Tag Archives: distributors

Are Traasdahl, Crisp
FST Soapbox

How a History of Slow Technology Adoption Across Food Supply Chains Nearly Broke Us

By Are Traasdahl
1 Comment
Are Traasdahl, Crisp

The COVID-19 crisis has exacerbated existing disconnects between food supply and demand. While some may be noticing these issues on a broader scale for the first time, the reality is that there have been challenges in our food supply chains for decades. A lack of accurate data and information sharing is the core of the problem and had greater impact due to the pandemic. Outdated technologies are preventing advancements and efficiencies, resulting in the paradox of mounting food insecurity and food waste.

To bridge this disconnect, the food industry needs to implement innovative AI and machine learning technologies to prevent shortages, overages and waste as COVID-19 subsides. Solutions that enable data sharing and collaboration are essential to build more resilient food supply chains for the future.

Data-sharing technologies that can help alleviate these problems have been under development for decades, but food supply chains have been slow to innovate compared to other industries. By reviewing the top four data-sharing technologies used in food industry and the year they were introduced to food supply chains, it’s evident that the pace of technology innovation and adoption needs to accelerate to advance the industry.

A History of Technology Adoption in the Food Industry

The Barcode – 19741
We’re all familiar with the barcode—that assemblage of lines translated into numbers and letters conveying information about a product. When a cashier scans a barcode, the correct price pops up on the POS, and the sale data is recorded for inventory management. Barcodes are inexpensive and easy to implement. However, they only provide basic information, such as a product’s name, type, and price. Also, while you can glean information from a barcode, you can’t change it or add information to it. In addition, barcodes only group products by category—as opposed to radio-frequency identification (RFID), which provides a different code for every single item.

EDI First Multi-Industry Standards – 19812
Electronic data interchange (EDI) is just what it sounds like—the concept of sharing information electronically instead of on paper. Since EDI standardizes documents and the way they’re transferred, communication between business partners along the supply chain is easier, more efficient, and human error is reduced. To share information via EDI, however, software is required. This software can be challenging for businesses to implement and requires IT expertise to handle updates and maintenance.

RFID in the Food Supply Chain – 20033
RFID and RFID tags are encoded with information that can be transmitted to a reader device via radio waves, allowing businesses to identify and track products and assets. The reader device translates the radio waves into usable data, which then lands in a database for tracking and analysis.

RFID tags hold a lot more data than barcodes—and data is accessible in remote locations and easily shared along the supply chain to boost transparency and trust. Unlike barcode scanners, which need a direct line of sight to a code, RFID readers can read multiple tags at once from any direction. Businesses can use RFID to track products from producer to supplier to retailer in real time.

In 2003, Walmart rolled out a pilot program requiring 100 of its suppliers to use RFID technology by 2005.3 However, the retail giant wasn’t able to scale up the program. While prices have dropped from 35–40 cents during Walmart’s pilot to just 5 cents each as of 2018, RFID tags are still more expensive than barcodes.4 They can also be harder to implement and configure. Since active tags have such a long reach, businesses also need to ensure that scammers can’t intercept sensitive data.

Blockchain – 20175
A blockchain is a digital ledger of blocks (records) used to record data across multiple transactions. Changes are recorded in real-time, making the history unfalsifiable and transparent. Along the food supply chain, users can tag food, materials, compliance certificates and more with a set of information that’s recorded on the blockchain. Partners can easily follow the item through the physical supply chain, and new information is recorded in real-time.

Blockchain is more secure and transparent, less vulnerable to fraud, and more scalable than technologies like RFID. When paired with embedded sensors and RFID tags, the tech offers easier record-keeping and better provenance tracking, so it can address and help solve traceability problems. Blockchain boosts trust by reducing food falsification and decreasing delays in the supply chain.6

On the negative side, the cost of transaction processing with blockchain is high. Not to mention, the technology is confusing to many, which hinders adoption. Finally, while more transparency is good news, there’s such a thing as too much transparency; there needs to be a balance, so competitors don’t have too much access to sensitive data.

