FDA pursues farm-to-fork food traceability ruling amid comment period extension calls
09 Nov 2020 --- A growing food organization coalition is requesting a 60-day comment period extension on the US Food and Drug Administration (FDA)’s recently proposed Food Traceability rule.
The American Herbal Products Association (AHPA) is the latest organization to join the Food and Beverage Issue Alliance-led coalition, seeking to push the extension from the original end date on January 21 to March 24, 2021.
The proposed FDA rule aims to establish additional traceability recordkeeping requirements for foods on a “Food Traceability List.” It falls under the FDA Food Safety Modernization Act (FSMA), which aims to shift the approach to foodborne illnesses from response to prevention.
“This proposal lays the foundation for a standardized approach to traceability recordkeeping, paving the way for industry to adopt, harmonize and leverage more digital traceability systems in the future,” Taryn Sjursen Webb, FDA health communications specialist, tells NutritionInsight.
From farm-to-fork, the FDA is proposing to establish additional traceability recordkeeping requirements.Sufficient time to comment?
There is a slew of obstacles ahead of organizations such as AHPA before they can comment on the ruling by the initial deadline.

“AHPA and the coalition of 19 organizations note the complexity of the rule, limitations imposed by the COVID-19 pandemic, a limited period scheduled public meetings and the presence of multiple public holidays during the current comment period,” says AHPA.
Sjursen Webb tells NutritionInsight that it had set the 120-day comment period because it felt that was “a reasonable amount of time for stakeholders to consider the proposal” based on its experience with other rulemakings.
However, the food agency is aware of requests for the comment period to be extended and is considering those requests.
“In determining the comment period, we do our best to provide our stakeholders with enough time to consider the proposal, participate in public meetings, and submit comments,” highlights Sjursen Webb.
“Meanwhile, we allow time for the FDA to consider the feedback we receive as we work to finalize the rule.”
The FDA proposes that any final rule on traceability requirements for the Food Traceability List would become effective 60 days after publication in the Federal Register.
The FSMA is shifting the focus from responding to foodborne illness to preventing it.Traceability forward
The proposed rule officially entitled “Requirements for Additional Traceability Records for Certain Foods” would implement Section 204(d) of the FSMA.
FSMA Section 204, “Enhancing Tracking and Tracing of Food and Recordkeeping,” advocates for additional recordkeeping requirements for certain foods to help establish clear tracing of a food product’s source when needed to address food safety risks.
At the core of this proposal is to require those who manufacture, process, pack or hold foods on the Food Traceability List to establish and maintain records containing key data elements associated with different “critical tracking events.”
Growing, receiving, transforming, creating and shipping count as critical tracking events across the supply chain. Items on the Food Traceability List include, for example, (fresh) herbs, (fresh-cut) fruits and vegetables, finfish, crustaceans, shell eggs and nut butter.
While the proposed requirements would only apply to those foods on the Food Traceability List, they were designed to be suitable for all FDA-regulated food products. The FDA envisions a voluntary adoption of these practices industry-wide.
To support the rule’s adoption, the FDA is also offering a number of digital tools, including webinars, a risk-ranking model and other infographics.
Wary of the pandemic’s toll on industry, the FBIA is leading an industry coalition calling for an extended comment period.A long time coming
Recognizing the importance of food traceability, the US Congress included provisions in Section 204 that intend to enhance food tracking and tracing when it enacted FSMA in 2011.
Under section 204(a) of FSMA, Congress directed the FDA to establish pilot projects in coordination with the food industry. These are to explore and evaluate methods to rapidly and effectively identify food recipients to prevent or mitigate foodborne illness outbreaks.
The projects should also address “credible threats of serious adverse health consequences or death” to humans or animals due to such food being adulterated or misbranded.
Innova Market Insights revealed “Traceability Triumphs” as its top-ranking F&B trend for 2021. The market researcher notes that six in ten global consumers are interested in learning more about where foods come from.
Additionally, the consumer lifestyle trend toward cleaner living is broadening and heightening expectations around what constitutes a clean label. Aspects include human and animal welfare, supply chain transparency, plant-powered nutrition and sustainable sourcing.
By Anni Schleicher