Cybersecurity

Food Defense in the Age of AI: Are We Prepared?

By Radojka Barycki
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Cybersecurity

I watched a movie last year where a woman was being framed for murder using her facial features that were captured by a technology used in a bus that allowed passengers to get in based on facial recognition. In the movie, the woman, who was a cop, was investigating suspicious activity relating to the research of the facial recognition self-driven bus that a high-profile tech company was trying to approve for massive production and introduction into the market. The cop was getting too close to confirm her suspicions. So, the tech company got her face profile and embedded it in a video where another person was killing an executive of the company. This got me thinking about how we use face recognition nowadays and how technology is included in everything we do. So, I pose the question: are we at risk in the food industry in terms of Food Defense?

Recent cybersecurity attacks in the food industry have highlighted the urgency of this question. For instance, in 2021, the world’s largest meat processing company fell victim to a ransomware attack that disrupted its operations across North America and Australia. The company had to shut down several plants, leading to significant financial losses and potential supply chain disruptions.

Similarly, earlier that year, a cyberattack targeted a U.S. water treatment facility, where hackers attempted to alter the chemical levels in the water supply. Although this attack was prevented, it underscored the vulnerabilities within critical infrastructure systems, including those related to food production and safety.

Additionally, in 2022, a large fresh produce processing company experienced a cyber incident that disrupted its operations. The attack temporarily halted production and distribution of packaged salads and other products, causing delays and financial losses. The company paid $11M in ransom to the hackers to restitute order for their operations. This incident further underscores the importance of cybersecurity in the food industry and the potential risks posed by inadequate security measures.

These incidents illustrate the growing threat of cyberattacks in the food industry and the potential consequences of inadequate cybersecurity measures. As technology becomes more integrated into food production, processing, and distribution, the need for robust food defense strategies that encompass cybersecurity has never been more critical.

Understanding Food Defense
Food defense refers to the protection of food products from intentional contamination or adulteration by biological, chemical, physical, or radiological agents. Unlike food safety, which focuses on unintentional contamination, food defense addresses the deliberate actions of individuals or groups aiming to cause harm. In an era where technology permeates every aspect of food production, processing, and distribution, ensuring robust cybersecurity measures is crucial for effective food defense.

The Intentional Adulteration Rule, part of the FDA’s Food Safety Modernization Act (FSMA), mandates measures to safeguard the food supply from deliberate adulteration aimed at causing large-scale public health harm. Key requirements of this rule include conducting vulnerability assessments, implementing mitigation strategies, performing monitoring, verification, and corrective actions, as well as providing employee training and maintaining thorough records.

The Intersection of Technology and Food Defense
The integration of advanced technology into the food industry brings numerous benefits, such as increased efficiency, improved traceability, and enhanced quality control. However, it also introduces new vulnerabilities that can be exploited by cybercriminals. As technology becomes more sophisticated, so do the methods employed by those who seek to manipulate or sabotage our food supply.

AI and Technology: A Double-Edged Sword
Artificial intelligence (AI) and other advanced technologies are revolutionizing the food industry. Automated systems, IoT devices, and data analytics enhance productivity and provide real-time monitoring capabilities. However, these technologies also present new avenues for white-collar crime and cyberattacks. For instance, a cybercriminal could hack into a food processing plant’s control system, altering ingredient ratios or contaminating products, which could lead to widespread public health crises.

Pros and Cons of Using AI and Technology in Food Safety
The adoption of AI and technology in the food industry has both advantages and disadvantages:
Pros:
1. Enhanced Efficiency: Automation and AI can streamline food production processes, reducing human error and increasing output. This leads to more consistent product quality and improved overall efficiency.
2. Improved Traceability: Advanced tracking systems allow for real-time monitoring of food products throughout the supply chain. This enhances the ability to trace the source of contamination quickly, thereby reducing the impact of foodborne illness outbreaks.
3. Predictive Analytics: AI can analyze vast amounts of data to predict potential risks and prevent contamination before it occurs. This proactive approach can significantly enhance food safety.
4. Real-Time Monitoring: IoT devices and sensors can provide continuous monitoring of environmental conditions, ensuring that food storage and transportation are maintained within safe parameters.

Cons:
1. Cybersecurity Risks: As seen in recent cyberattacks, the integration of technology introduces new vulnerabilities. Hackers can exploit these weaknesses to disrupt operations or intentionally contaminate food products.
2. High Implementation Costs: The initial investment in AI and advanced technologies can be substantial. Small and medium-sized enterprises may find it challenging to afford these technologies.
3. Dependence on Technology: Over-reliance on technology can be problematic if systems fail or are compromised. It is essential to have robust backup plans and manual processes in place.
4. Privacy Concerns: The use of AI and data analytics involves the collection and processing of large amounts of data, raising concerns about data privacy and the potential misuse of sensitive information.

The Role of Cybersecurity in Food Defense
To safeguard against such threats, the food industry must prioritize cybersecurity as an integral component of food defense strategies. Here are key strategies to consider:
1. Conduct Regular Risk Assessments: Identify potential vulnerabilities within your technological infrastructure. Regular risk assessments can help detect weaknesses and prioritize areas needing immediate attention.
2. Implement Robust Access Controls: Ensure that only authorized personnel have access to critical systems and data. Use multi-factor authentication and monitor access logs for suspicious activity.
3. Invest in Employee Training: Employees are often the first line of defense against cyber threats. Provide comprehensive training on cybersecurity best practices, including recognizing phishing attempts and other common attack vectors.
4. Update and Patch Systems Regularly: Ensure that all software and hardware are up-to-date with the latest security patches. Regular updates can mitigate the risk of exploitation through known vulnerabilities.
5. Develop Incident Response Plans: Prepare for potential cyber incidents by developing and regularly updating incident response plans. These plans should outline specific steps to take in the event of a security breach, including communication protocols and recovery procedures.
6. Utilize Advanced Threat Detection Systems: Employ AI-driven threat detection systems that can identify and respond to unusual activity in real-time. These systems can provide an added layer of security by continuously monitoring network traffic and system behavior.
7. Collaborate with Cybersecurity Experts: Partner with cybersecurity professionals who can provide insights into emerging threats and recommend best practices tailored to the food industry’s unique challenges.

Current Efforts to Standardize the Use of AI
Recognizing the critical role of AI and technology in modern industries, including food production, international efforts are underway to standardize their use and ensure safety, security, and reliability. Two notable standards introduced recently are ISO/IEC 23053:2022 and ISO/IEC 42001:2023.
• ISO/IEC 23053:2022: This standard focuses on the transparency and interpretability of AI systems. It aims to make AI-driven processes understandable and explainable to users, which is crucial for maintaining trust and accountability. In the context of food safety, this standard can help ensure that AI decisions, such as those related to quality control and contamination detection, are transparent and can be audited.
• ISO/IEC 42001:2023: This standard provides guidelines for the governance of artificial intelligence, ensuring that AI systems are developed and used responsibly. It addresses ethical considerations, risk management, and the continuous monitoring and improvement of AI systems. For the food industry, adhering to this standard can help ensure that AI technologies are implemented in a way that supports food safety and defense.