Cloud-Based Demand Forecasting – 2019 to present7
Cloud-based demand forecasting uses machine learning and AI to predict demand for various products at different points in the food supply chain. This technology leverages other technologies on this list to enhance communication across supply chain partners and improve the accuracy of demand forecasting, resulting in less waste and more profit for the food industry. It enables huge volumes of data to be used to predict demand, including past buying patterns, market changes, weather, events and holidays, social media input and more to create a more accurate picture of demand.

The alternative to cloud-based demand forecasting that is still in use today involves Excel or manual spreadsheets and lots of number crunching, which are time-intensive and prone to human error. This manual approach is not a sustainable process, but AI, machine learning and automation can step in to resolve these issues.

Obtaining real-time insights from a centralized, accurate and accessible data source enables food suppliers, brokers, distributors, brands and retailers to share information and be nimble, improving their ability to adjust supply in response to factors influencing demand.8 This, in turn, reduces cost, time and food waste, since brands can accurately predict how much to produce down to the individual SKU level, where to send it and even what factors might impact it along the way.

Speeding Up Adoption

As illustrated in Figure 1, the pace of technology change in the food industry has been slow compared to other industries, such as music and telecommunications. But we now have the tools, the data and the brainpower to create more resilient food supply chains.

Technology adoption, food industry
Figure 1. The pace of technology change in the food industry has been slow compared to other industries. Figure courtesy of Crisp.

Given the inherent connectivity of partners in the food supply chain, we now need to work together to connect information systems in ways that give us the insights needed to deliver exactly the rights foods to the right places, at the right time. This will not only improve consumer satisfaction but will also protect revenue and margins up and down food supply chains and reduce global waste.

References

  1. Weightman, G. (2015). The History of the Bar Code. Smithsonian Magazine.
  2. Locken, S. (2012). History of EDI Technology. EDI Alliance.
  3. Markoff, R, Seifert, R. (2019). RFID: Yesterday’s blockchain. International Institute for Management Development.
  4. Wollenhaupt, G. (2018). What’s next for RFID? Supply Chain Dive.
  5. Tran, S. (2019). IBM Food Trust: Cutting Through the Complexity of the World’s Food Supply with Blockchain. Blockchain News.
  6. Galvez, J, Mejuto, J.C., Simal-Gandara, J. (2018). Future Challenge on the use of blockchain for food traceability analysis. Science Direct.
  7. (2019). Crisp launches with $14.2 million to cut food waste using big data. Venture Beat.
  8. Dixie, G. (2005). The Impact of Supply and Demand. Marketing Extension Guide.
John McPherson, rfxcel
FST Soapbox

Clear Waters Ahead? The Push for a Transparent Seafood Supply Chain

By John McPherson
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John McPherson, rfxcel

The seafood supply chain handles 158 million metric tons of product every year, 50% of which comes from wild sources. Operating in every ocean on the planet, the industry is struggling to figure out how to overcome the numerous obstacles to traceability, which include unregulated fishing, food fraud and unsustainable fishing practices. With these and other problems continuously plaguing the supply chain, distributors and importers cannot consistently guarantee the validity, source or safety of their products. Furthermore, there are limits to what a buyer or retailer can demand of the supply chain. Niche solutions abound, but a panacea has yet to be found.

In this complex environment, there are increasing calls for better supply chain management and “catch to plate” provenance. One problem, however: The industry as a whole still regards traceability as a cost rather than an investment. There are signs this attitude is changing, however, perhaps due to pressure from consumers, governments and watchdog-type organizations to “clean up” the business and address the mounting evidence that unsustainable fishing practices cause significant environmental problems. Today, we’ve arrived at a moment when industry leaders are being proactive about transparency and technologies such as mobile applications and environmental monitoring software can genuinely help reform the seafood supply chain.

