Summer is over, the heat is on and I start writing again. I’m really glad that I subscribed to a blog of that ambulance chaser out of Seattle, WA who really keeps me in the loop on all major policy changes and outbreaks and people affected by the outbreaks now represented by that law firm. And what a summer we had: Burgers Made by Cargill, Dairy Products made by Umpqua, Eggs from Iowa – this all will put the s.510 back on the front burner once Senate will return.
I don’t know if it is just me, but for me it seems interesting that the “Food Safety Modernization Act” will be put back on the front burner due to the large egg recall, BUT WON’T CHANGE A THING, at least not for eggs, since it is just changing the way we trace FDA regulated food products. The list above does not contain any of these, all are USDA regulated foods. Ohhh…well, perhaps legislators will notice. Things have certainly shifted, at least in the public where the large outbreaks covered in the news moved from FDA regulated product to USDA regulated product. Until the egg recall, it was understood that USDA regulated food is better traced and that it would not take such a long time to find the source of an outbreak. Just in case you did not notice: It took 3 month to from outbreak to source identification in the egg recall.
Things in Washington D.C. seem to take time, so they will pass the legislation more or less as it is to fix the problems we noticed a year or two ago, and will later on adapt and change. I don’t think that in this instance they will stall mate over major necessary changes. Once they figured out that we have some very similar problems in the food supply chain, regardless if it is USDA or FDA regulated, legislation will synchronize and we will get better, interoperable traceability systems that allow the identification of the source of an outbreak will get much faster, otherwise the legislation would be ineffective. This is really needed in a country where we have hundreds of food related recalls every year.
It is also clear that GS1-Standards will be the centerpiece of key-element data we will use in food traceability. There is just no alternative. The meat industry has recently published an ‘implementation guideline for traceability’ which largely describes what 90% of them are already doing. Fruits and vegetables started developing the Produce Traceability Initiative (PTI), which creates much noise with not so many early adapters. There will be changes necessary to PTI, especially towards serialization. While these industries take a lead towards traceability, other parts of a very fragmented section of the food industry under the FDA roof do not do much or do this individually. FDA will look at the leaders and what they do, and regulate that others who need to follow. Plus, GS1 standards are already in all major retail and food service restaurants and in over 170 countries in the world. There is no alternative out there. They even have with EPCIS already co-developed a standard that allows with modern web service architecture full interoperability between different (traceability-) systems.
Adaptation of these technologies will likely take some time. I think there is nothing wrong with participating today in any GS1 standard based traceability system, whether it is a small solution or based on a large standard. It will come, no question. If you have it, you will be able to adapt. Early adapters are the only companies that will learn and experience how these systems work and are able to participate in regulatory process to get practical solutions. Those that don’t, need to eat whatever is served to them. I guess they will complain no matter what.
Those that wait have at least another year until FDA comes with final rules, and more if they deal with USDA regulated products. During that time, FDA will do trials, will research the current state of traceability systems that exist today and make up their mind on how they want to see it. FDA has already contracted with the Institute of Food Technologists to research the “Technical Aspects” as well as the “Cost Considerations” of Traceability Systems. They will be able to pass quickly rules that need to be adapted fast, they are already far ahead in the learning curve and you can read already what they learned.
We will get enhanced interoperable traceability systems, we will get them in the next 2 years, they will be based on GS1-standards, and they will, going forward from there, require food service establishments and grocery retailers to trace what they sold to whom to really be able to locate the source of an outbreak faster. Once the upstream food supply is managed, the last piece will fall into place.
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