Building Food Traceability for FSMA 204 Compliance

[00:00:00] I've watched people open a bag of salad kits and not wash the lettuce and I'm going, ah, would I still wash the lettuce? I mean, that's just me and that's not a knock on anyone that works within prepared salads. I think they definitely do a great job. I just am a little bit extra like that.

[00:00:18] Hello and welcome to the Next Level Supply Chain with GS1 US, a podcast in which we explore the mind-bending world of global supply chains, covering topics such as automation, innovation, unique identity, and more. I'm your co-host, Reed. And I'm Liz. And welcome to the show.

[00:00:36] Reed and I just had a conversation with Christina Herrick at The Packer, and we covered a whole bunch of topics. Traceability and FSMA 204 are top of mind because of the produce industry being very much impacted by FSMA 204.

[00:00:53] One of the key highlights for me is when she said compliance is not a light switch and organizations need to get started when thinking about FSMA and what they need to do and talking to trading partners about working towards compliance in 2028. She also mentioned the complexity of produce and every commodity is a little bit different in the process. And many organizations only have one person that wears a lot of different hats.

[00:01:22] And so thinking about traceability is going to be a little bit more challenging for them. Enjoy. Hey, Christina, welcome to the show. Yeah, thanks for having me. This is kind of role reversal for me. So I've already apologized once before we hit record that I might try to drive the bus. So I'm going to try not to do that today. No, no, we're delighted to have you. And we're looking forward to this conversation.

[00:01:46] But before we jump into everything, if you wouldn't mind, just for our audience, if you could just introduce yourself, give a little bit about your background, where you're working today. My name is Christina Herrick, and hopefully everyone kind of already knows that getting into this episode. But I'm the produce editor for The Packer. I've been with The Packer since 2023, covering the fresh produce industry, although I focus a lot on food safety, which is part of the reason we're talking today. But I do ag labor, economics.

[00:02:16] And I also previously, to working at The Packer, wrote for American Fruit Grower. I'm a grower-focused publication on specialty crops. So a little bit of a background. I wasn't a newbie when I joined The Packer. Awesome. It's always Christina and I run into each other at shows, and we've been talking about doing this for a while. So we're really excited that you're here and to talk about it.

[00:02:39] Jumping into kind of the guts of the conversation, one of the things that I know goes on is consumers think about food and produce and traceability, and then there's kind of what actually happens in the supply chain. And I was wondering if you could give your perspective on some of the disconnects there from what we see when we go to the grocery store to actually what the supply chain looks like from a produce perspective. Yeah. Well, it's funny.

[00:03:07] When you started asking that question, I immediately thought about the consumer, and I'm thinking, you know, I'll use my parents as a base. I mean, not that that's what everyone should. But, you know, I don't think they have any clue what goes into food safety. You know, consumers, I think, have no idea. I definitely think, you know, as we look into the food chain, you know, I don't necessarily think, you know, everyone knows what all goes into it. You know, I don't necessarily think maybe the retailer understands exactly what the grower has to do.

[00:03:36] You know, I don't necessarily think the grower may think about what goes on when they get that produce to a distributor. So I guess to answer your question, from my perspective, I think there's still a lot of disconnect on what's done and maybe the influence that those particular steps might have on that final outcome to the consumer. That's at least my thought, you know. Yeah, I think we all take for granted food safety.

[00:04:02] Like, we're busy, I go to the grocery store, expiration date, good to go, move it on from there. And really don't give it too much of a thought. Yeah. Yeah, I think that's very true. And, you know, I guess that maybe that's a compliment to where things are with the food safety industry in that, you know, we as consumers might take that for granted. I mean, I've watched people open a bagged salad kit and not wash the lettuce.

[00:04:30] And I'm going, ah, but I still wash the lettuce. I mean, that's just me. And that's not a knock on anyone that works within prepared salads. I think they definitely do a great job. I just am a little bit extra like that. Yeah, I'm definitely guilty of opening the bag and just putting it in the bowl and starting to mix it. And my wife's like, what are you doing? What are you doing? Putting it in the salad spreader thing where we're pumping the... The spinner. Yeah, I forgot it. I had a spinner.