A Global Movement for Seafood Traceability

There are several prominent examples of the burgeoning worldwide commitment to traceability (and, by default, the use of new technologies) in the seafood supply chain. These include the Tuna 2020 Traceability Declaration, the Global Tuna Alliance, and the Global Dialogue on Seafood Traceability. Let’s focus on the latter to illustrate the efforts to bring traceability to the industry.

The Global Dialogue on Seafood Traceability. The GDST, or the Dialogue, is “an international, business-to-business platform established to advance a unified framework for interoperable seafood traceability practices.” It comprises industry stakeholders from different parts of the supply chain and civil society experts from around the world, working together to develop industry standards to, among other things, improve the reliability of information, make traceability less expensive, help reduce risk in the supply chain, and facilitate long-term social and environmental sustainability.

On March 16, 2020, the Dialogue launched its GDST 1.0 Standards, which will utilize the power of data to support traceability and the ability to guarantee the legal origin of seafood products. These are guidelines, not regulations; members who sign a pledge commit themselves to bringing these standards to their supply chains.

GDST 1.0 has two objectives. First, it aims to harmonize data standards to facilitate data sharing up and down the supply chain. It calls for all nodes to create Electronic Product Code Information Services (EPCIS) events to make interoperability possible (EPCIS is a GS1 standard that allows trading partners to share information about products as they move through the supply chain.). Second, it defines the key data elements that trading partners must capture and share to ensure the supply chain is free of seafood caught through illegal, unreported and unregulated (IUU) fishing and to collect relevant data for resource management.

Why Transparency Is Critical

By now it’s probably clear to you that the seafood sector is in dire need of a makeover. Resource depletion, lack of trust along the supply chain, and the work of global initiatives are just a few of the factors forcing thought leaders in the industry to rethink their positions and make traceability the supply chain default.

However, despite more and more willingness among stakeholders to make improvements, the fact is that the seafood supply chain remains opaque and mind-bogglingly complex. There are abundant opportunities for products to be compromised as they change hands over and over again across the globe on their journey to consumers. The upshot is that the status quo rules and efforts to change the supply chain are under constant assault.

You may ask yourself what’s at stake if things don’t change. The answer is actually quite simple: The future of the entire seafood sector. Let’s look at a few of the most pressing problems facing the industry and how transparency can help solve them.

Illegal, unreported, and unregulated fishing. IUU fishing includes fishing during off-season breeding periods, catching and selling unmanaged fish stocks, and trading in fish caught by slaves (yes, slaves). It threatens the stability of seafood ecosystems in every ocean.

According to the Food and Agriculture Organization of the United Nations, IUU fishing accounts for as much as 26 million tons of fish every year, with a value of $10–23 billion. It is “one of the greatest threats to marine ecosystems” and “takes advantage of corrupt administrations and exploits weak management regimes.” It occurs in international waters and within nations’ borders. It can have links to organized crime. It depletes resources available to legitimate operations, which can lead to the collapse of local fisheries. “IUU fishing threatens livelihoods, exacerbates poverty, and augments food insecurity.”

Transparency will help mitigate IUU fishing by giving buyers and wholesalers the ability to guarantee the source of their product and avoid seafood that has come from suspect sources. It will help shrink markets for ill-gotten fish, as downstream players will demand data that proves a product is from a legal, regulated source and has been reported to the appropriate government agencies.

International food fraud. When the supply for a perishable commodity such as seafood fluctuates, the supply chain becomes vulnerable to food fraud, the illegal practice of substituting one food for another. (For seafood, it’s most often replacing one species for another.) To keep an in-demand product flowing to customers, fishermen and restaurateurs can feel pressure to commit seafood fraud.

The problem is widespread. A 2019 report by Oceana, which works to protect and restore the Earth’s oceans, found through DNA analysis that 21% of the 449 fish it tested between March and August 2018 were mislabeled and that one-third of the establishments their researchers visited sold mislabeled seafood. Mislabeling was found at 26% of restaurants, 24% of small markets, and 12% of larger chain grocery stores. Sea bass and snapper were mislabeled the most. These results are similar to earlier Oceana reports.

