4 replies to this topic

[hglazunov]

Hi everyone, 

 

Is anyone else struggling with the FSMA204 Final Rule regulations? In theory it all seems simple, track your product and the ingredients that make up the FTL (Food Traceability List) at each step. We are struggling with our GDST and syncing it to our current ERP and feels like we're doing it blind. Can anyone share some insight that made it all "click" for them?

 

Thank you in advance,

 

Helen

[jfrey123]

No insights yet, we too are struggling with what it's going to look like for us.  The ability to get it all into a sortable excel file at random FDA demand is also a factor for us.  Enforcement appears to be delayed to 2027 now, so it's hard to get traction to make changes at my company for now.  Knowing that our customers are affected is likely going to be the driving factor for us, once they start asking for it it'll become a rush project lol.  I also forecast we'll have some struggles with our smaller farms and packing houses to sort through whatever hodgepodge they come up with for sending the KDE's to us (I'm in the cut fruit and veg industry just as a heads up).

[hglazunov]

Thank you for sharing, we're in the Seafood industry ourselves. I really struggle to figure out how to get out of the weeds and have some traction to this data while higherups are demanding implementation plans and presentations... we are just not there yet. 

No insights yet, we too are struggling with what it's going to look like for us.  The ability to get it all into a sortable excel file at random FDA demand is also a factor for us.  Enforcement appears to be delayed to 2027 now, so it's hard to get traction to make changes at my company for now.  Knowing that our customers are affected is likely going to be the driving factor for us, once they start asking for it it'll become a rush project lol.  I also forecast we'll have some struggles with our smaller farms and packing houses to sort through whatever hodgepodge they come up with for sending the KDE's to us (I'm in the cut fruit and veg industry just as a heads up).

[TucsonFoods-QA]

We use semi soft cheese in a product that is not cooked. We do freeze it and it's my understanding that if the cheese is frozen or has been previously frozen that it's exempt? Anyone going through this one?

[Shrimper]

Good day hglazunov,

 

I too am in the seafood industry focusing on frozen products, but mostly shrimp. I am interested in your GDST system you have. I would love to hear more about it. My plant is pretty small and all of our work is done on paper, so that makes the transition from paper docs to a "sortable spreadsheet" more difficult. From my understanding, the steps to approach FSMA 204 is to 1) identify the CTE's that apply to you, 2) list out which KDE's you already track, and 3) begin to format a traceability plan. Some further steps that I think area valuable to do are to draft a letter that addresses the requirements for your persons up and down the supply chain. Our biggest worry is regarding the shrimp shed that unload the vessels since they are considered "first land-based receivers." I asked for some advice regarding FSMA 204, and got similar responses to this page, but someone did attach some good links:

 

Link for Traceability plan template

Link for Supply Chain Written Agreement (to ask suppliers to sign off and agree that they will help comply with FSMA204

Link for Supply Chain Partner Notification Letter (This would let your downstream partners know you did not perform the killstep, but someone else will)

Link for Traceability Worksheets in PDF and Docx format (These help you figure out if you already keep track of KDEs and where you're getting them from)

Link for FDA Official CTE & KDE guide.

 

Let me know if you have more questions, FSMA is a topic I would like to discuss more since it seems everyone is sort of confused on the topic. 

 

Best,

Shrimper