EXCLUSIVE: How Traceability Shortcuts Can Prove Costly to Food Safety

Progressive Grocer talks to expert Frank Yiannas about the intersection of FSMA rules and technology
Lynn Petrak, Progressive Grocer
Frank Yiannas
Former FDA Deputy Commissioner Frank Yiannas serves as an advisor to IoT tech company Wiliot.

As the 2026 compliance date for the traceability rule that is part of the Food Safety and Modernization Act (FSMA) gets closer, one of the architects of the rule is cautioning against possible shortcuts that could ultimately undercut food safety. Frank Yiannas, former Deputy Commissioner of Food Policy and Response at the U.S. Food and Drug Administration (FDA) and a strategic advisor to ambient IoT tech company Wiliot, recently spoke with Progressive Grocer about traceability data collection points, including the pivotal areas of shipping and receiving, and how technologies like IoT tags can close gaps and prevent risky shortcuts. Steve Statler, chief marketing officer at Wiliot, also weighed in on implications and opportunities. 

[RELATED: Verifying Receipt for Food Traceability]

Progressive Grocer: Stakeholders in the food chain have invested so much in food safety over the past few decades – why are there lingering issues in traceability and how does Rule 204 of FSMA address that?

Frank Yiannas: We still see some issues today in food safety – especially with not being able to track and trace food. There was a recent cantaloupe outbreak that caused 15 deaths in the U.S. and Canada and it took our nation over 30 days to execute the recalls of where potentially contaminated cantaloupes were shipped to. I can tell you with authority that the consumer expects more.

In November 2022, FDA issued the final food traceability rule. We are more than a third of the way to the compliance date, and a lot of companies have stepped up and are doing good work. Kroger, for example, sent letters to suppliers saying, ‘This is what we expect. We want traceability all foods that we receive and we want to you comply by July of 2025.’ But there are still some people who have their head in the sand and there are some pockets of resistance and friction. I think the resistance is unnecessary and unhelpful.

Steve Statler: When Kroger put their guidance to the vendors and said, ‘We will go beyond the foods on the food traceability list and we want you to start having the traceability lot codes in advance of the deadline,’ that set the bar for the industry. 

Digital passport
New technologies enable companies to comply with FSMA traceability requirements in an automated, labor-efficient way.

PG: What are ways to remove some of that friction?

FY: As we see people developing their compliance plans, we applaud how many of them are trying to comply by leveraging GS1 standards. People who are trying to comply by using GS1 standards will find compliance with the food traceability rule to be much easier. 

Also, people are very creative and in a decentralized food system, they are figuring out how to comply in different ways, including high-labor, low-tech and no-labor, high-tech models of compliance. You could do it with paper records, but now in 2024, you see people leveraging some technology. There is simple printing and scanning of 1D and 2D barcodes, which still requires some labor. 

One of the reasons I decided to work with Wiliot is they have a next-generation emerging technology that is an evolution of RFID. The Wiliot Pixels offer a different wavelength than RFIDs and can be read with devices that are all around us for a fraction of the cost. It’s a low to no-labor, high-tech solution.

SS: This platform is Bluetooth – it’s like apps in your phone. You can have different apps running, and food safety is one of them.

Food safety is the catalyst, and giving customers information about the food they are eating is another thing. This provides assistance to those staffing the store, to help with more accurate information.

PG: Let’s talk about one area of concern: The possible circumvention of the traceability rule through the use of Advanced Shipping Notices that notify deliveries sent from shippers to receivers. Why is this a potential problem?

FY: ASNs are a good thing – if you are running large warehouses, it’s good to know what’s coming in so you can plan your day. But while ASNs play a certain role in the rule, they are not sufficient for verification of receiving. Even some of the largest retailers and food companies in the world are not 100% accurate. If mistakes happen in food safety, that can result in illnesses.

Everyone wants to simplify and are trying to confirm what foods are truly received, but doing it with ASNs alone does not comply with a receiving event and if we do that, we could be passing bad information along the food chain.

PG: The stakes are high for bad information.

FY: I was talking to a large company this week about the cost of compliance, and I said, ‘The cost of compliance is a lot cheaper than the cost of an outbreak.’ 

Rather than using shortcuts, there is a way to use automation in the collection of data that let people do something that’s safe and meets the letter and the spirit of the law, and also have more accurate supply chains. 

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