Consumer health and food safety. It’s difficult to guarantee consumer health and food safety without a transparent supply chain. End-to-end traceability is critical during foodborne illness outbreaks (e.g., E. coli) and recalls, but the complex and global nature of the seafood supply chain presents a particularly daunting challenge. Species substitution (i.e., food fraud) has caused illness and death, and mishandled seafood can carry high histamine levels that pose health risks. Consumers have expectations that they are eating authentic food that is safe; the seafood industry has suffered from a lack of trust, and is starting to realize that the modern consumer landscape demands transparency.

Why Seafood Traceability Supports the Whole Supply Chain

Most seafood supply chain actors are well-intentioned companies. They regard themselves as stakeholders of a well-managed resource whose hardiness and survival are critical to their businesses and the global food supply chain. Many have implemented policies that require their buyers to verify—to the greatest extent possible—that the seafood they procure meets minimum standards for sustainability, safety and quality.

This kind of self-regulation has been an important first step, but enforcing such standards has been hampered by the lack of validated traceability systems in a digital supply chain. Of course, it costs money to implement these systems, which has been a sticking point, but industry leaders are starting to realize the value of the investment.

Suppliers. A key benefit of traceability for suppliers (i.e., processors and manufacturers) is that it allows them to really protect their business investments. Traceability achieves this because it demonstrates to consumers and trading partners that suppliers are doing things the correct way. Traceability also gives them better control over their supply chains and improves the quality of their product—other important “indicators” for consumers and trading partners.

These advantages also create opportunities for suppliers to build their brand reputations. For example, they can engage with consumers directly, using traceability data to explain that they are responsible stewards of fish populations and the environment and that their products are sustainably sourced and legitimate.

The bottom line is that suppliers that don’t modernize and digitize their supply chains probably won’t be able to stay in business. This stark realization should make them embrace traceability, as well as adopt practices that comply with the regulations that govern their operations. And once they “get with the program,” they should also be more inclined to follow initiatives and guidelines such as the GDST 1.0 Standards. This will invariably create more trust with their customers and partners.

Brands (companies) and distributors. These stakeholders also have a lot to gain from traceability. In a nutshell, they can know exactly what they’re purchasing and have peace of mind about the products’ origins, sustainability, and legitimacy. Like suppliers, they can readily comply with regulations, such as the U.S. Seafood Import Monitoring Program (SIMP), a risk-based traceability effort that requires importers to provide and report key data about 13 fish and fish products identified as vulnerable to IUU fishing and/or seafood fraud.

And, of equal importance to their own fortunes, brands and distributors can use traceability to bolster their reputations and build and solidify their relationships with customers. Being able to prove the who, what, when, where, how, and why of the products they’re selling is a powerful branding and communications tool.

The end of the supply chain: Retailers, food service groups/providers, and consumers. High-quality products with traceable provenance mean retailers and food service companies will have better supply chain control and more “ammunition” to protect their brands. As with the stakeholders above, they’ll also garner more customer loyalty. For their part, consumers will know where their seafood comes from, be assured that their food is safe, feel good about being responsible buyers, and be inclined to purchase only products they can verify.

Transparency, Technology, Trust and Collaboration

The seafood industry is at a critical point in its very long history. It’s not a new story in business: Adapt, adopt and improve or face the consequences—in this case, government penalties, sanction from environmental groups, consumer mistrust and abandonment, and decreased revenues or outright failure.

There is one twist to the story, however: What the industry does now will affect more than just its own interests. The health of all fish species, the environment, and the future of the food supply for an ever-growing population hang in the balance.

But as we’ve demonstrated, there is good news. Supply chain transparency, driven by international initiatives and new technologies, is catching on in the industry. Though companies still struggle to see transparency as an investment, not a cost, their stances seem to be softening, their attitudes changing. The writing is on the wall.

