Western Grower & Shipper Q4 2026

to asking, “Are we testing effectively and developing the science, technologies and surveillance capabilities necessary to anticipate and detect the emerging hazards we will face tomorrow?” And then there is traceability. With the publishing of FDA’s FSMA Rule 204 on traceability, the promise of enhanced, more efficient traceability is significant. However, no grower, shipper, processor, distributor, broker, retailer or restaurant can create an effective traceback system independently. Information must remain consistent and connected to food as it moves through the supply chain. This need for continuity marks traceability as a shared supply-chain responsibility and not simply a regulatory obligation assigned to individual businesses or sectors of a supply chain. Traceability, too, presents its own systems challenges. Companies are at different stages of implementation and have invested in different technological solutions and approaches to comply with FSMA Rule 204. As companies make decisions about which system to use and service providers build various tools, the focus, as a whole, should be on system interoperability, data quality and best practices that allow information to move safely and efficiently across the supply chain. Ultimately, no single supply chain segment can make traceability successful on its own; its value depends on shared responsibility and a coordinated farm-to- fork effort. The real opportunity before us is to strengthen all three legs of the stool and how they work together. After every outbreak, rather than focusing on traceability improvements or immediately looking for someone to blame, we

should be asking where information was lost, where time was lost, if investigations were driven by the data or by assumptions and how the connections among epidemiology, laboratory testing and traceability can be strengthened. Finding the source of an implicated food is not the same as solving an outbreak. Traceability may help investigators follow the trail, and recalls may help contain the risk, but neither can stand alone. Effective outbreak investigations require epidemiology, laboratory evidence and traceability to work together—not only to identify the problem, but also to understand it, contain it and prevent similar issues in the future. Earlier and more consistent exposure-data collection could improve the accuracy and completeness of the information available to investigators, helping them develop stronger hypotheses. At the same time, the testing conversation must evolve and focus on advancing the science, knowledge, technologies and surveillance capabilities needed to maximize its value. Combined with better traceability, these efforts could accelerate source identification and improve outbreak response. The goal for both industry and regulators should not simply be faster traceback. Traceback speed matters, but the larger goal should be a faster-learning, more efficient and effective food safety system—one capable of detecting potential signals sooner, forming better hypotheses and testing them with the best available science; tracing products rapidly through an interconnected and often complex supply chain; taking proportionate action to protect consumers; and, most importantly, using what is learned to prevent future foodborne illness outbreaks.

13 Western Grower & Shipper | www.wga.com October – December 2026

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