As the food industry continues to embrace technological advancements, the importance of integrating robust cybersecurity measures into food defense strategies cannot be overstated. By understanding the potential risks and implementing proactive measures, we can protect our food supply from malicious actors and ensure the safety and security of the public. The scenario depicted in the movie may seem far-fetched, but it serves as a stark reminder of the potential consequences of unchecked technological vulnerabilities. Let us learn from fiction to fortify our reality

The author will be presenting Food Defense in the Digital Era at the Food Safety Consortium Conference. More Info

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Retail Food Safety Forum

Educating the Public on Food-Related Health Risks: The Critical Role of Nutritionists

By Ainsley Lawrence
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While most people think of nutritionists as general advisors who sit down with them one-on-one to create diet plans, their role goes far beyond that. Nutrition specialists play a critical role in educating the public with regard to food safety.

Some work with patients one-on-one, but they can also work in corporate settings, athletic facilities, food manufacturing centers, government organizations, hospitals, physician’s offices, schools, and more.

In this article, we will take a closer look at the connection between food safety and nutrition, including the important role nutritionists play in nutrition education, food safety, and mitigating food-related health risks.

The Connection Between Food Safety and Nutrition

Food safety and nutrition are inherently linked. Food safety refers to the prevention of food contamination, and for people to be healthy, they must have access to food that keeps them well-nourished and free from foodborne illnesses. In other words, to avoid food-related health risks, people must have consistent access to safe and healthy foods. Poor nutrition is one of the leading causes of illness in the United States. Without safe and equitable access to healthy foods, 600,000 Americans die each year.

By educating others on what to eat and where to get these foods, as well as helping organizations create better food safety and food security plans, nutritionists ensure people have access to the best foods possible for maintaining overall health and well-being.

What is a Nutritionist?

Before diving further into the role nutritionists play in food safety, it’s helpful to understand what they do exactly. Despite the connection between their work and the health of the public, nutritionists are not doctors.

Nutritionists can either be licensed or unlicensed, depending on their specific career goals and where they live, as licensure requirements can differ from one state to the next. When working with patients one-on-one out of a private practice, for example, a nutritionist might not need to be certified. However, if working with a hospital, a school, or a government organization, it is likely that they will be required to have a license — but again, this can depend on the specific requirements of the state they are working in.

However, doctors are often not routinely trained in nutrition. Thus, when a doctor does not have the knowledge needed to help a patient, they can refer them to a nutritionist for special guidance and support. If a patient is recovering from cancer or is dealing with diabetes, they may need to work with a larger medical team so they can learn to manage their condition and alleviate symptoms through a proper diet. In addition to educating patients on what foods to eat for their health, these specialists can also consider factors such as food allergies, dietary needs for athletes, personal tastes, and cultural and religious dietary needs.

What Role Do Nutritionists Play in Nutrition Education and Food Safety?

There are numerous ways that nutritionists work to educate others on food safety. Many organizations and companies are responsible for providing nutritious meals, such as nursing homes, hospitals, and restaurants. These facilities will often hire nutrition experts to help them craft menus and create healthy and flavorful meal plans.

The government also partners with and hires nutritionists for various programs. The USDA Food and Nutrition Service (FNS), for example, is responsible for offering science-based nutrition education to the public. Nutrition professionals will then work with the FNS to create educational programs and even policies that support the health and well-being of communities, families, and individuals.

Nutritionists also use their knowledge and expertise to help back up nutrition claims and work with food manufacturers to create nutrition labels and other important dietary information on food packaging They also use analytical data to calculate things like protein quality or food category contributions and share this information to ensure people are choosing the right food products for their individual health and nutrition needs.

Overall, you can find these specialists working with a wide range of organizations to help educate and ensure food safety, including:

  • Federal and local health departments;
  • Hospitals;
  • Private practices;
  • Nursing homes;
  • Schools;
  • Research facilities;
  • Food distributors and retailers;
  • Hotels and resorts;
  • Athletic organizations.

Some of the specific examples of what they can do in these settings can include researching and developing recipes, creating menus and meal plans, educating clients on nutritional food choices, ensuring plans align with weight, health, and nutrition goals, and creating nutrition-related care plans.

In schools, for example, nutrition professionals are responsible for ensuring meals abide by nutrition regulations, meet the taste preferences of diverse student bodies, are prepared properly, address food allergies, and are affordable.

They can also work with local organizations to assist with food security issues, such as communities that are considered food deserts where people lack access to healthy foods. For example, they can work with food vendors and distributors to ensure certain communities and their local grocery stores and markets have a good selection of fresh and nutritious foods.

Furthermore, nutritionists also play a vital role in educating the public to help reduce food-related illness and disease. Cancer, for example, is one of the leading causes of death worldwide but can be mitigated with better food and nutrition education. Nutrition professionals can also help alert the public to contamination and assist with handling food testing and recalls.

Nutrition Education and The Fight Against Cancer

45% of cancer deaths in the United States are linked to things like poor diet and obesity, thus, nutritionists play an important role in helping mitigate cancer risks. There are a number of carcinogens in everyday food products that are linked to cancer, such as acrylamide, which is a chemical that forms in foods placed under high heat, and aflatoxins, which are produced by food molds.

Nutritionists can offer guidance on testing for food safety. For example, nitrosamines or N-nitroso compounds (NOCs) can be carcinogenic and are known to compromise food quality and safety. Unfortunately, there are many ways NOCs can make their way into the food chain, including crop protection processes, meat preservation processes, food drying processes, and even via the consumption of nitrates in vegetables that react with stomach bacteria and acids to form NOCs. With this knowledge, however, nutritionists can advise on nitrosamine testing to ensure proper food safety.

In Summary

Nutritionists are vital when it comes to educating the public and helping to provide access to safe, healthy, and nutritious foods. There are many organizations in our country that heavily rely on the support and guidance of these specialists to better serve and protect the health and well-being of individuals, families, and communities.

Nutritionists will forever play a critical role in helping people make more informed nutrition decisions. Whether working at a private practice, with schools, hospitals, the government, or other organizations, these food educators are key to reducing food-related health risks.

