ECSGA <strong>Newsletter</strong> Page 12 Issue 2 <strong>June</strong> <strong>2024</strong>
—Continued from page 10 Traceability final rule 3 published in the Federal Register, or better yet, search for more digestible summaries on the web. The rules are extensive, and at first glance they appear quite daunting. In reality, almost all of the larger operations are already doing most of what is specified. Everyone in the value chain will be required to record Critical Tracking Events (CTEs), and Key Data Elements (KDEs). CTEs include steps such as harvesting, packing, shipping, product transformation, comingling and repackaging. Each CTE has one or more KDEs that must be recorded, such as lot code, location, date, temperature, and records like invoices and bills of lading. One of the new requirements that many will have to get used to is that the “first landbased receiver” must establish a “lot code” that will identify the product source, description and harvest date, and will follow the product from the first dealer to the end user. Adam reiterated that shellfish regulated under the NSSP are exempt from the rule, but he acknowledged that many buyers will start to require lot codes and scannable tags to facilitate their receiving and inventory management. Once they have to implement the Rule for other foods, they will probably want to do it across the board. The rest of the seminar featured presentations from a variety of software and hardware purveyors. We heard from BlueTrace, Trace Register, Innova, Wholechain and HeavyConnect. Each firm has its own pricing scheme. For example, while Trace Register charges a fee based on the weight of the product you ship, BlueTrace charges growers a flat fee for printers and tags, but has a different pricing structure for dealers who need scanners and inventory management features. Many companies using these software solutions use smartphones for scanning and data entry. Athough some seafood buyers require that sellers use specific software (with proprietary tagging and coding), there is a lot of pressure across the industry for interoperability, so that each system can understand other systems’ tags and codes. Most of these programs are integrated with billing, and may help in the recovery of lost product. Benefits I think that growers could also see benefits from traceability requirements. The FSMA Rule requires the first receiver to establish a lot code, but for growers who are also dealers, it makes sense for them to take care of this step. QR codes on the tags will allow the grower to convey to the customer the story about how the product was produced. —Continued on page 17 ECSGA <strong>Newsletter</strong> Issue 2 <strong>June</strong> <strong>2024</strong> Page 13