Supermarket Perimeter - February 2024 - 25

record-keeping requirements, reducing the likelihood of information
gaps in the event of a food safety concern.
The provision also allows for flexibility, permitting the FDA to identify
specific records necessary for different types of food facilities.
" Retailers who operate their own distribution centers and central
kitchens have new record keeping requirements for every facility
under Section 204, " said Randy Fields, CEO of ReposiTrak, a retail
technology company focused on traceability and compliance. " This
includes collecting traceability lot codes and related transaction data
for every shipment of Food Traceability List products into and out of
DCs and central kitchens, and into stores. Also, records must be created
and retained at the central kitchens when products from the FTL are
transformed into other products on
the FTL. This could result in many
millions of records to be generated
and retained annually for even a
Randy
Fields
regional retail chain. "
" All traceability records
containing the required Key Data
Elements as prescribed by FSMA
204 must be retained for 24
months, and the data must be sent
to the FDA within 24 hours of a
request, " Fields said. " Practically no
retailers have systems in place to do
this today. "
In addition to enhancing traceability, Section 204 emphasizes the
importance of interoperable systems for record-keeping. The act
encourages the use of technology and standardized formats to ensure
that records can be easily accessed, exchanged, and understood by
relevant stakeholders. This provision recognizes the role of modern
information systems in streamlining record-keeping processes,
reducing errors, and expediting response times during food safety
incidents.
" The food supply chain needs to generate tens of billions of
traceability records for FSMA 204 compliance, and unfortunately most
retailers don't have the technology in place to do this today, at the
scale required, " Fields said. " Retailers will need to enhance existing
operational systems or look for third party technologies to augment
existing systems to capture data, and create and maintain traceability
records. "
FDA has new powers
Section 204 also empowers the FDA to access and review these
records promptly. This authority enables the FDA to conduct effective
investigations and identify the source of a food safety issue efficiently.
The provision also outlines specific circumstances under which the
FDA may access records, including when there is a reasonable belief
that a food product is adulterated and poses a threat to public health.
This targeted approach ensures that the FDA's authority is exercised
judiciously while prioritizing public safety.
" Retail stores will need to capture and record certain data for
foods on the FSMA 204 Food Traceability List received at the store, "
said Andrew Kennedy, principal traceability advisor for iFoodDS, a
supermarketperimeter.com
FEBRUARY 2024 - 25
Examples of
traceability
lot codes
(01)04562135785133
(17)140704 (10) DE-456
GS1-128 Example
475123C
6-digit code + letter
to represent grower/
manufacturing location
BFCA179A152023213
6
1
2
3
4
1. Company name
2. Production location
3. Product
4. Grower
5. Julian date
1147M2023213
2
1
3
1. Product code
2. Facility
3. Julian date
134AD5607
Randomized alphanumeric
code generated by firm's
traceability system
Source: FDA
http://www.supermarketperimeter.com
Supermarket Perimeter - February 2024

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