Ask The Expert

Hygiene and Efficiency in Food Processing: Goodway Technologies’ Advanced Solutions

By Evan Reyes
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Q&A with Evan Reyes, Global Director of Sales, Sanitation Division, Goodway Technologies

Goodway Technologies provides cleaning and sanitation equipment for the food and beverage processing industry. They offer a range of products including dry steam cleaners, conveyor belt cleaning systems, industrial vacuums, and surface sanitizing equipment. They also specialize in innovative solutions such as CIP technologies and industrial vacuums. Their goal is to help improve hygiene and food safety, and increase production efficiency in food production plants.

QUESTION: Is steam safe to use around water sensitive equipment?

ANSWER: Thanks to the low moisture content of dry steam, we are able to use it to safely clean motors, conduit, control panels, and other areas where water use is typically not welcome. Some highly sensitive components like touch screen, power receptacles, and photo eyes should still not be directly steam cleaned, although you can steam clean in close proximity to these sensitive components without worrying about them getting wet.

Goodway Technologies

Link to case study

QUESTION: How can you get to a passing ATP level without introducing cleaning chemicals to aid in the process?

ANSWER: In the right applications, our belt cleaning systems will do the job of a cleaning chemical to break down the soils using dry steam, and then we follow up with vacuum extraction to physically remove the soil from the belt. This is a powerful cleaning combination that leads to a very clean and completely dry belt surface. 

Goodway Technologies PureBelt

We frequently see 0 ATP readings after the belt cleaning is completed, and are always within a passing ATP level after cleaning. One other benefit is that we provide a consistent cleaning across the entire belt surface, every time, eliminating the possibility of an operator missing a spot on the belt, failing a swab, and needing to re-clean.

Link to case study

 

Learn more from Goodway Technologies

Visit Goodway Technologies’ booth at the Food Safety Consortium Conference, Oct. 20-22, Washington DC

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Checklist

The Importance of Food Safety Auditing

By Jennifer Lott
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Checklist

To begin to understand the importance of food safety auditing, it is essential to know what a food safety standard comprises in terms of auditing.

Food safety standards are a set of rules and regulations established by regulatory agencies, such as FDA (21CFR117), international organizations, i.e., World Health Organization (WHO) or Global Food Safety Initiative (GFSI), and industry bodies, such as SQF, to ensure the safety and quality of the food supply chain.

These standards aim to reduce the risk of contamination, reduce the chances of foodborne illnesses, and protect the workers and customers who consume or use the product.

Food Safety standards contain requirements for food production, from sourcing ingredients and materials to production processes to packing and distribution.  Food safety standards add transparency, traceability, and accountability to your organization’s operations.

So why are food safety audits necessary?

Food safety audits are organized activities that aim to evaluate the extent of a food business’s food safety management system in the pursuit of protecting public health.

Public health can be at stake, and audits on food safety practices aim to evaluate how a food business management system can effectively protect against contaminated food getting released into the marketplace.

Food safety audits focus on critical areas of food manufacturing operations, such as the food safety management system, food storage, food preparation, sanitation, facility design, and employee hygiene.

How does the audit help?

Well, auditors examine a combination of intended practices and methods with the actual facility and design to gather how effective are the food safety management protocols, how the product is stored, how employees handle food preparation—as well as machinery and building safety, including facility design, sanitation, and employee’ personal hygiene practices.

Food safety audits come in three basic designs: first-party (internal), second-party (audit of your supplier), or third-party or accredited third-party (independent or certification). The type of audit chosen can be based on your needs and the auditing firm.

Audits provide a real-time assessment of the status of the operation and quality management system. More than looking at safety records and historical statistics, food safety audits look at problems that may be fermenting now – they can be proactive rather than reactive—reviewing areas where implementation of preventative strategies and reporting findings can bring value with improved efficiency and avoidance of future problems.

Food safety audits are also an excellent time to foster organizational communication.

Engaging with employees in interviews provides many points of view and is an opportunity to promote a sense of ownership and buy-in within the organization – this can go a long way in developing a strong food safety culture.

The unintentional contamination of food is one of the most significant risks associated with not complying with food safety regulations. If the source of contamination can be traced to the company, the organization may face hefty fines and consequences.

On top of that, with noncompliance with food safety standards, an organization risks sowing distrust from internal employees through to their customers. When companies don’t follow safety standards, customers will be hesitant to buy and consume their products, negatively impacting sales and overall company performance.

The author, Jennifer Lott is presenting Assessing Food Fraud using PAS 96 to Meet GFSI and FSMA Requirements at the Food Safety Consortium Conference, October 20-22, Washington DC. This presentation will use information from PAS 96, Guide to Protecting and Defending Food and Drink from Deliberate Attack, and real-life examples to provide insights and guidance when completing/reviewing your VACCP and TACCP programs. For more information visit FoodSafetyConsortium.org

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Jennifer Allen
Food Safety Attorney

Not a magic bullet: The dos and don’ts of dietary-supplement labeling

By Jennifer Allen
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Jennifer Allen

Dietary supplements are commonplace in the American diet. Indeed, so many Americans expect supplements to do most of the heavy nutritional lifting in their diets that “substitute” might be a more accurate name. But while many consumers view supplements as a magic bullet or cure-all, and supplement manufacturers happily reinforce that viewpoint through their labeling, the FDA does in fact set limits on the types of statements that supplement manufacturers may make. To ignore those limits is to run the significant risk of receiving a warning letter from FDA. Warning letters are made public, and being on the receiving end of one can damage a manufacturer’s brand. In February 2021, FDA announced that it had recently sent warning letters to ten supplement manufacturers who were claiming that their products could treat or cure depression and other mental health disorders.

No dietary supplement, no matter how effective it is, may contain labeling that claims to “diagnose, mitigate, treat, cure, or prevent” disease. Labeling is a broad term. It doesn’t just apply to the physical label affixed to the container. It also applies to marketing materials accompanying the supplement, or to statements made on the website selling the supplement. FDA explains what types of statements will be considered improper drug claims in 21 CFR 101.93(g). A statement will be considered an improper drug claim if it claims, explicitly or implicitly, that the product has an effect on a specific disease or class of diseases, or on their characteristic signs or symptoms, or on an abnormal condition associated with a natural state or process, if that abnormal condition is uncommon or can cause significant or permanent harm.

A statement will also constitute an improper drug claim if it claims that the product: belongs to a class of products intended to “diagnose, mitigate, treat, cure, or prevent” disease; is a substitute for a product that is a therapy for a disease; augments a particular therapy or drug; has a role in a body’s response to disease; treats, prevents or mitigates adverse events associated with a particular drug or therapy, if that adverse event is in itself a disease; or otherwise suggests an effect on a disease.