The message I want to end with is that supply chain stakeholders should know that transparency is attainable—and it needn’t be painful. Help is available from many quarters, from government and global initiatives like the GDST to consumers themselves. Working with the right solution provider is another broad avenue leading to supply chain transparency. Technology is at the point now that companies have solid options. They can integrate their current systems with new solutions. They can consider replacing outdated and expensive-to-operate systems with less complicated solutions that, in the long run, do more for less. Or they can procure an entirely new supply chain system that closes all the gaps and jumps all the hurdles to transparency.

Whatever path the industry decides follow, the time to act is now.

Megan Nichols
FST Soapbox

Blockchain Improves Visibility In the Food Supply Chain

By Megan Ray Nichols
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Megan Nichols

Cryptocurrency is a favorite topic in the business world currently, but it’s not the coins or currency that are the star of the show. Bitcoin in and of itself is exciting and promising from several perspectives. However, the foundation of what these technologies run on is much more important. You likely already know what we’re going to talk about next: Blockchain.

To understand why blockchain is considered so crucial, you first need to delve into the core components of the technology. It’s basically a digital ledger, except it has some incredibly useful properties that make it uniquely lucrative. For starters, it’s public and transparent, so anyone with access to the network can see what’s happening in the moment, or what has been happening while they were away. However, the parties involved in a transaction or entry remain private, as do the materials or items exchanging hands.

Finally, because of the nature of blockchain, it’s secured and valid. The ledger itself is thoroughly protected, and no one can alter data save the parties involved. Even then, the relevant parties only weigh in with pertinent information such as time and date of the transaction and the amount transferred.

Most of what we’re talking about here is in reference to currencies and more traditional transactions. But it’s important to remember that we’re merely scratching the surface. As we speak, various organizations are working to adapt this technology for alternate industries and applications.

Still, what does any of this have to do with your average food supply chain?

Blockchain May Evolve the Food Supply Chain As We Know It

Believe it or not, blockchain can help improve the transparency and management of the food supply chain. It’s definitely needed. The world’s population continues to grow, and it’s expected to reach 10 billion by 2050. In food requirements, that means we’ll need to be increasing food production by as much as 70% to keep up. This puts a demand on the food supply chain to evolve and become more efficient, more accurate and more reliable.

The following are several ways blockchain can help achieve better transparency in and management of the food supply chain.

Preventing Foodborne Outbreaks, Enabling Fresher Goods

IBM has teamed up with several major suppliers including Wal-Mart, Dole and Nestle to come up with a blockchain-powered system that can be used to track a product’s journey from farm to store shelves. The goal is to create a more transparent deployment and transportation process so that interested parties can see exactly when and where certain foods might become contaminated.

Tracking this information will achieve a couple of things. For starters, public health officials, suppliers and management teams can help limit and prevent contagions from spreading. After the detection of Salmonella, for instance, they could mark all related goods as a risk and stop both stores from selling them and consumers from buying faster than ever before.

Second, it will help identify problematic systems and processes, hopefully cutting down on the risk of contamination in the future. If they know certain foods are going bad in transport, they can discern that it’s something to do with how they’re handled or stored along that segment of the journey. This would further enable them to identify and fix or optimize the issue. In other words, suppliers and retailers will use blockchain to keep food fresh. This is especially important since FSMA calls for reliable hygiene and storage methods during transportation.

More Accurate Inventory Tracking for Distributors

Unexpected shortages pose significant challenges to the food supply chain. A variety of external factors can contribute to a supply block, including inclement weather, poor soil, insect infestations, equipment failures and much more. When this happens, distributors are left to pick up the slack, but sadly, they often can’t do much to fix the problem.

Blockchain technologies, however, make the supply chain more transparent, which helps distributors get the information they need to address shortages. Through the use of blockchain, they’ll know exactly how much supply is available and what they need to do to ramp up their offerings.

