does not cover all foods, but certain high-risk foods published on the Food Traceability List.
That proposed list covers:
- Cheeses, other than hard cheeses, including all soft ripened or semi-soft cheeses, and fresh soft cheeses that are made with pasteurized or unpasteurized milk
- Shell eggs (eggs of domesticated chickens)
- Nut butter, including all types of tree nut and peanut butters; does not include soy or seed butters
- Cucumbers, all varieties
- Herbs (fresh), including all types of herbs, such as parsley, cilantro, basil
- Leafy greens, including fresh-cut leafy greens. Includes all types of leafy greens, such as lettuce, (e.g., iceberg, leaf and Romaine lettuces), kale, chicory, watercress, chard, arugula, spinach, pak choi, sorrel, collards, and endive
- Melons, including all types of melons, such as cantaloupe, honeydew, and watermelon
- Peppers, all varieties
- Sprouts, all varieties
- Tomatoes, all varieties
- Tropical tree fruits, including all types of tropical tree fruit, such as mango, papaya, mamey, guava, lychee, jackfruit, and starfruit
- Fruits and Vegetables (fresh-cut), including all types of fresh-cut fruits and vegetables
- Finfish, including smoked finfish and finfish species such as cod, haddock, Alaska pollack, tuna, mahi mahi, mackerel, grouper, barracuda, and salmon; except does not include siluriformes fish, such as catfish
- Crustaceans, including all crustacean species, such as shrimp, crab, lobster, and crayfish
- Mollusks, bivalves, including all species of bivalve mollusks, such as oysters, clams, and mussels; does not include scallop adductor muscle.
- Ready-to-eat deli salads, including all types of ready-to-eat deli salads, such as egg salad, potato salad, pasta salad, and seafood salad; does not include meat salads
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