So how can a dietary supplement manufacturer promote the health benefits of its products if it can’t make any of these types of claims? Broadly speaking there are three types of claims that will not violate the regulations: 1) classical nutrient deficiency claims; 2) structure-function claims; and 3) FDA-approved health claims. Let’s look at each of these in turn.

A classical nutrient deficiency is a disease or condition caused by a deficiency in a particular nutrient. Diseases such as pellagra and scurvy fall into this category. Dietary supplement labeling may inform consumers that use of the product can cure or prevent classical nutrient deficiencies if the manufacturer provides notice to the FDA that complies with the requirements in 21 CFR 101.93(a) within 30 days of first marketing the product, and if the product bears the following disclaimer: “This statement has not been evaluated by the Food and Drug Administration. This product is not intended to diagnose, treat, cure, or prevent any disease.” Section 101.93(b)-(e) contains specific requirements about the placement and prominence of the disclaimer.

Structure-function claims are also permissible. These types of claims suggest an effect of the product on the body’s normal structure or function. Emphasis here is on the use of the word normal. So, rather than saying, for example, “this product prevents heart disease,” which is an obvious example of an improper drug claim, the labeling could state, “this product helps promote healthy heart function.” Like classical nutrient deficiency claims, however, the manufacturer must provide the required written notice to FDA within 30 days, and also include the disclaimer language.

The third type of permissible claim is an FDA-approved health claim. Manufacturers can find such approved claims at 21 CFR 101.72-83. An example of the type of health claim that is permissible would be a claim linking vitamin D or calcium to reduced risk of osteoporosis. But if the FDA hasn’t approved a claim, manufacturers may not make that claim, even if the science shows it is true. If a manufacturer believes that the science supports the use of ginger root for reducing symptoms of Crohn’s Disease, for example, it may not make any such claim, even if it is true, without petitioning FDA to approve such a claim.

While it is true that dietary supplements are regulated with more leniency than regular foods, this is not a license to sell unapproved drugs. Supplement manufacturers would be well advised to have their marketing folks work closely with legal counsel to craft labeling language that promotes the benefits of the product while staying within the FDA’s guardrails.

 

 

 

Predictive Analytics for Proactive Food Safety

By Emily Newton
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Many of the most popular predictive analytics use cases revolve around risk assessments and optimization. While businesses largely use them to drive efficiency and financial gains, the same tech can help make the food and beverage industry safer.

Predictive analytics could benefit virtually any industry that applies it. While that means monetary improvements in most sectors, this technology could impact people’s health and well-being in others. Applying predictive analytics in food safety in one such use case.

The Importance of Proactive Food Safety

Foodborne illnesses affect 48 million people each year in the U.S. alone. These diseases are easily treatable in many instances, but as hospitals become more crowded and the population grows, more could result in worse outcomes. Already, 128,000 of these cases hospitalize their victims and 3,000 end in death.

These outbreaks may become a more prominent threat over time, too. Climate change can make certain foodborne pathogens more common and affect food’s nutritional value. The global population is also growing, so available resources must spread further to cover everyone. That could result in more people being unable to access the care they need if they contract a foodborne disease.

Given these concerns, food safety must be proactive. Organizations need to stop outbreaks before they occur to reduce the burden on the health care system and ensure a healthier world. Predictive analytics can support that goal by optimizing several aspects of food safety.

Emily Newton,

Preventing On-Farm Contamination

Food safety starts with food’s farm origins. Some diseases can spread through pest contamination, and predictive analytics may provide more reliable proactive anti-pest measures than conventional alternatives.

Pest outbreak modeling begins by collecting data on weather patterns, past outbreaks, and known interactions between certain pests and other chemicals or plants. Machine learning models can then predict when rising pest populations are likely and what could stop them. Farmers can then respond as necessary, whether that means spraying the optimal amount of pesticide or companion planting to repel animals before they arrive.

Early experimental models under this umbrella have accurately predicted outbreaks up to seven years in the future — more than enough time for farms to adapt. Even if these warnings spur little more than increased attention to contamination risks, they could significantly impact food safety.

Protecting Food Products in Transit

Predictive analytics can guard crops or animal products in transit once they leave the farm. Unlike pest prevention, this application is less concerned with long-term trends, instead centering around real-time data.

Internet of Things (IoT) sensors can track metrics like shipment temperatures and humidity in real time. With this data, predictive models can identify when current conditions may lead to food safety concerns, such as temperatures rising above safe levels. Once they identify these trends, they alert drivers and other stakeholders to take action before spoilage occurs.

Some available solutions today can monitor core temperatures up to 1 meter away, while others can detect bacteria and gas associated with spoilage. Whatever the specifics, real-time data and machine learning enable fast responses to prevent contamination or stop spoiled products from reaching consumers if prevention is impossible.

Refining Manufacturing Processes

Predictive analytics can also promote proactive food safety in the manufacturing stage. Many manufacturers today are already investing in AI to optimize their production workflows, and the same technology can yield safety improvements.

Take the production of dry pet food — which accounts for 60% of all pet food sold today — for example. These products are prone to cross-contamination from additives or surface contact during extrusion, but these hazards are difficult to identify in a large facility. Predictive analytics can analyze digital twins of these facilities to pinpoint where this kind of contamination is most likely, informing workflow changes to remove or mitigate the risk.

Just as predictive analytics can highlight production bottlenecks, it can alert manufacturers to processes prone to bacterial infection or other health hazards. Advanced models can even suggest alternative workflows to make it easier to ensure the safest possible production process.

Pinpointing Supply Chain Vulnerabilities

Similarly, food and beverage companies can use predictive analytics to identify hazards in their supply chains. Third-party health and safety risks are hard to pinpoint manually, but AI can monitor real-time conditions and analyze past trends to predict vulnerabilities.

Businesses can apply predictive analytics to food supply chains in a few ways. One effective option is to analyze past health department reports to identify suppliers with a history of health and safety violations. Some solutions today can even highlight common themes between reports to reveal what kinds of hazards a company struggles with.

Other supply chain analytics engines can analyze real-time data to predict potential outbreaks in a region’s food supply or growing cross-contamination threats in an area. Food companies can then adjust their supply strategy to avoid sourcing from these problem areas and prevent outbreaks.

Learning From Past Outbreaks

Many supply chains have also embraced predictive analytics for scenario modeling. Applying this practice to food safety can help experts learn where past outbreaks came from to inform preventive measures in the future.

With enough data on past foodborne disease outbreaks, machine learning models could identify trends in their early warning signs. Alternatively, they could highlight how some logistics or manufacturing practices contributed to the disease’s spread. Predictive models can then apply these insights to real-time farm, production facility and health report data to predict incoming cases.

