Currently the Food and Drug Administration (FDA) is working through guidelines for a new rule that will place added pressure on food manufacturers once passed. With every new regulation come changes to the way manufacturers do business, often hitting their wallets in the process. The deadline for the new rule resolution comes up in November 2022, giving businesses some time to strategize before the changes take place.
Proposed new food traceability requirements are certain to add expenses and labor but may not improve the way the FDA receives its information. For one, the FDA currently does not put measures in place for outbreaks caused by food products until after the Center for Disease Control has investigated and returned a verdict for solving the problem.
Waiting for that investigation to take place takes time, sacrificing the health of people impacted and putting involved businesses at greater risk. The CDC, after all, is a private institution; better and faster solutions to enact an action plan are quite possible, if explored.
Lot Tracking is a Must
When the responsibility falls on the manufacturer despite the point of contamination, every item must be tracked in batches with lot number tracking. On an everyday basis, the lot number is associated with date of receipt and expiration date to ensure fresh product is delivered to the customer. Most importantly, lot tracking gives the manufacturer the ability to track a product’s path backward and forward in its journey. Aside from meeting FDA compliance regulations, food traceability allows the manufacturer to minimize the damage both to the company and the consumers by quickly locating tainted product and limiting recalls to the fewest days’ worth of shipments possible. Ultimately, having lot tracking in place will save the manufacturer a lot of money and serve to mitigate a bad reputation.
When different products are combined, food traceability becomes more complicated. The proposed FDA rule would not address this scenario, nor would it be appropriate for the FDA to dictate processes for every industry type.
FDA further complicates the rule with the expectation that the item is tracked by lot at every point of the supply chain. If simplified, the FDA could request information from the manufacturer who originally created the lot number tracking.
The FDA has been open to comments from the industry; however, are unlikely to ask for additional feedback prior to publishing the new rules. In the interim, food manufacturers should take the time now to put a system in place for lot tracking. Ultimately, they will find that the few extra steps involved in creating the tracking number will give them greater control over inventory, help avoid spoilage, improve product quality, and provide the reporting demanded by the FDA. If the rules are simplified, most businesses should be able to adapt without too much trouble. If left as is, it’s going to be a tough nut to swallow.
Image source: Food inspection via Alexander Raths/Shutterstock