For example, in the event of a shortage, they might connect with local farmers to make up the difference. Gathering the information needed to find the right partner, however, can take a long time when using traditional methods. Through blockchain, though, distributors could easily see product types, farming practices, harvest dates and amounts, treatment info, fair-trade certifications and other information. This would allow them ample time to find a suitable replacement or additional partner.

Transparent Safety Protocols

The food supply chain is lengthy, includes a lot of different parties and involves a lot of metrics and details that need to be recorded and monitored. The problem with having so many factors is that it can muddy the waters. It’s hard to keep track of what every party is doing, where problems exist and what improvements can be made.

Many modern food supply providers are as transparent as they can be with partners and colleagues, but it’s not an element you would describe as streamlined or accessible to all. Blockchain can completely alter and disrupt this for the better.

Since food safety is an enormous concern for suppliers, distributors and retailers, blockchain can offer more than just peace of mind. It can help organizations perfect the entire process, improving safety for consumers and even enhancing the freshness or quality of the products provided. Improper storage or transport, for instance, can have a detrimental effect on quality, before the goods even reach store shelves. Blockchain will enable better tracking and monitoring, and make the resulting details much more accessible and transparent.

It’s Time for the Food Supply Chain to Evolve

The coming change is warranted and welcomed by many. A more transparent process means a much more accessible system. Suppliers can better communicate with farmers and food sources. Distributors and retailers can keep a close eye on the goods they’re acquiring and offering to consumers. Furthermore, safety, quality and quantity can be more accurately monitored and measured by everyone along the way. It’s time for the food supply chain to evolve in this way — it’s been a long time coming.

Erika Miller
FST Soapbox

When Worlds Collide

By Erika Miller
2 Comments
Erika Miller

The Foreign Supplier Verification requirements of FSMA have perhaps been less well advertised than those of the Preventive Controls rules, but the compliance dates are fast approaching nevertheless. On May 30, 2017, a new field will appear in Ace, the software system wherein importers declare their imports and, in so doing, fulfill the requirements of many different U.S. regulations. This seemingly innocuous event will have serious and wide-reaching implications for all entities involved in the importation of food intended for consumption in the United States, but perhaps no one will be more affected than brokers and distributors, for they have long relied on the protection of their sources to ensure a share of the profits on their imports.

Exchange knowledge about managing your supply chain at the Best Practices in Food Safety Supply Chain conference | June 5–6, 2017 | LEARN MORE

Brokers and distributors often provide an important service by taking care of the legal requirements to bring a product into the country, and by purchasing large quantities of product that can then be broken down into more manageable quantities for their customers. Nowadays, information that was used to be transmitted to Customs and Border Protection (CBP) on paper forms is entered in Ace, which is a one-stop-shop software system that aggregates data on all imports. This data can then be accessed by several government agencies, including the FDA. Anyone wishing to bring food into the United States for consumption on our shores will be required to declare a Foreign Supplier Verification Program (FSVP) Importer for the food, and the names entered as FSVP Importers will then form a database from which the FDA will work to ensure enforcement of this program.

This FSVP Importer may or may not be the same as the Importer of Record (IOR). Large companies are already re-writing their import contracts to include this requirement, for it’s quite clear already that communication of expectations will be vital to the success of this program. The FDA recognizes that it is possible that unscrupulous parties may enter the name of a party as the FSVP Importer who does not realize their name has been entered; however, the main recourse for the injured party is to better communicate with their supply chain to ensure the issue does not arise again.

Although these technicalities are important to understand, it is perhaps even more interesting to consider the implications of all the FSMA requirements surrounding this rule. For example, FDA’s requirements for records are very clear, and each record must include the name and address of the facility at which it was created, in addition to other information. The rules of FSMA are also quite clear in stating that brokers or distributors cannot provide the necessary food safety paperwork on their own; rather, this documentation must come from the grower, manufacturer, processor—for a true farm-to-fork implementation, in keeping with the spirit of the rule.