Food processors already use hyperspectral sensors that could help detect early warning signs of undesired microbes, like the release of some gasses. Feeding this data to predictive models alongside information on how past foodborne illnesses emerged and evolved could let them predict new diseases before they affect anyone. Global health agencies and food and beverage companies could enact much more effective mitigation measures as a result.

Predictive Analytics Takes Food Safety Further

Many of the most popular predictive analytics use cases revolve around risk assessments and optimization. While businesses largely use these applications to drive efficiency and financial gains, the same technology can help make the food and beverage industry safer. That will become increasingly crucial as the population grows and climate change worsens the threat of foodborne illnesses.

The use of predictive analytics in proactive food safety is still in its infancy, but early signs are promising. As this technology evolves and more brands capitalize on it, it could make the world a safer, healthier place.

Food Safety Technology Can Protect Businesses from Recalls and Other Risks

By Colin Rose, Patricia Baxter
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Recalls represent one of the largest threats to a food company’s profitability and reputation. In recent years, technology solutions such as cloud-based software have been introduced to better prepare and safeguard businesses.

According to the US Department of Agriculture, more than 300 food products were recalled last year, representing a significant 31% increase compared with 2022. The reasons behind recalls vary and include food containing contaminated items such as metal or plastic, exposure to pathogens and undeclared allergens on product labels. The Centers for Disease Control estimates that each year, roughly one in six Americans (or 48 million people) gets sick from foodborne diseases. Recalls represent one of the largest threats to a food company’s profitability and reputation. In recent years, technology solutions such as cloud-based software have been introduced to better prepare and safeguard businesses.

Supply Chain Connectivity

Despite advances in technology, many food manufacturers and processors still rely on manual tools and management across their supply chains. Manual systems can result in major issues during a crisis, including errors in inputting or updating data and miscommunication, such as being unable to quickly reach multiple vendors and suppliers at a given time.

Proper and comprehensive supply chain management is critical to food safety. In the instance of a recall, businesses must be able to quickly activate their recall management plan, disseminating important information both up and down the supply chain while documenting to meet certification and regulatory requirements. It’s key that all suppliers – local, national and international – demonstrate that they are compliant with all relevant food and market regulations. Product source information must also be tracked and searchable in records.

Robust and proactive document control can help an organization avoid recalls by quickly identifying risky suppliers or non-compliant ingredients.

Innovative Solutions Support Recalls

Several new technologies are being employed to support greater traceability and transparency across the food supply chain. With cybersecurity attacks now being a risk that can result in product recalls, more companies are investing in information security solutions to further protect their data. Certifications to standards such as ISO/IEC 27001, which has requirements for establishing, managing and maintaining an information security management system help businesses to demonstrate that they follow an international standard for managing security controls. This can provide an added level of assurance that cybersecurity risks have been identified and safeguarded.

Some companies are now using RFID to tag and track food items. QR codes and bar codes can be scanned on easily accessible devices such as smartphones and tablets, providing instant access to records to ensure traceability.

Cloud-based software also allows companies to manage complex and critical data more confidently. NSF TraQtion® is a new software solution that directs suppliers to an online portal to upload documents, complete questionnaires and communicate. Beyond supplier data, cloud-based software can also be used for recipe management and storage, tracking complaints, label compliance and setting company-wide standards. By simplifying and digitizing data, documents and records collection, leaders can instantly access information during audits and assessments, allowing for quick delivery when program documentation is requested or required.

If not properly and swiftly handled, a recall or outbreak can cost a business tens of thousands of dollars or more. By using cloud-based technology to put an easily accessible and implementable risk management plan in place, businesses can be better prepared for a food safety incident. Overall, software can minimize back-and-forth messaging, urgent data requests, meetings and calls by digitizing and streamlining both communication and documentation.

How to Select the Right Tech Solutions

When preparing for a potential recall, it’s important to be proactive. Start with identifying the pain points in the organization’s risk management plan and then see if there are tools that can be used to strengthen the plan and address its weaknesses. While some tools may require greater investment, this can pay off in the long run when you consider how detrimental recalls can be.

As we look at recalls and technology solutions, we must acknowledge that the requirement for full compliance to the Food Safety Modernization Act (FSMA) 204 rule is January 20, 2026. For those applicable, technology will play a major role in the FDA’s recordkeeping requirements and 24-hour turnaround of an electronic, sortable spreadsheet for traceability of products. In most cases, with larger-scale operations, this can only happen with the utilization of new and emerging software.

The goal of technology implementation is to create a more sustainable food system. With earlier identification and traceability of adulterated products, the removal and retrieval process from commerce will be faster and, in turn, should result in a decrease of incidents reducing illness and potential deaths.

Digital solutions will also help to fill the gaps for root cause investigations, thus more efficiently allowing for enhanced preventative actions and training to avoid recurrence. While onboarding of new technology can sometimes be costly, over time, the ROI of reduced recalls and product losses can increase revenue gains and negate the initial investment.

Food is a global commodity, and advancing technology and innovations in system processes can help move the supply chain forward in delivering safe, quality consumable products around the world. Now is the time to lead the industry forward for a safer, more sustainable future for both companies and consumers. We must invest in technology solutions within our food supply chain to continue advancing human and planet health.

Food Traceability and Authentication in the AI Era

By Maria-Eleni Dimitrakopoulou
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Food traceability provides comprehensive information about a product’s history and origin, facilitating efficient recalls and supply chain management. However, distinct types of food fraud, such as concealment, counterfeit, and mislabelling, pose significant challenges. The integration of Artificial Intelligence (AI) and new regulatory measures, like the FDA’s traceability rule, enhance food safety and authenticity, fostering a more transparent and reliable food supply chain.

In the intricate web of the global food supply chain, ensuring the safety and authenticity of consumables stands as a paramount concern. Food traceability, defined as the ability to provide comprehensive information about the history and origin of a product throughout its journey, emerges as a cornerstone in this endeavour. This meticulous documentation not only facilitates supply chain management but also empowers swift actions such as recalls in the event of safety or quality breaches.

Beyond its logistical benefits, food traceability assumes a pivotal role in safeguarding consumer interests. By serving as a fundamental component of food safety and quality assurance, traceability ensures transparency and accountability at every stage of production and distribution. However, the efficacy of a traceability system is inherently tied to the credibility of its origins, paving the way for the convergence of food traceability and authentication.

Unveiling the Shadows: The Challenge of Food Adulteration

In an era plagued by instances of food adulteration and mislabelling, the imperative for robust authentication mechanisms becomes increasingly apparent. Reports from international and national research bodies shed light on a myriad of cases spanning various food categories, from wine and spirits to olive oil, fish, meat, and beyond. This pervasive challenge underscores the need for stringent standards and regulatory frameworks to combat fraudulence and uphold consumer trust.