[00:05:00] Yeah. Well, we talk about traceability quite a bit. And there's traceability in fresh produce space specifically. I would like to know, how is that different from the other parts of the food industry? And is there a significant difference from fresh produce to the canned foods, bagged foods? Well, I'll say, you know, do a shameless plug for being a GS1 event to kind of understand the bigger picture.

[00:05:30] Because to be honest with you, I didn't realize just how different fresh produce was coming from this side of it. And granted, you know, when I gave my background, I worked on the grower side. So, you know, we were so focused on production and things like that that I didn't necessarily think about all of the food safety. Food packing houses were a part of it. But that was really kind of where the box stopped in my previous role.

[00:05:53] So, thinking about it now, you know, I mean, I hear about where, you know, there's certain data elements that are reused, right? There's some lock codes and things like that that might be used or applied broadly. Things like that that I think, you know, where you're talking about maybe a CPG, something packaged that might have a barcode where things are a little bit more detailed.

[00:06:16] I've heard a lot of that when I do stories is that, you know, there's obviously that's why FISMA 204 is in place to kind of bring some of that information into a place where it's shareable. But, yeah, in my mind, traceability is still kind of not there yet in terms of being able to share data, trace data, truly, things like that.

[00:06:39] You know, you can see some of the outbreaks where, you know, the FDA is saying it might be this or that, but it's not fully traced down to a lot code, right? Right. And produce is so, it's different. I mean, fresh food, right? But it's different than CPG because it has such a short shelf life. And when you have a traceback or an outbreak, which ends up in a traceback, that product may not be on the shelf anymore.

[00:07:06] And so, being able to very quickly get that information is so important where a box of cereal or soup or whatever in the center of the store is just different. It's not going to move as quickly throughout that supply chain. Yeah. And I guess the other part of it, too, you know, I was thinking, as you, Liz, you said, you know, might not, might not be on the shelf. I'm just also thinking it might not even be grown in that same field. I mean, some fields, yes, you know, they extend and seasons extend.

[00:07:33] But sometimes, you know, if you're getting in between seasons or change of seasons, that produce might not be grown in that field anymore to be able to test. Yeah, that's such a such a good point. Very scary. Yeah. And as a general consumer walks into the grocery store, you have your tomatoes that are sitting out that you pick and put in a plastic bag and you weigh or whatever.

[00:07:57] Then you have your tomatoes that are in a bin, whether it's a plastic or it's a bag and there has a barcode on it. And now you're maybe you're not me, but I'm just going to give my story. I grab that stack of bananas and I go to self-checkout and it's like I type in bananas organic, regular list. There's like four bananas to pick from. And I'm like, I don't know really which one there is. And then there's that little number on the banana.

[00:08:27] It's like, you know, a little sticker with the nine seas. So where are we going with all of this? Well, I mean, ideally, it's it's that conversation we just had that Liz mentioned. You know, if there is a need for some kind of recall, you're able to trace it back. You know, all of the steps that took from the moment it was picked all the way to the point it hit the grocery store and to be able to trace it back to that farm. Maybe that day, whatever.

[00:08:55] I mean, I think, you know, the more you write about food safety, I don't know about you and maybe you're kind of blissfully unaware. I feel like the more I learn about food safety, the more scared I get. And that's, again, not enough on the fresh pregnancy industry. I feel like they're doing a great job. But I also feel like there's just a lot of variables that just kind of happen along the way that can really change something and really influence something. So it is an interesting thing. The more, you know, isn't always necessarily the best thing. Yeah.

[00:09:25] Inurance is definitely bliss. But I would like to go back to your original comment, which is we take it for granted because it is working so well. And I truly believe that the FISMA 204, a lot of perspectives on it. It's definitely a change. It's definitely work. But it's just going to make everything so much better, even for the growers and the distributors. And the retailers.

[00:09:53] Everyone will benefit from it. But just like anything else, changes can be a little bit of a pain in the butt. What I think part of the problem is, right, that the industry, it's taken so long to get to this point. There hasn't been a whole lot of modernization along the way. And I think that's kind of why this is, it hurts in many ways for implementation.

[00:10:15] Just because, you know, it's been kind of piecemeal and kind of cobbled along for so long that the industry is so big now that it's going to take a lot more to actually get it in place and get it moving. Yeah. People actually have to thoughtfully think through what needs to be done and then put a plan together because 2028 is not as far away, I think, as people think. But it is possible.

