Dream team assemble: Working together to comply with FSMA Rule 204
Signed into law in 2011, the Food Safety Modernization Act (FSMA) aims to help regulators trace and recall contaminated products. The final addition to the Food Traceability Rule, also known as FSMA Rule 204, will require additional record-keeping for certain foods. Unlike previous food safety regulations, FSMA Rule 204 demands significantly more planning, preparation, and coordination across departments. Leaders must implement comprehensive changes like redesigning production flows and replacing legacy systems to comply, which is complex and will take time. Because FSMA Rule 204 takes product traceability to the next level, it will also usher in an era of much closer collaboration among trading partners across a more efficient supply chain.
Each organization has its own unique journey towards modernizing data sharing to meet requirements. However, it’s evident that collaboration across various departments is essential, and there are a few key areas leaders should focus on as they build their teams.
Establish leadership buy-in and support.
“Getting prepared for FSMA Rule 204 is not just a flip of a switch,” says Norma Crockett, Director of Community Engagement at GS1 US, the leading not-for-profit standards organization. “It’s a team effort because you may need to introduce new standards, change SOPs, and in some cases improve your software capabilities...You need to change how you do business.”
This is not the time for leadership to wait and see, says Crockett. If your company is not well-prepared, your revenue, brand, and business could be impacted. So, it’s critical that the C-suite understands FSMA Rule 204 and how it differs from past rules. Leaders must create a sense of urgency around data recording requirements so changes are made in time.
When Dot Foods, the largest redistributor of approximately 125,000 products to distributors and food processors across North America, established their Trusted Supplier Program, they initially believed their data was accurate. However, as Matt Wand, Master Data Team Leader at Dot Foods explains, it quickly became clear that this was not always the case. “Those in operations quickly realized that our data wasn't always reliable,” he stated. This realization led to the necessity of enhancing their accuracy checks.”
To address this issue, Dot Foods implemented a new system across its 13 distribution centers. This included utilizing Advanced Ship Notices (ASNs) received through Electronic Data Interchange (EDI), ensuring consistent data based on GS1 Standards. Additionally, they developed an internal supplier scorecard to improve their ASN program. Such rigorous examination of data and processes is essential for most companies in the food value chain to receive and transmit information effectively.
Consider establishing a cross-functional team.
To comply with FSMA Rule 204, companies must verify and validate product data, then communicate it with vendors and customers. This may involve adopting unique identifiers to track where products are made and shipped. Although the requirements to meet the traceability standards may differ for foods like fresh produce or frozen seafood, the GS1 US FSMA 204 Readiness Checklist can provide guidance on where to start.
To coordinate efforts and stay on track, you should identify key organizational leaders and create a cross-functional task force. For many companies, complying with FSMA Rule 204 will touch virtually every function, including:
- Operations
- Food safety and quality
- Procurement
- Distribution
- IT
Another challenge is capturing, tracking, and maintaining the necessary data. If your Enterprise Resource Planning (ERP) system lacks the capability for additional reporting, you might need to upgrade to a next-generation cloud-based system or consider using third-party service providers. Alternatively, you may have to expand your workforce to meet the requirements of this rule. Fortunately, scanning technology can help reduce labor hours for recording and reporting information.
Get trading partners on board early for better data sharing.
To dramatically increase supply chain visibility, companies must coordinate and collaborate with their trading partners like never before. These include suppliers, distributors, third-party storage providers, and customers. Keep in mind these can be domestic or international entities.
Under FSMA Rule 204, companies must capture and share product information from manufacturing to the end customer. They need to work with trading partners to maintain consistent traceability lot codes throughout the supply chain, and any new lot codes due to transformations must be communicated. Each entity must also verify the accuracy and labeling of received information before passing it on. Engaging with trading partners now will ensure a smooth transition to this advanced traceability approach. Dot Foods’ success relies on working closely with suppliers and setting clear accuracy expectations, which has improved data accuracy and expedited shipments for trusted partners.
Although FSMA Rule 204 compliance may be challenging, it’s also an opportunity for the food industry to build a safer, more efficient supply chain. As industry leaders work with internal and external partners, they will reap benefits like cost and labor savings, better inventory control, sustainability, and consumer confidence.
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