Businesses meeting the current definition of a farm that are growing, harvesting, handling, or holding covered crops subject to the FSMA Standards for the Growing, Harvesting, Packing, and Holding of Produce for Human Consumption (Produce Safety Standards, or PSS) are not required to have a formal food safety plan or traceability system. Regardless, many handlers, market-standards, and “approved-supplier” audit requirements from buyers mandate at least the one-step-back-one-step-forward tracking capability, including clear and defensible lot coding practices. Sprout growers are similarly covered under the PSS but have additional testing, recordkeeping, and recall-motivated tracking requirement expectations.
Traceability and recall programs are mandated for registered facility businesses that are subject to the FSMA Current Good Manufacturing Practice, Hazard Analysis, and Risk-Based Preventive Controls for Human Food. They must encompass the potential need, based on the hazard analysis, for supply chain controls and oversight management related to the FSMA Foreign Supplier Verification Program.
The ability to trace product into and out of an organization is like taking out an insurance policy: Most times it is not needed, but when it is, it proves highly beneficial. A well-designed and managed track-and-trace program will prove its value in times of crisis and in preserving your organization’s credibility. Recent experiences during the 2018 romaine lettuce outbreaks have, once again, graphically underscored the high potential for substantial collective economic losses and erosion of consumer confidence resulting from lapses and gaps in step-wise, handoff-to-handoff supply chain traceability.