Food fraud manifests in several forms, each presenting unique challenges for detection and prevention. For example:

  • Concealment involves hiding inferior or harmful ingredients within a product to avoid detection. An example of this is the addition of melamine in milk to falsely increase protein content readings, which led to a major scandal in China.
  • Counterfeit products replicate and sell a product under the guise of a well-known brand, often with substandard quality. These fake products can range from everyday items like bottled water to high-end goods like wines and spirits. Counterfeiting not only deceives consumers but also damages brand reputations and violates intellectual property rights.
  • Botanical Authentication ensures that plant-based products are derived from the claimed species and not substituted with cheaper alternatives. This is particularly important for products like herbal supplements, teas, and spices. For instance, saffron, one of the most expensive spices in the world, is often adulterated with less expensive substances such as dyed corn stigmas or safflower.
  • Geographical Origin fraud involves misrepresenting the region from which a product originates. Certain regions are known for producing specific high-quality foods and beverages, such as Champagne from France or Parmigiano Reggiano cheese from Italy. Mislabelling products to benefit from these reputations deceives consumers and undermines genuine producers.
  • Substitution entails replacing a high-value ingredient with a lower-cost one. This is common in products like olive oil, honey, and seafood. For example, extra virgin olive oil might be diluted with cheaper oils, or expensive fish species like tuna might be replaced with less costly ones like escolar. This not only cheats consumers but can also pose health risks.
  • Mislabelling involves incorrectly listing ingredients or nutritional information on labels. An example is claiming a product is organic when it is not.
  • Dilution involves adding water or other substances to increase the volume of a product. For instance, diluting fruit juices with water and not declaring it.
  • Unapproved Enhancements involve using unauthorized substances to enhance the appearance or quality of a product. An example is adding unauthorized dyes to make a product look fresher or more appealing.
  • Theft and Resale refers to stealing products and reintroducing them into the market through unauthorized channels. For example, reselling stolen goods without proper storage conditions.
  • Artificial Additives involves using artificial ingredients to mimic the qualities of a natural product. For example, adding synthetic vanilla flavor instead of natural vanilla extraction

The New Traceability Rule of FDA

The Food and Drug Administration (FDA) has introduced a new traceability rule aimed at enhancing the ability to trace the origin of foods throughout the supply chain more efficiently. This rule mandates that companies maintain more rigorous records of their supply chains, focusing on high-risk foods. The implementation of this rule is expected to significantly improve the speed and accuracy of traceability in the event of a foodborne illness outbreak or contamination incident, thus ensuring faster recalls and reducing the risk to public health.

The Dawn of a New Era: Advancements in Food Fraud

As the spectre of food fraud looms large, there arises an urgent demand for sophisticated analytical techniques to authenticate foodstuffs with precision and reliability. Here, the advent of Artificial Intelligence (AI) heralds a new era of innovation. AI-driven algorithms can sift through vast datasets, identifying patterns and anomalies that elude traditional methods. Machine learning models can analyse complex chemical compositions, flagging deviations indicative of adulteration or mislabelling. By harnessing the power of AI, authorities can fortify their efforts in safeguarding consumer interests and preserving the integrity of the global food market.

Charting the Course Ahead: Toward a Safer, More Authentic Future

In the pursuit of food safety and quality, the symbiotic relationship between traceability and fraud, bolstered by AI technologies, emerges as a beacon of hope. By fortifying supply chain transparency and deploying cutting-edge analytical methods, stakeholders can navigate the complexities of the modern food landscape with confidence and integrity. The integration of the FDA’s new traceability rule further strengthens this endeavour, ensuring a safer and more reliable food supply chain for all.

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Digitizing Your Food Safety Program

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Many food suppliers are investigating and making early investments in the adoption of digital technology to aid and automate their food safety programs. One area of intense interest has been the increasing application of digital automation within food safety testing programs. As a data and technology leader and practitioner across multiple industries for the past 30 years, I have had the privilege of working with organizations as they seek to build the appropriate plans and business justification for taking on digital transformation initiatives.

The following are the top three questions I am continually asked and the answers that, over time, have provided the information and support needed to help companies through this important transition. Perhaps these are similar to the questions that your leadership is asking you?

David Hatch
Featured Expert: David Hatch, VP Digital Solutions Marketing, Neogen Analytics

What are the actual benefits that digitizing our food safety testing program will yield?

David: During the past six years, I have witnessed the implementation and deployment of approximately 500 digital food safety testing programs across the globe. This is always one of the first questions I am asked, and there is inevitably a challenge in the question… namely – “Our program is solid, we pass our certification and customer audits, so tell me how this will be better than what we are doing today.”

The most tangible benefit, of which there are many, boils down to two metrics of success that I have witnessed consistently, over time and across three decades of work, deliver real, measurable change: Time and Trending.

Time, metrics within food safety scenarios, is characterized as having three components:

  1. “Time-to-information” – reducing the time between an event occurring, and information about that event being communicated to those in need of this knowledge.
  2. “Time-to-decision” – reducing the time from when information is known to the moment when a decision can be made to affect the outcome of whatever the information indicates as needing to be addressed.
  3. “Time-to-Action” – reducing the time from when a decision is made to when the enactment of that decision is carried out.

In the world of food safety, the diagnostic information, policy- and compliance-driven decisions, and the corrective and preventative actions (CAPA) that are mandated by regulation and driven by policy compliance standards, define the effectiveness of a food safety testing program.

Therefore, the ability to decrease these timeframes immediately produces a risk reduction result. When the time between an occurrence of a food safety issue and the completion of a corrective action is reduced, so too is risk reduced. Especially when the issue is deemed to be impacting public safety, brand value, and operational continuity… all of which can yield very costly results if not addressed quickly and accurately.

If information is collected and recorded manually, and is stored in individual paper and spreadsheet files, it is, by definition, made ineffective. The time it takes to manually record the data, or retrieve it when needed, works against the requirement that information be on-tap in real time as issues arise. Digitizing a food safety testing program means, beyond merely putting data into spreadsheets, that information be collected and stored in a data base, whether that is data coming from on-premises testing, or a 3rd-party lab. And that database must be connected to a system that enables immediate access, auto-alerts, and data-driven triggers to enact corrective actions without having to wait for a human to think where to look, or how to combine data from various manual storage files.

Trending is equally important. While speed, as highlighted above, is critical, so too is the continuous collection and analysis of data. The ability to trend your diagnostic results goes further than merely seeing a time series report of testing results. If constructed properly, a trending analysis can provide your team with the ability to become far more preventative than ever before.