What does this mean for the broker who sells to a large company that is perfectly capable of purchasing the large quantities required to “go direct”? Will they be cut out of their livelihoods by being forced to give this information to their customers? This is a question that has been raised in all the FSVP Importer classes held to date, and in reading the rule, it appears clear that the broker is expected to disclose their source. How else is it possible for them to follow the law, and assure their customer that the food was produced with the same level of food safety as if it were made here in the United States?

Foreign Supplier Verification, TraceGains A Comprehensive Guide to the Who, What & How to FSMA’s FSVP Rule

Have confusion regarding some of the specifics to FSMA’s Foreign Supplier Verification Program rule? You’re not alone… Are you the importer? What if you’re a broker? What are the actual contents of a verification program? This comprehensive guide can help answer some of these lingering questions, and will provide you with a couple real examples of FSVP in action.

This is a particularly interesting conundrum because at its heart, this is an issue of information exchange between private companies. Although the FDA does expect that some entity will keep the records to satisfy the requirements of the FSVP, they will not expect this paperwork to be transmitted to any government agency prior to approval of a load for import. Rather, the FDA will send electronic records requests to the entities declared as FSVP Importers later, wherein they will ask for the records related to previous shipments. Should the FSVP Importer declared at import not produce the required documentation at the time of this request, enforcement activities are expected to result (eventually, once the rule has gone into effect and regulation has begun).

It stands to reason that some entities may continue to operate in a fool’s paradise for some length of time, thinking nothing has really changed. This is incredibly dangerous for the business, its reputation and indeed, for the consumer. Times are obviously changing across the globe, and the FDA is doing its best to keep up with the demands of an increasingly complex global society. The broker who enters his own name without understanding the implications of what that means may find himself on the receiving end of a number of records requests from the FDA, with no records on hand with which to fulfill them. This is not an enviable position, and will likely result in an in-person visit from an investigator if the food imported is considered high-risk.

There are, of course, many brokers and distributors who are proactive and concerned about food safety. These are the companies that are sending multiple individuals to FSVP training to stay informed about the changing face of import regulations. Many of these brokers and distributors already gather paperwork such as third-party audit reports and letters of guarantee from their suppliers, but they do not transmit this information to their customers. Should these proactive companies be essentially punished for following the letter of the law? Even if a purchasing department has a warm personal relationship with their broker or distributor, if the C-suite sees an opportunity to save a substantial sum on their commodity of choice while increasing transparency in the supply chain, certainly those decisions will be made without regard for hurt feelings.

What about redaction? Can the brokers or distributors redact the sensitive information from the documents, and transmit them in that way? Perhaps, but after consultation with a brilliant and experienced legal mind, redaction may not be the panacea it first appears. For example, redaction of documents is a boring and redundant task, frequently relegated to the intern or other low-paid office worker due to its repetitive nature. These workers may perform the redaction lackadaisically, or use CTRL-F to find all appearances of the information to be redacted. In doing this, they often miss important information that appears in an image or is misspelled. Additionally, anyone who has spent much time in the food industry understands that this is a small world, and it is often easy to recognize a document simply from the style in which a particular company presents all its documentation. Clues such as colors, partial logos and incomplete redaction can lead to a shrewd individual deducing the original author of the documents quite easily.

Although there are no answers to be had at this juncture, especially considering that the compliance date for these requirements has not yet passed, it is important to think about all these implications, along with many others that are being brought to the forefront through the Importer workshops approved by the Food Safety Preventive Controls Alliance. The FDA readily admits they are learning right alongside industry, and they have every intention of continuing to educate while they regulate. If these issues cannot be hammered out between industry representatives and the FDA directly, it stands to reason the issue will eventually be brought before the courts, where the demands of capitalism will be weighed against those of regulation for food safety. Is there a legal precedent for this situation? If you know of one (or several), please leave the information in the comments below to continue the discussion.