Are you prepared for the US Food Safety Modernization Act (FSMA) Rule 204?
In 2021, Canada exported over US$31 billion worth of agricultural products to the US. And according to the US Department of Agriculture, 61.5 percent of U.S. agricultural imports from Canada consisted of meat and other animal products, grains and feed, oilseeds, and oilseed products.
In 2021, global food exports from Atlantic Canada were valued at over $8.1 billion, which was more than $2 billion over the previous year and the highest in the last five years. The United States was the biggest buyer of food products from Atlantic Canada with imports valued at just over $5.7 billion in 2021.
With the new Rule 204 of Food Service Modernization Act aka FSMA 204 by US FDA, Canadian companies involved in exporting food products to the US market must start putting plans together to comply with the stringent traceability and provenance requirement across the supply chain.
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What Is FSMA Rule 204?
The US FDA finalized FSMA Rule 204 in November 2022, recognizing that ensuring the safety of the food supply is a shared responsibility among many different points in the global supply chain for both human and animal food. Section 204 of the FDA Food Safety Modernization Act (FSMA) requires additional recordkeeping requirements for food products to be consumed within the US to protect public health. Additional recordkeeping requirements are outlined in the Food Traceability Final Rule and are intended to allow for faster identification and rapid removal of potentially contaminated food from the market, resulting in fewer foodborne illnesses and/or deaths.
The Food Traceability List (FTL) identifies the food products for which the additional traceability records are required. The additional recordkeeping requirements apply to the foods specifically listed on the FTL, and to food that contain listed foods as ingredients, provided that the listed food that is used as an ingredient remains in the same form (e.g., fresh foods) in which it appears on the list. FSMA Rule 204 went into effect in January 2023, 60 days after the final rule publication in November 2022. Within the new rules, suppliers have 24 hours to produce full traceability records of that food item when an event occurs (possible containment, disease, food poisoning etc.).
It’s not enough to become JUST compliant – Be a Leader!
It is critical to understand that under the new rule, it is not sufficient just for you to become compliant with the traceability requirements. Imagine a scenario where you are the only one who kept records of all the critical tracking events while other suppliers in your network didn’t. Now, if you are asked by the FDA to produce the traceability records in 24 hours’ notice, would your team be able to achieve this on such a tight deadline? By ensuring full traceability across your close loop supply chain (farmer, processor, packaging, storage, shipping, importer, distributor, retailer, or food services to customer) network, you’ll gain visibility into the entire supply chain. This will protect you from exposing yourself to non-compliance related risks as well facilitate better sourcing decisions by improving your supplier mix.
Consumers are also becoming more demanding when it comes to traceability. They want to know what the source of their food is and can it be trusted. In a recent survey by IBM, it is found that 71% of those surveyed think traceability is very important and are willing to pay a premium for brands that provide it.
Source : https://tinyurl.com/Meet-the-2020-consumers
How Barrington Edge can help you complying with FSMA 204 ?
Our team of consultants, analysts, subject matter experts, and technologists, have significant experience in Supply Chain, Agriculture, Retail, Consumer Packaged Goods, Distribution, and Technology. We have collaborated closely with multiple clients in designing solutions for Food Authenticity and Track & Trace along with assessing Sustainability Impact over the last few years. We have significant knowledgebase on the key requirements, frameworks, and various nuances of FSMA 204, and we have the necessary skillsets, tools, and processes to help organizations become FSMA RULE 204 READY.
Our team of consultants and SMEs can review your existing supply chain process, map all the stakeholders involved and create a close-loop Traceability Plan to comply with Rule 204. We can help you digitalize your entire supply chain process, build integration capability to existing supply chain partner IT systems, and build transparency and traceability at the core of it.
In our most recent project, we worked with farmers, processors, distributors, and retailers across North America with the goal of sourcing the highest quality food available and getting that food to market. In this project, we built a technology platform that calculates the environmental impact of getting food from the farm to a retail shelf, and also computes the authenticity and provenance of the food through a block chain-based track & trace solution to help deliver a high degree of trust to different stakeholder, regulatory bodies, and ultimately to the consumers.
To learn more about how the team at Barrington Edge can help you navigate through the stringent FSMA 204 requirements and become fully compliant, please reach out to edge@barringtonedge.com.