Trends allow you to see reoccurrences of issues, and as these grow, an alert engine can offer recommended actions that can prevent the future need for full CAPA scenarios, or worse, response to a regulatory inquiry. As illustrated below, when combined together, Time and Trending can yield significant benefit that, as a result, reduce a significant portion of the risk and costs associated with slow response to manually managed food safety testing data. Further, a digitized system can put your data to work for you, creating a scenario that enables the data itself to find the right person at the right time when thresholds and triggers deem this action to be necessary (see figure below).

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How can we measure Return-on-Investment (ROI) on the cost of moving to a digitally managed program?

David: If the question and answer above are not yet enough to justify the move to a digitally managed testing program, there are three more factors to consider when assessing the return on a digital investment:

Reduction of production downtime: The occurrence and frequency of food safety issues increases the risk of system downtime. If a pathogen detection occurs, a machine, conveyor system or other equipment may need to be temporarily shut down for unplanned cleaning, or in extreme cases, torn down altogether for deep cleaning. Our interactions with over 500 implementations have shown that:

  • Downtime can reach an astounding 500 hours annually, leading to overall costs that some studies put in the range of $20,000 to $30,000 per hour, on average.
  • The financial impact of reducing production downtime by just 90 minutes per week can be dramatic once you’ve added up the week-after-week results. For example, a company operating two facilities with a $30,000/hour downtime cost can gain back $90,000 per week with just 90 minutes regained at each location weekly.

Reduction of Waste/Scrap and Rework: A pathogen positive diagnostic result in a Zone 1 or food contact surface location, or worse yet, within a finished product test, will result in the need to scrap and rework production lots. Each pound of finished product that is scrapped will require rework to make up for lost order fulfillment for customers. It is therefore imperative that when issues are detected, the associated corrective actions quickly and accurately address the situation. In my experience, we show that digital trending and time-to-action improvements can drive business impact – specifically, gaining back just 10% of scrapped food per week can yield significant results. For example:

  • An organization operates two facilities where 500 lbs. of finished product are scrapped each week.
  • The value per pound of finished product, when factoring in all the labor, energy costs and materials, is valued at a conservative cost of $1 per pound.
  • Annually, by reducing time-to-information by just 4 hours per sanitation cycle, the organization was able to realize $400,000 reduction in waste-related costs.

Improve Overall Efficiency: Over the course of several months, we partnered with a large dairy producer to explore how automating a manual EMP process could help drive increased efficiencies, reduce pathogen positives, and ultimately, improve the bottom line (see figure below).

Neogen Test Results Chart

Over time, the analysis gained from automated data gathering enabled new sanitation procedures to implemented, leading to significant efficiency gains:

  • A new baseline of testing volume, test types and correlated sanitation procedures were refined and implemented.
  • A revamped remediation program yielded new corrective action steps that have been proven through the study’s data to be more effective.
  • The FSQA team gained back 25% of their time by eliminating the need for manual reporting, analysis, and spreadsheet-based data preparation.
  • The organization improved corrective action completion time by 50%.

What are the resources and time required for the transition to a digitally automated program?

David: There can be a high degree of ‘fear of change’ involved in any digital transformation initiative. This is not unfounded fear, as horror stories abound regarding large enterprise system implementations and the havoc they can cause. The main consideration in avoiding these outcomes is to ensure the initiative has leadership buy-in and support. This is why the answers to the first two questions above are so important. The path to gaining leadership buy-in is through the ability to connect food safety digitization and automation to tangible business results. If a successful business case can be made utilizing the concepts described above, then the battle for assigning resources and the appropriate implementation timeframes can be achieved.

I started working with food safety teams in 2018, when the existence of food safety testing automation was still at a relatively low adoption rate. In the intervening six years, as adoption has increased, the complexity and timeframes of implementation have decreased significantly. This remains a key area of concern, however, as organizations are struggling to keep up with ongoing staffing shortages and resulting resource constraints. There are two key areas where a digital solution provider must be challenged to prove their ability to support your digital transformation:

  1. Proof of delivery: Due to the relatively recent emergence of digital food safety testing platforms, we have not yet reached a state of maturity where tens of thousands of implementations have defined a standard of known implementation and adoption processes to exist. Therefore, it is critical that you find and work with a provider who will deliver a fully functioning trial of their system, preferably free of charge, for a significant amount of time. This will enable you and your team to experience the full range of capabilities offered, including the onboarding and training program, the length of time it takes, the level of technical acumen your team will be expected to have, and the overall delivery of the benefits described above.
  2. Focus on requirements: Commonly, digital solutions are designed to work within fairly rigid processes and workflows as designed into the system. If you’re lucky, you may find a solution that aligns to your own existing workflows, but all too often, the largest stumbling block is the realization that your new system is not just a digital transformation but also requires a full business process reengineering project in order to conform to the way the software works. Challenge your providers to demonstrate how their solution is flexible enough to enable your team to reduce any process changes to the lowest degree possible. While some new processes will always be inevitable (and potentially helpful!), it should be the hallmark of any provider’s customer support/success team to understand your requirements and configure their solution to enable them without too much drastic change.

To learn more about how digitizing food safety programs can impact business ROI, download our EMP ROI white paper today.

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Produce Traceability: 4 Steps to Get Started

By Samantha Humphrey
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With the effective date for updated traceability recordkeeping approaching in January 2026, traceability is a top priority for most organizations working in the food industry. Produce companies are especially impacted by traceability requirements as the first step in the food supply chain.

On November 21, 2022, the Food and Drug Administration (FDA) published the Food Safety Modernization Act (FSMA) Final Rule: Requirements for Additional Traceability Records for Certain Foods (Food Traceability Rule). With the effective date for updated recordkeeping approaching in January 2026, traceability is a top priority for most organizations working in the food industry. Produce companies are especially impacted by traceability requirements as the first step in the food supply chain.

Most produce companies are no strangers to the importance of traceability. In fact, the Produce Traceability Initiative (PTI) was created over 15 years ago as a voluntary, industry-wide effort designed to help the industry maximize the effectiveness of current track and trace procedures, while developing a standardized industry approach to enhance the speed and efficiency of traceability systems for the future. The PTI has set dozens of companies throughout North America—ranging from small farms to international retailers—on the path to enhanced traceability and compliance with the FDA’s Food Traceability Rule.[i]

The following steps can help any produce company, whether it currently follows the PTI or not, prepare to meet FDA’s traceability requirements:

  1. Understand the Food Traceability Rule.

While the FDA has had traceability requirements in the past, the FSMA Food Traceability Rule is intended to enhance traceability recordkeeping for certain identified foods beyond a limited “one step forward, one step back” traceback approach. The objective of the Rule is to help the FDA rapidly and effectively identify recipients of those foods to prevent or mitigate foodborne illness outbreaks and address credible threats of serious adverse health consequences or death.[ii]