[00:10:41] And there are so many people and organizations out there that can help with best practices, what works, what doesn't work, and just things to think about to get started. But, Reid, to your bananas, the PLU code is 401 for bananas. Thank you. I mean, you know. I was actually going to say that. I was going to say, Reid, if you're scared of bananas for PLUs, good luck buying bulk apples. Yeah. Or knowing what kind.

[00:11:08] I want to shift gears a little bit because there's so much going on. And I know you have, you talked about the other pieces of your role other than food safety. I would love to ask about labor, the costs and the tariffs and trades and regulations like EPR and how all of those together are affecting traceability. Or are they?

[00:11:35] Like, are they related because there's so much going on with these other things? Does it take those resources away? How do you see that playing out? I think in many ways, EPRs are still a little new to the point that I don't necessarily know that the fresh produce industry realizes its full impact. You know, with California finally coming online and regulations coming, I think it's going to hit later. Like, that's almost a slow burn for our conversation today.

[00:12:02] I think those impacts are going to hit soon and producers and growers are going to start to realize what's going on. But I still think that one's almost too new. Labor is definitely a huge issue. We're talking today on the day that Agriculture Committee Chairman just debuted a new labor regulation that's going to hopefully change the way the H-2A labor works in this country for the benefit. But, you know, that obviously has to get passed.

[00:12:31] But, you know, I've worked on a huge economic series, kind of breaking down some of the challenges because labor is obviously a huge cost to growers. You know, sometimes it depends on the commodity. But, for example, you know, I've talked to the folks in Washington State and growers there are basically, I think it's 110% of their gross returns went to labor. So they're not even being able to pay for anything else. That's inputs. That's fertilizer. That's anything else.

[00:13:00] Not only themselves. So they're not even able to pay for that. So where I think that hits kind of rubber meets the road with traceability is, you know, if you're a grower packer and you're getting almost nothing for your produce, are you able to make those investments in traceability? Yeah. You have to. I mean, right? We're talking, we know FISMA 204 is coming. And, you know, hopefully it doesn't get delayed again. But we know that that deadline is coming.

[00:13:29] And so compliance is not necessarily a light switch that you can turn on. It's something you've got to work on and integrate. But, you know, does that mean that that could impact the cost and the affordability of implementing those programs? Maybe. I mean, I don't necessarily see it as an option. Like, that's not an option for them. So, yeah, there's that. Trade tariffs have been kind of all over the place in terms of, you know, where things are.

[00:13:58] You know, to me, labor is kind of the number one. Obviously, tariffs and trade are a challenge. I also think regulations is another one. Again, that goes to EPRs. That goes to some other things that are kind of in the same sphere as labor. There's some regulations that are pretty onerous for certain growers of commodities. But, yeah, it's definitely not an easy time to be a produce grower. So, you know, growers are pretty resilient.

[00:14:22] That's the one thing that I've learned as I've talked to, you know, growers over the X number of years is they're able to face challenges. But, you know, it's a little bit of predictability that's important to them. You know, when things are kind of all over the place, that makes it very tough to factor in any changes like, you know, integrating traceability. But, you know, if there's stability, they're able to kind of plan for, adapt, and move forward.

[00:14:49] Yeah, I would love to double click into this traceability aspect of it. We covered, you know, tariffs and regulations and all of this. And, you know, we know it's coming. There was a push out, right? It was supposed to be here. Was it this year? Yeah, January. January, right? So there was a push out, which is good. From what we're hearing is that there's not going to be another push out. It's coming. We're, you know, 2028.

[00:15:18] What do you see, you know, like with companies, it's still all pretty new, but how are companies approaching this? And are you seeing areas where there's this is the big struggle or this is the big roadblock? Are you seeing any trends in it? And how are they approaching it? I don't know if this is a trend. A lot of what I get the sense of is a lot of companies just don't know where to begin. There's, you know, there's obviously guidance from the FDA.

[00:15:47] But I think in some ways, the sense I get is it's almost too broad to the point that, you know, a lot of companies just don't know where to begin. And obviously, there's a lot of solutions out there that can help with compliance. But I almost think they just I hate to say it's like that decision fatigue or that it's like you just don't know where to start. So you don't start.

