Opinion column

USA: Rule 204 of Food Safety Modernization Act (FMSA)

What is the food traceability list?

It is a list of foods that will be subject to additional recordkeeping requirements under FSMA Rule 204. This includes:

– Most fresh fruits and vegetables, all green leafy vegetables, melons, sprouts, cucumbers, tomatoes, bell peppers, fresh herbs, tropical tree fruits, and all fresh-cut produce.

-Soft cured and semi-cured cheeses

-Eggs in shell

-Nut butter

-Some categories of seafood

-RTE delicatessen salads (ready to eat)

What should I do if I grow, ship, pack, process, manufacture, or sell any of the foods on the Traceability List?

Maintain historical records of all processes, applications and events related to the production line. Paper originals, electronic or true copies (must be legible and must be able to be stored to avoid deterioration or loss). The idea is that traceability records should be able to be provided to the FDA no later than 24 hours after a request associated with a public health threat is made.

When does rule 204 start to apply?

FSMA Rule 204 will go into effect in January 2023, 60 days after the final rule is published in November 2022 (process has already started). The FDA will give companies two years to comply, giving them until 2025 to fully comply. However, it is imperative that companies start preparing now, as researching and implementing a food traceability solution takes time and rigor. If you wait until the rule is published to start preparing, you may find it difficult to meet the 2025 deadline.

Rule 204 gives us the opportunity to make significant progress on food safety issues that are so necessary in current times. On the other hand, the possibility of digitizing our records allows us to be more responsible and sustainable with the environment... are you ready?

John Paul Avendano

iFoodDS Representative

Juan Pablo Avendaño - iFoodDS Representative

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