In comparing the FSMA Rule to the PTI, a recent PTI press release states that the requirements of the PTI for case-level traceability are aligned with the Final Rule and cover approximately 90-95% of the requirements, with major differences stemming from the Traceability Lot Code Source and Traceability Lot Code Source Reference.[iii]

The key elements of the FDA Rule are built into several acronyms:

  • FTL (Food Traceability List): This list identifies the categories of high-risk foods that require additional traceability records under the Food Traceability Rule. The FTL currently comprises the following produce commodities: cucumbers, fresh herbs, leafy greens, melons, peppers, sprouts, tomatoes, tropical tree fruits, and fresh cut fruits and vegetables. Other non-produce foods on the FTL include cheeses, shell eggs, nut butter, finfish, crustaceans, mollusks/bivalves, and ready-to-eat (RTE) deli salads.
  • TLC (Traceability Lot Code): This descriptor, often containing a combination of letters and numbers, is used as a unique identifier for product as it moves through the supply chain. The TLC is to be established by entities that originate, transform, or create food on the FTL. Once a food has been assigned a TLC, the TLC must be included in traceability program records collected at each Critical Tracking Event (CTE) and as a part of all Key Data Elements (KDEs) (see below). The TLC remains the same throughout the supply chain unless a transformation of the food occurs. The objective is to create linkages throughout the supply chain to help the FDA address key points in the supply chain more quickly in the event of an outbreak.
  • CTE (Critical Tracking Event): CTEs are the events in the food supply chain that require additional recordkeeping. These include harvesting, cooling before initial packing, packing, transforming, shipping, and receiving. At each CTE, the responsible entity must record the TLC.
  • KDE (Key Data Element): KDEs comprise the information associated with a CTE for which a record, including a TLC, must be maintained. Examples of KDEs include location description of the food being harvested; name of the field or growing area where the produce was harvested; date of harvest; quantity and unit of measure of the produce; date when the produce went from harvest, to cooling, to packing, to shipping, etc.
  1. Interpret the Rule and Determine its Applicability.

To determine the Rule’s applicability, it is important to first take an inventory of your operations and products:

  • Do you grow cucumbers, herbs, leafy greens, melons, peppers, sprouts, tomatoes, or tropical tree fruits?
  • Do you process fresh cut fruits, leafy greens, or vegetables other than leafy greens?
  • Do you manufacture a product that contains any of the foods listed above?

If the Rule applies (i.e., you answered yes to any of the three questions above), you must:

  • Maintain specific data records (i.e., KDEs) for at least two years.
  • Keep records of all CTEs.
  • Maintain an approved, updated Traceability Plan.
  • Ensure all data is easily accessible so it can be provided to the FDA within 24 hours of a request.

Note that there are a few nuanced exemptions that apply to farms, as noted on this FDA flow chart.[iv]

  1. Perform a Gap Assessment.

Most produce companies are likely capturing at least some of the information needed to comply with the Food Traceability Rule, particularly if they already implement the PTI requirements. Conducting a gap assessment will help identify missing elements that may be required for compliance with FDA’s Rule. The following questions can help guide this assessment:

  • Does your organization already capture data that may be considered a KDE? For example, do you apply lot codes to your products? Do you collect location information about where your product is harvested (e.g., farm site A, field 7)? Determine if there is any specific information or data points you are missing and how you can gather that data.
  • Do you have a sufficient Traceability Plan? Does it cover all the elements required in the Food Traceability Rule?
  • Are there upgrades you need to make to your recordkeeping system to solve your data collection pain points? Having a good document/records management system is essential for maintaining and sharing the data required by the Food Traceability Rule.
  • What collaborative activities can you and your suppliers/buyers perform to ensure that data is shared efficiently and encourage compliance?
  1. Create a Plan of Implementation.

The gap assessment will identify elements that you need to implement to help ensure compliance. Use that information to create a game plan, working backwards from the Rule’s January 20, 2026 effective date. Doing so now affords time to test solutions, see how they work in practice, problem solve, and find the right solutions for your organization.

At a minimum the implementation plan must include two key elements that will be vital for compliance:

  • Traceability Plan. Every organization must develop a new (or update an existing) Traceability Plan for collecting the KDEs that are required by the Rule, as outlined in the CFR[v] (see also the FDA example of a Traceability Plan for Farms[vi]). The Traceability Plan must be updated annually, and old plans must be maintained for at least two years. The Traceability Plan must include:
    • Description of the procedures used to maintain required records, as well as how to format and where to store those records.
    • Description of how TLCs are assigned.
    • Assignment of and contact information for a point person who can answer questions about the Traceability Plan and/or traceability records.
    • Map identifying the farms where FTL produce is grown.
  • Document/Records Management System. Produce companies who manufacture, process, pack, or hold foods on the FTL will need to implement a document/records management system to fulfill the Food Traceability Rule’s recordkeeping requirements. While hard copies in binders can work, an electronic document management system can create efficiencies and standardization, reduce human error, and improve accessibility when managing vast amounts of data.

As produce companies work through this process, it is important to remember the objective of the Food Traceability Rule. Ultimately, the Rule will allow the food industry to quickly remove potentially harmful foods from the supply chain and make the entire recall process more efficient. Even if the FTL list does not apply to all your products, your customers may still require that all produce they purchase meet the same requirements as foods listed on the FTL. Creating this end-to-end traceability will save time, money, and most importantly, human lives.

[i] Produce Traceability Initiative. The Produce Traceability Initiative: Working to achieve standardized, electronic (computerized) traceability across the supply chain. September 2011. https://producetraceability.org/wp-content/uploads/2022/03/PTI-Flyer_FNL_v2-2011-10-20.pdf.

[ii] Food and Drug Administration. What you need to know about the Food Traceability Rule: Recordkeeping Information for Produce Farms. June 2023. https://www.fda.gov/media/169510/download.

[iii] The Produce Traceability Initiative. Produce Traceability Initiative (PTI) Releases FSMA 204 Implementation Guidance. February 13, 2024. https://producetraceability.org/produce-traceability-initiative-pti-releases-fsma-204-implementation-guidance/.

[iv] Food and Drug Administration. Exemptions to the Food Traceability Rule. https://collaboration.fda.gov/tefcv13/.

[v] National Archives and Records Administration. CFR Title 21, Chapter I, Subchapter A, Part 1, Subpart S, Traceability Plan. May 21, 2024. https://www.ecfr.gov/current/title-21/chapter-I/subchapter-A/part-1/subpart-S/subject-group-ECFRe6c9096adb572d4.

[vi] Food and Drug Administration. Traceability Plan Example for Farms (§1.1315). November 2023. https://www.fda.gov/media/174057/download?attachment.