Editor's Plate: Is An Electronic Records Mandate Coming?

Feb. 8, 2022
Frank Yiannas of the FDA says the agency is working on a track & trace mandate to be revealed in the fall.

We had this month's cover story on food safety all tucked away when a Wall Street Journal story appeared that said the FDA is working on a mandate for tracking food across the entire supply chain, potentially giving a boost to blockchain-enabled tracing.

Frank Yiannas, deputy commissioner for food policy and response at the agency, told the business newspaper the FDA expects to complete the proposed rule by November. It would require the food industry to maintain records associated with critical tracking events on the supply chain for certain products – critical events such as growing, receiving, transforming, creating and shipping food products.

As much as we write about track & trace and recall readiness in the food & beverage industry, it's always amazed me that while the government agencies require processors to keep records, they don't have to be electronic records. And to be accurate, Yiannas said all of one sentence in support of blockchain, although he clearly sees the need for digital/software records, not paper ones.

The rule the FDA is working on appears to be a refinement and expansion of the agency's September 2020 “Requirements for Additional Traceability Records for Certain Foods,” a proposal to establish additional traceability recordkeeping requirements for products such as leafy greens, fresh cut fruits and vegetables, some types of fish, shell eggs and nut butters.

That proposed rule followed a number of foodborne illness outbreaks that involved produce, and they proved to be some of the most difficult to trace back to the source. That new rule was intended to make it easier to rapidly and effectively track the movement of a food in the event of a foodborne illness outbreak.

Blockchain does appear to be a good enabling technology. Most folks first heard of blockchain, which originated in 2009, as a way to record monetary transactions in the Bitcoin network. Transactions between participants on the system are bundled together into blocks, which are then linked to the previous block, forming a chain. Each new block is based on the previous one, which supposedly makes changing previous entries functionally impossible. At the same time, this immutable chain is also visible, at least to those given access to it, which makes for a cleverly secure but transparent chain of information.

Think of the possibilities in tracking and tracing. Nestle and Dole, Walmart and Kroger are. They're among apparently more than 100 organizations in the bigger food industry exploring it through Food Trust, an effort shepherded by IBM and using IBM's food-optimized blockchain software and systems.

The Journal story said Walmart first tested the concept in 2017, then started using Food Trust in 2018 to track leafy greens, including romaine lettuce and spinach. It has since added green bell peppers and other categories and expanded the list of suppliers it tracks from 12 to about 100.
(As an aside, Yiannas was vice president of food safety at Walmart during that time and he spearheaded the retailer's entry into Food Trust.)

Likewise, Nestlé has tested blockchain technology to track 10 food suppliers and told the Journal it's "exploring a pipeline of products to track on Food Trust in 2022 and beyond."

Blockchain has its skeptics, and all track & trace tools are only as good as the data put into them. But it certainly appears clouds and software, not filing cabinets, are the future of food safety. Prepare for November!

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