PTI, much of the information required by the rule is captured in the PTI-compliant case label. During the webinar, Kennedy reviewed a PTI-compliant case label and explained the elements that pertain to and align with the rule’s requirements, such as the barcode’s GTIN and internal batch or lot code, which together provide the information required in the rule’s “traceability lot code.” The PTI website includes resources, such as electronic sortable spreadsheets; a traceability implementation guide is in the works. PTI leadership is currently focused on updating its best practices related to capturing and sharing data with trading partners. Becoming compliant with the Rule In August 2023, Western Growers published a guidance document to help companies comply with the Traceability Rule. The guide covers: 1) which foods are and are not covered by the rule, 2) how to determine which requirements apply to you, 3) the information you are responsible for collecting and sharing, 4) how data and information will move through the supply chain, and 5) sharing information and data with the FDA. In addition, the FDA has numerous online resources available that provide an overview of the rule, highlight key features and elements, list
the foods covered by the rule, review exemptions and modified requirements, and provide examples. What is important to remember? The Traceability Rule assigns different entities slightly different responsibilities depending on whether they are engaged in harvesting, cooling, initial packing, first land-based receiving, receiving, transforming or shipping foods on the Food Traceability List. Although “growing” is not a CTE, farms that do not engage in other activities, such as harvesting, cooling or initial packing, are nonetheless required to maintain a traceability plan. FDA explicitly did not mandate that traceability records be maintained in a specific format, and covered entities are permitted to choose their preferred storage method. That said, the rule still requires traceability records to be provided in an electronic, sortable spreadsheet within 24 hours when it is necessary to address a threat to public health. For this reason, while it is not required, companies may decide it is worthwhile to store the information electronically. For questions related to this regulation and WG resources, contact us at science@ wga.com.
Minos Athanassiadis Vice President, iFoodsDS
Andrew Kennedy, Principal Traceability Advisor, iFoodsDS
JANUARY | FEBRUARY 2024
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Western Grower & Shipper | www.wga.com
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