Ep. 158. Harris and Grantham: How Food Processors are Preparing to Meet FSMA 204 Traceability Requirements
Nov 28, 2023
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Blake Harris and Alison Grantham discuss food processors preparing for FSMA 204 traceability requirements, including the use of antimicrobial blue light for treating listeria contamination, the importance of nomenclature and traceability, improving traceability with Ambient IoT, implementing traceability systems, the impact of FDA's final traceability rule on GDSC standards, and the importance of cooperation and technology in meeting traceability requirements.
Cross-contamination actions were more common in restaurants without manager certification or policies on hand washing and bare hand contact with ready-to-eat foods.
Antimicrobial blue light could be a potential intervention for treating Listeria contamination in food production materials.
Companies preparing for FISMA 204 compliance should prioritize education and training for teams that will be affected and establish interoperable data standards.
Deep dives
Understanding the Challenges of Restaurant Food Safety
A CDC study showed that frequent contamination actions in restaurants were linked to a lack of food safety certification, training, and hand washing policies. Cross-contamination actions were more common in restaurants without manager certification or policies on hand washing and bare hand contact with ready-to-eat foods. Chain restaurants generally had better food safety practices than independently owned restaurants. The study also highlighted the negative relationship between manager experience and food safety outcomes.
Using Blue Light to Inactivate Listeria Monocytogenes
A study demonstrated the efficacy of antimicrobial blue light for inactivating dried cells and biofilms of Listeria Monocytogenes. Polystyrene showed the highest reduction in log after blue light treatment, followed by HDPE. The study suggests that antimicrobial blue light could be a potential intervention for treating Listeria contamination in food production materials.
Implementing Whole Genome Sequencing for Foodborne Illness Surveillance
The World Health Organization issued a guide on how whole genome sequencing (WGS) can be used to improve foodborne illness surveillance and response. The guide outlines the minimum requirements for establishing foodborne illness surveillance and response systems, including lab capacities and certifications. It also provides step-by-step guidance on forming working groups, describing existing systems, and running pilot studies to prepare for the implementation of WGS for surveillance and outbreak investigations.
Preparing for FISMA 204 Compliance with IFT's Traceability Experts
Companies preparing for FISMA 204 compliance should prioritize education and training for teams that will be affected. This includes Safety QA, Shipping, Receiving, Procurement, Compliance, and Product Development. Internal preparation should also involve educating leadership and allocating budgets for necessary software updates and systems. Companies should then look externally to direct supply chain partners, ensuring they are aware of the data sharing requirements and discussing how to exchange data effectively. Joining pre-competitive commodity-specific working groups and industry associations can help broaden preparation efforts. Overall, FISMA 204 will drive companies to invest in technology, cooperate with suppliers and customers, and establish interoperable data standards.
Advances in Traceability Initiatives and Technology for FISMA 204 Compliance
The FDA's low-no-cost traceability challenge has sparked advancements in traceability initiatives and technology. This initiative invited stakeholders, including technology providers, to present low and no-cost technologies. Evaluations conducted by the Institute for Food Technologies Global Food Traceability Center (GFTC) identified key themes, including interoperability, data standards usage, solution support and infrastructure needs, and usability. The evaluation focused on assessing innovation, enabling the adoption of digital traceability technology, and fostering stakeholder collaboration. The availability of low-cost or no-cost technologies aims to enhance the adoption of end-to-end digital traceability, with interoperable software systems playing a crucial role. The report encourages combined efforts by stakeholders and highlights the progress made in making traceability a reality.
Blake Harris, CSCP, is a specialist in standards and process enhancement, digital solution development, and implementation, with more than a decade of experience in supply chain-related functions within the private sector and at non-governmental organizations (NGOs). He places high value on tackling complex issues to create efficient and uncomplicated solutions. As the Technical Director at the Institute of Food Technologists' Global Food Traceability Center (IFT’s GFTC), his focus centers on enhancing data digitization in food systems, which involves collaborative efforts with a diverse range of stakeholders from industry, government, and NGO sectors.
Alison Grantham, Ph.D., is a consultant who brings a rigorous, practical approach to her work with public and private sector organizations to improve the food system. Alison focuses on helping her clients develop data-driven tools and programs to define and achieve goals to enhance food and agriculture. She has worked closely with IFT's Global Food Traceability Center since 2019, developing the Global Dialogue in Seafood Traceability (GDST) standards, among other traceability initiatives. Prior to consulting, she led food systems research and development, and then food procurement, at an $800-million revenue e-commerce food company. Previously, she led Penn State Extension's beginning farmer training program and directed research at the Rodale Institute. Alison currently serves on the Rodale Institute's Board of Directors and the National Academy of Sciences' Committee to advise the U.S. Global Change Research Program, the body that oversees climate and other global change research across the 14 federal agencies.
In this episode of Food Safety Matters, we speak with Blake and Allison [35:05] about:
IFT traceability experts’ observations over the past year regarding industry preparation to comply with FSMA 204 in 2026
Advances in traceability initiatives and technology, especially low-cost/no-cost technologies promoted by FDA, to assist industry compliance
Advice for companies that have not made much progress in compliance efforts on how they can get started
Advice for companies that have made strides toward assuring compliance on how they can ensure they are on track to fully meet FSMA regulations by January 2026
How worldwide adoption of Global Dialogue on Seafood Traceability (GDST) standards has been facilitated, tools offered to help the seafood industry comply with GDST standards, and how GDST standards are influenced by FSMA 204
Ways in which FSMA 204 compliance will benefit public health and food safety
How FSMA 204 can help optimize individual company and entire supply chain operations.