[00:16:07] I also kind of wonder, too, with companies that import into the U.S., I often wonder whether or not there's a lot of awareness on what needs to be done there as well. And maybe there's some, what is it, cognizant dissidents or, you know, maybe not wanting to know.

[00:16:26] But I do think, you know, there's a lot of not sure where to start, not sure, you know, how to share and just kind of maybe kind of pretending like it'll go away. Put their head in the sand. Yeah, there might be a little bit of ostrich, ostrich head in the sand going on. Fair enough. It's a big deal. It's a big deal.

[00:16:48] And one of the questions that I was going to follow up with was it feels like there is an awareness gap. And you talk to the bigger organizations and they're certainly aware that FISMA is coming, whether they then put their head in the sand or not. That's a different conversation.

[00:17:07] But the smaller grower packers, the terminal markets, like I just feel like when you get a layer down into the size of company, there may be an awareness. And I would love to hear your perspective around that. And is there a way we can all kind of help them become aware and start this journey? Because, I mean, it's coming.

[00:17:33] Like Reid said, we think that we from what we understand, 2028 is it. And it's not like you said, and I wrote it down. This is not just turning the light switch on. This is a thoughtful process of collecting and sharing data. You know, I often interviewed a few folks in their FISMA 204 journey. And one lady I talked, her commodity is not necessarily what falls under FISMA, but they are getting prepared.

[00:18:02] But she wears multiple hats. So sometimes with those larger operations, it's very easy. They've got someone that's at least one person that's head of food safety, head of compliance, right? There is someone there that's in charge of figuring this out. A lot of times on the smaller ones, it's a grower that might be doing this too. It might be the owner, might be somebody that does payroll, you know, it's somebody else wearing a different hat. Like this lady, she also does sales. So she does sales and food safety. And I'm like, how do you do that?

[00:18:30] You know, how do you wear two hats and do two full-time jobs well? And I think there might be a little bit of that. You know, I've been kicking around an idea of doing kind of a series of getting ready, like the road to 2028, something like that. Just because I feel like the industry needs to do a good job of talking about this. And sometimes, you know, we say FISMA 204. I don't necessarily, you know, I don't know how many folks actually understand that that means me. I am a grower.

[00:18:59] I am a distributor. Yes, 100%. I love, Christina, I love your idea of like, let's put a series together and break it down. And take it in a couple of different scenarios. My father had a small, durable medical equipment, you know, provided wheelchairs, beds, commodes, respirators, all this stuff. But in order to service hospice and to collect on Medicare, you had to have federal inspections.

[00:19:29] And so he did the sales. He did the deliveries. He did the pickups. He did the maintenance. And he did the compliance. And when he was getting ready to retire, which he never did, he just retired eternally from the job, from the life, from everything. But I was helping him out in different areas. And I'm like, how do you do this? And it was, you know, a small business. There was five total employees. And you're trying to do that.

[00:19:56] And I see that with, yes, some of these farms, we all know the companies, they own millions of acres. I'm exaggerating here a bit. But and then there's farms that own, hey, we got 100 acres and this is what we do. And we provide for this group and they sell it at this grocery store. They all have to be compliant. Yeah. I think the other big challenge is that every commodity is a little different.

[00:20:21] And even within that, the way growers grow and the way things are done is slightly different. I mean, that was always kind of the big challenge for me is almost accepting that no one does everything exactly the same. That might be similar, but it's not exactly the same. And so I think that also probably adds a layer of complexity here is that, you know, none of these businesses were created, you know, with the intention of traceability.

[00:20:47] You know, things have been added either over time or things have changed over time. You add a new packing link, whatever it might be. Things just kind of update as we go. And it's not necessarily designed with the flow and ease of sharing data. And so I think that's really the challenge, too, is that everyone's a little different.

[00:21:07] So, like, you know, I'm thinking, like, as a solutions provider, how on earth do I provide a solution when this company is doing things slightly different from this company and this and that? And then all of the different retailers that might have different expectations and needs. And I'm not necessarily just talking about traceability here, but I'm talking about all of the other compliance that might have to be done to meet a retailer. You know, to me, it's all maddening.

