13 replies to this topic

[shookimogh]

Hi every one,

Can someone help me to understand this new rule and help me to come up with a template ? or i appriciate if you can share your templates with me .

 

Thank you!

[TimG]

First, make sure you're on the list :)

FSMA Final Rule on Requirements for Additional Traceability Records for Certain Foods | FDA

[shookimogh]

First, make sure you're on the list :)

FSMA Final Rule on Requirements for Additional Traceability Records for Certain Foods | FDA

Thanks, I had already checked it. we make RTE imitation crab and a customer is asking us to implement this new system. I think regardless of being on the list, that's something they have an eye on. and honestly the material is too long to go through so i thought why not ask the forum for help.

Thank you, 

SM

[jfrey123]

I don't think there's an easy answer/template that any of us could provide.  Those of us affected, I guess speaking for myself, are still trying to navigate a sea of regulatory chatter on this topic as well as respond to the bigger corporate customers who are all figuring out how they want to receive the required traceability information.  GTIN labels seem to be getting thrown out there a lot, but I don't understand it yet.

 

If you're making an imitation crab product, am I wrong to assume that is cooked?  You'll need to capture Rule 204 KDE's for receiving and up through the transformation where a kill step is applied, but once you apply a kill step then the finished goods are not subject to Rule 204.

[tahoeskier]

National Fisheries Institute has some examples and templates.

Resources - About Seafood

 

FDA website also has a basic template you can modify

[Shrimper]

I don't think there's an easy answer/template that any of us could provide.  Those of us affected, I guess speaking for myself, are still trying to navigate a sea of regulatory chatter on this topic as well as respond to the bigger corporate customers who are all figuring out how they want to receive the required traceability information.  GTIN labels seem to be getting thrown out there a lot, but I don't understand it yet.

 

If you're making an imitation crab product, am I wrong to assume that is cooked?  You'll need to capture Rule 204 KDE's for receiving and up through the transformation where a kill step is applied, but once you apply a kill step then the finished goods are not subject to Rule 204.

 

Hey Shookimogh, 

 

jfrey is correct here. After making sure you are on the FTL, if your product has a kill step (which it does), then you have to maintain your KDE for your respective CTE's up until that point. My idea is that most people are already doing this except for the TLC and TLC reference/source. Just confusing all around 

[TimG]

Just confusing all around 

 

What's confusing to me is that I keep hearing Target, possibly Kroger (and more are rumored, those 2 were from reputable sources) is moving toward requiring these additional traceability rules on all products they purchase.

After seeing how specific the documentation is to the product, I don't see how.

[Setanta]

What's confusing to me is that I keep hearing Target, possibly Kroger (and more are rumored, those 2 were from reputable sources) is moving toward requiring these additional traceability rules on all products they purchase.

After seeing how specific the documentation is to the product, I don't see how.

 

 

Our senior management us preparing much the same way.  Trying to get coverage before Sam's, Costco, Walmart, HEB, etc. ask for this for everything.

I appreciate the thought, but...wow!

[shookimogh]

Hey Shookimogh, 

 

jfrey is correct here. After making sure you are on the FTL, if your product has a kill step (which it does), then you have to maintain your KDE for your respective CTE's up until that point. My idea is that most people are already doing this except for the TLC and TLC reference/source. Just confusing all around 

Hey, Is it not the same thing as maintaining the lot code of ingredients, packaging material and final product? what are these abbreviations ?

Thanks, SM

[shookimogh]

National Fisheries Institute has some examples and templates.

Resources - About Seafood

 

FDA website also has a basic template you can modify

Thanks a lot for sharing. i think it is at least a bit more understandable under their descriptions.

[jfrey123]

Hey, Is it not the same thing as maintaining the lot code of ingredients, packaging material and final product? what are these abbreviations ?

Thanks, SM

 

Different and way deeper level of trace information than what any of us are used to.  The abbreviations refer to the Food Traceability List and require you collect Key Data Elements for different Critical Tracking Events (event being receiving, shipping, any transformations of ingredients, etc).  Best source of info is here (and that's not saying much), but if you hold any ingredient on the new List of foods they issued, you're required to start participating.

FSMA Final Rule on Requirements for Additional Traceability Records for Certain Foods | FDA

 

As for @setanta, we're stuck in a spot with some of those major retailers as well.  So far it's only been some surveys as they try to get the lay of the land and figure out how they want to do it, and we're a little gunshy to start major changes in case we go down a path that doesn't support what they're going to demand from us formatting wise.  The fact retailers are hit with this traceability requirement on FTL foods means they have to put as much skin in the game as we do now, they can't just push it back to us while they do a bare minimum for tracing.

[shookimogh]

National Fisheries Institute has some examples and templates.

Resources - About Seafood

 

FDA website also has a basic template you can modify

Hi. It looks like they have deleted all those templates. have you checked recently?

[shookimogh]

Different and way deeper level of trace information than what any of us are used to.  The abbreviations refer to the Food Traceability List and require you collect Key Data Elements for different Critical Tracking Events (event being receiving, shipping, any transformations of ingredients, etc).  Best source of info is here (and that's not saying much), but if you hold any ingredient on the new List of foods they issued, you're required to start participating.

FSMA Final Rule on Requirements for Additional Traceability Records for Certain Foods | FDA

 

As for @setanta, we're stuck in a spot with some of those major retailers as well.  So far it's only been some surveys as they try to get the lay of the land and figure out how they want to do it, and we're a little gunshy to start major changes in case we go down a path that doesn't support what they're going to demand from us formatting wise.  The fact retailers are hit with this traceability requirement on FTL foods means they have to put as much skin in the game as we do now, they can't just push it back to us while they do a bare minimum for tracing.

HI, one of our ingredients is on the FTL. Do we have to follow this plan only for that ingredient up until kill step or do we have to write it for all of our ingredients that are being used as a mix with the one on FTL list? to be clear, our fish is on FTL but we mix it with some other ingredients that are not on the FTL in the process. 

[jfrey123]

I think your Receiving KDE's would only apply to the fish. 

 

I'm then thinking you likely have two transformation steps on your flowchart: mixing and then cooking/kill step, and KDE's would need to be tracked at each of those steps:

• mixing the fish with other ingredients transforms the entire WIP into a FTL food (using a single FTL ingredient makes the new food an FTL food), so KDE's would be required.
• you then cook/kill step the food, so KDE's have to be documented going into this step; then once you verify the kill step was successful through your SOP the finished good is now exempt.