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The FDA proposes stricter traceability rules for certain food products



This post is part of a series sponsored by Worldwide Facilities, LLC.

The ability to track where food originally came from allows authorities to better contain and manage contaminants when they occur. Recently, the Food and Drug Administration (FDA) has proposed that additional requirements for traceability registration be introduced that go beyond existing rules for activities that manufacture, process, package or keep food. Here's what your customers need to know about the proposed updates to existing rules.

Why the update?

The original 2011 legislation provides that certain requirements must be met to enable proper food traceability and record keeping under the FDA Food Safety Modernization Act (FSMA). In September 2020, however, the FDA released a proposed rule aimed at improving the traceability of food from soil to table under FSMA Section 204 to help manage food safety risks.

What is Section 204 Rule?

Simply put, the rule defines the extended registration requirements for tracking and tracing of food products. It contains additional traceability requirements proposed by the FDA and focuses on certain foods mentioned in the Food Traceability List (FTL) that may be considered a higher risk of contamination. All foods on FTL, as well as foods that contain ingredients listed in the list, are covered by the new requirements.

What is the main purpose of the new requirements?

 FDA proposes stricter traceability rules for certain food products The goal of the revised FDA tracing requirements is to prevent or better mitigate foodborne illness outbreaks by introducing stricter record keeping that enables traceability from end to end.

The requirements will be mandated:

  • How traceability registers are to be maintained.
  • That a company can provide traceability records within 24 hours of a request.
  • That records and data are well maintained and easily sorted into an electronic spreadsheet to quickly determine the source of an outbreak and to assist with a product recall or other public health hazard.

Technology will simplify the tracking process

The lack of data to track specific products through the supply chain has been a challenge for the FDA. For the new tracking system, the FDA is looking at developing standardized data elements that facilitate access to information sent to the next unit in the supply chain. The FDA hopes to utilize digital features in a more technically enabled traceability system for certain foods will also help it maintain more accurate records.

Conclusion

Your customers do not expect problems that could lead to a product recall. But if that happens, they may be surprised that most commercial liability insurances do not provide insurance coverage for a recurring event.

In fact, a product contamination event can be costly, resulting in expenses associated with:

  • Removal / recall / destruction of contaminated products.
  • Must hire damage control consultants / experts.
  • Extended business interruption due to partial or complete closure of the business.
  • Third Party Claims for Consumer Injuries.
  • Costs for property damage if a contaminated product becomes an ingredient in another product.

At Worldwide Facilities, we have the expertise and markets to provide your customers with comprehensive product recall insurance to help them get on the road to financial recovery. Contact David Fiske at (312) 465-5305 or dfiske@wwfi.com or Lori Hunter at (213) 236-4585 or lhunter@wwfi.com if you want to know more about our products and services or for coverage issues.

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