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The FDA has finally released comprehensive guidance to address the food recall surge of 2019, including a focus on leveraging technology, traceability and data. It also introduces new supply chain controls that take advantage of these tools to enable greater security and collaboration between active industry participants. This Leafy Greens STEC Action Plan (STEC stands for “Shiga toxin-producing E.coli”) is a step towards modernizing compliance in the food and beverage industry, reflecting the need in the market to upgrade food safety culture with digital transformation.
Recalls in the fruit and vegetable sector represent only a fraction of adulterated or otherwise harmful food – meat and poultry account for the majority of tainted product. The rate of foodborne illness has continued to rise in recent years as the production chain has grown too big for any one entity to control. The only way to prevent the constant adulteration and costly recalls is to ensure visibility with food manufacturing and distribution traceability.
Here are the biggest items to consider when creating new data-driven compliance processes to meet emerging food and beverage regulations:
FDA 2020 Action Plan for Leafy Green Safety
The FDA’s 2020 Leafy Greens STEC Action Plan will be composed of three primary areas of execution:
Building upon the Food Safety Modernization Act (FSMA) Produce Safety Rule, the FDA will take steps to improve the food and beverage industry’s ability to prevent pathogen spread at the source. This will include greater raw material safety standards as well as education and support for stakeholders to enable meeting and upholding these guidelines.
Prevention action items of interest include:
- Enhance Inspection, Auditing, and Certification Programs – The Agency looks to rectify gaps in auditing standards and certification programs while also prioritizing inspections for leafy green vegetables.
- Buyer Specifications – FDA will work with retail and food service stakeholders on enhanced buyer specifications regarding food safety, leveraging the other compliance elements of the 2020 Action Plan.
- Leafy Green Data Trust – Taking advantage of the proliferation of digital information streams, the Leafy Greens Action Plan will establish an industry data trust that will feed into preventative analytics.
The Response portion of the Plan will focus primarily on investigative, research and reporting activities by the FDA. This area is where technology-enabled supply chain visibility and data retrieval take precedence – the Agency expects to be able to utilize records to traceback foodborne illness outbreaks to potential origin points and halt the spread of additional pathogens with a greater degree of accuracy.
Response action items of interest include:
- Conduct Follow-Up Surveillance During the Growing/Harvest Season – The Agency will continue surveillance efforts of farms identified through traceback data as where pathogens originated.
- Promote Tech-Enabled Traceability – Seeking to modernize food supply chain traceability across the market, the FDA will propose a new rule building upon FSMA Section 204 (electronic records compliance) and work with vegetable processors to design and scale an industry-wide track and trace system.
- Advance Root Cause Analysis Activities – Tighter collaboration between stakeholders at all levels, including federal, municipal and consumer representatives.
- Addressing Knowledge Gaps
While the Prevention and Response portions deal directly with the action items related to combating adulteration, the third and final stage is designed to actively work against the lack of knowledge faced by the FDA and food and beverage industry at large. The Addressing Knowledge Gaps section seeks to identify, highlight and solve areas where intelligence and research is thin, aided by technology solutions which will enable stakeholders to collect and share data on findings.
Knowledge gap action items of interest include:
- Data Mining and Analytics on Previous Outbreaks – Retrospective analysis will be conducted on past foodborne illness outbreaks to uncover previously overlooked data points.
- Adjacent and Nearby Land Use – The Agency will work with partners to better understand the spread of leafy green pathogens, collecting and analyzing additional data to that end.
FSMA Records Compliance and the Future of Food Traceability
It is important to reiterate that the 2020 Action Plan for Leafy Green Safety relies tremendously upon data because while the elements of this blueprint existed before, modern technology is now explicitly stated to be a requirement. The value of digital solutions for enabling visibility is too great to be ignored by the Agency, as well as by food processors and manufacturers.
As outlined by the FDA in the Plan, “[a]chieving end-to-end traceability throughout the leafy greens supply chain could make it possible to rapidly trace a contaminated food to its source, which can help shorten outbreaks, narrow product warnings, and prevent illnesses.” This thinking can be extended to the entire food and beverage market, allowing manufacturing and distribution chains to mitigate the impact of recalls or prevent them altogether.
To this end, the Agency is relying upon existing regulations around electronic record auditing. As seen in the “Promote Tech-Enabled Traceability” point, the FDA will strengthen the impetus for operational documentation through software to grant total supply chain visibility.
USDA Inspections and the Success of Food Safety Plans
While the FDA has received scrutiny for the wave of leafy green recalls, a study by US PIRG reveals that the work done through the FSMA has had a noticeable impact on limiting foodborne illness outbreaks. In a comparison with the USDA’s handling of meat and poultry contaminations, the researchers drew a parallel between how the implementation of Food Safety Plans and the lack thereof generated significantly different results. The Agency has made some progress curtailing recalls, while the USDA’s recalls have increased since 2013.
Effect of Coronavirus on Production and Supply Chains
To date there has been no definitive data showing the novel coronavirus passing through food; however, COVID-19 will certainly have an impact on the supply chain and compliance. Besides the human fatalities, information has been a big casualty of the outbreak and at least one beverage brand has had to fight back against rumors.
In addition to quarantine disruptions, manufacturers, processors and distributors will have to prepare themselves to face ingredient sourcing questions stemming from panicked confusion. There will also be a worst-case scenario in the event foodstuff or packaging disease transfer occurs – in any of these circumstances, visibility will be key to protecting your business brand.
What Food and Beverage Needs is the Right Data – and Automation
Bringing up the value of data yet again may sound like a broken record going off, but if you have been paying close attention, then you will have realized the scale at which you will have to expand your documentation practices. Once these traceability requirements become the standard not only for fruit and vegetable processors, but for the entire food and beverage industry, you may find yourself overwhelmed by the amount of information you will need to provide and the manpower needed to collect it all.
Your biggest pain point, however, will be that not all of this data will actually be valuable for compliance. This will eat away even more of your work hours as you manually sift through multiple fields trying to capture the figures the FDA needs. That is why your business requires a comprehensive software solution customized for automated traceability in the food and beverage market.
Migrate to Sage X3 Food and Beverage with SWK Technologies
SWK Technologies has developed a modified ERP compliance system built from Sage X3 and combined with a full suite of supply chain solutions. This bundled software platform designed for food and beverage allows manufacturers and processors to leverage the latest traceback automation features to ensure compliance with food safety regulations.
Download our e-book here to learn more about the only turnkey bundled compliance software developed for food and beverage manufacturing.