[00:21:30] I am impressed that produce businesses do what they do and are sharing the data that they are right now. Yeah. Yeah. I read. I take it from, like, a marketing perspective of how to inform because you're selling a new idea. And it just takes me back to that old little cartoon of the guys pulling a sled and the guys standing next to them with the wheel like, hey, guys, want to help it? We're way too busy to talk to you. Right? Right.

[00:21:58] It's kind of the scenario that we're in, but we're going to have to leverage the psychology of understanding who you're talking to. What's most important to the farmer versus what's most important to the distributor or the packaging or the cooler? They all have a different sliver of perspective. Yeah. Yeah. I mean, maybe for some it's going to be cost, right?

[00:22:20] If you can lean into this, you're going to reduce food waste by being more compliant and being able to initiate a trace back quickly and pull only the product that needs to be pulled off. You know, it might be time. You know, and it also just might be pressure from those retailers. I mean, I know that there are expectations coming already ahead of the actual regulation. So I think everyone has a little bit of a different motivation, as you said, Reid.

[00:22:48] So we've just got to figure out what those carrots are on the stick to get things moving. No doubt. No doubt. Liz, did you have something else there that you were looking at? I felt like I could go. I'm just going to talk about, you were talking, Christina, about the different ways that everybody's asking for stuff. And I just thought it was a great plug for GS1 standards. That's all. I mean, it just like, it was like a softball and I was, I tried to, and I missed. So it's fine.

[00:23:15] I mean, I have heard a lot of folks refer to GS1 as kind of the standard for traceability and compliance. And I recognize, you know, that the FDA, as they're pulling together their information, they can't just, you know, say only use GS1 because it's a little biased for an agency. But, you know, you do see a lot of alignment.

[00:23:39] You do see a lot of recognition with what GS1 provides in terms of data sharing and ability and QBs. So it is interesting to see that kind of being recognized. Yeah, there's no doubt. I go back to my old life of being in IT. And I started before Internet Protocol even existed. So if you had a Banyan Vines network, you couldn't talk to a token ring network and you couldn't talk to a Novell network. But IP comes out as a standard and they can all talk together.

[00:24:09] And that's really what we're getting at here is using a common language syntax that you know what you're receiving and you know what you're sending just makes it more ubiquitous for everyone. It's as simple as the address forms for, you know, the U.S. Postal Service globally. Right. It's not just in the U.S. Okay. We always end with two questions. All right.

[00:24:34] So what we would like to know, just closing this out, I'll go with the first question is. Either in your personal life or in your professional life, what is your favorite technology that you're leveraging right now? Well, honestly, it's pretty simple and stupid. I mean, I could say AI, but honestly, I love AirDrop. I have a Mac computer. I have an iPhone. Having AirDrop is a game changer for sharing files, adding stuff in.

[00:25:04] I mean, I can't tell you how much I use both. I mean, yes, I could go. Like I said, I could talk about AI. But honestly, AirDrop to me is like a piece of innovation that I absolutely love. I love it. I'm glad that Apple brought back the Palm Pilot feature where you just put the two ends of the phones together and the contact information goes. Yes. Again, dating myself, Liz. Go ahead. Listen, I've been there. Okay. Last question.

[00:25:30] What is something new professionally or in your personal life that you would like to learn about in the near future? Ooh, I think a new language. Despite some of my presence at some of the Packer and the Packer events, I'm not fluent in Spanish, but I'd actually like to learn another language as well. You know, maybe self-serving Japanese because I might have a trip to Japan next year. Fingers crossed. But yeah, I think learning another language is really important if I can't become fluent in Spanish.

[00:26:01] Wow. I love that. That's fantastic. Well, listen, thank you so much for being with us today. Greatly appreciated it. And yeah, very sincerely, we hope that people all check out your podcast after listening to this one. Yeah. I hope so too. But thank you for having me on this. This is, it wasn't hard to treat positions and not be the host. Thank you for joining the Next Level Supply Chain with GS1US.

[00:26:27] If you enjoyed today's show, you can subscribe to our feed or explore more great episodes wherever you get your podcasts. Don't forget to share and follow us on social media. Thanks again, and we'll see you next time.