Repositrak, Inc. · NYSE:TRAK
Repositrak — Starting Your New Food Traceability Journey webinar (April 2023)
20 slides from Repositrak's conference presentation, Apr 11, 2023
Slide 1: Starting Your New Food Traceability Journey
Starting Your New Food Traceability Journey April 11, 2023 REPOSITRAK.COM | ACHESONGROUP.COM
Slide 2: Today’s speakers
Today’s speakers Ben Miller, Ph.D., MPH Vice President of Scientific and Regulatory Affairs The Acheson Group (TAG) ▪ Epidemiologist and Foodborne Outbreak Investigation ▪ Led State of MN Human and Animal Food Regulatory Programs ▪ Served on the FDA’s IFT Task Order 6 - Pilot Projects for Improving
Slide 3: Today’s Webinar
Today’s Webinar • Section 204 – “Traceability Rule” Overview • Questions we’re getting about “The Rule” • Q&A from you 3
Slide 4: How is the new traceability rule different than the 2002 Bioterrorism Rule?
How is the new traceability rule different than the 2002 Bioterrorism Rule? One Forward – One Back Case-Level Traceability
Slide 5: What foods are covered by the new traceability rule?
What foods are covered by the new traceability rule? https://cfsanappsexternal.fda.gov/scripts/FDARiskRankingModelforFoodTracingfinalrule/
Slide 6: What foods are covered by the new traceability rule?
What foods are covered by the new traceability rule? https://www.fda.gov/food/food-safety- modernization-act-fsma/food- traceability-list
Slide 7: What foods are covered by the new traceability rule?
What foods are covered by the new traceability rule?
Slide 8: What foods are covered by the new traceability rule?
What foods are covered by the new traceability rule?
Slide 9: Who is covered by the traceability rule?
Who is covered by the traceability rule? 9
Slide 10: How do I know what KDEs I need to create?
How do I know what KDEs I need to create?
Slide 11: Can’t we just maintain the records rather than send the KDEs to customers?
Can’t we just maintain the records rather than send the KDEs to our customers, and provide them when and/if they need them? • The traceability rule isn’t just an expansion of the 2002 Bioterrorism Rule (one up and one back) • During an investigation need to provide records to FDA in 24 hours • If re
Slide 12: What if I have a kill step in my processing?
• Must maintain records of kill step. No records What if I have a need to be maintained from shipment forward kill step in my • For FTL foods prior to the kill step, records processing; do I must be maintained or have written need to track the agreements stating that a kill step will be FTL products
Slide 13: Can I create a new lot code when I send product to my customer?
• Traceability Lot Codes (TLCs) can only be created for specific CTEs: • Initially pack a raw agricultural commodity other Can I create a new lot than a food obtained from a fishing vessel code when I send • Perform the first land-based receiving of a food obtained from a fishing vessel product to m
Slide 14: Does this rule apply to products grown/produced outside the US?
Does this rule apply to products grown/produced outside the US? • Yes! – but recordkeeping does not apply to those who don’t “physically hold” a FTL food (importer, broker, etc.) • Broker or importer can be designated to maintain records • “Covered entity” needs to ensure that designee is meeting re
Slide 15: As a distributor, do I need to track case-level shipments?
• Yes, for FTL Foods! As a distributor, do I need to track case- level shipments to my retail and restaurant customers?
Slide 16: As a retailer or restaurant, what KDEs do I need to track?
As a retailer or restaurant, what KDEs do I need to track in general, and at the case-level?
Slide 17: What if I don’t have a system to generate the KDEs today?
What if I don’t have a system to generate the KDEs today? Lin, X., Ruess, P. J., Marston, L., & Konar, M. (2019). Food flows between counties in the United States. Environmental Research Letters, 14(8), 084011.
Slide 18: How does the rule apply to you?
How does the rule apply to you? • TAG is providing an assessment to help you determine what CTEs and KDEs apply to you • Zoom call and initial written assessment • $500 • Email “Traceability Rule Assessment”: info@achesongroup.com
Slide 19: Get FSMA 204 Compliant with ReposiTrak
Get FSMA 204 Compliant with ReposiTrak • FSMA 204 brings substantial new requirements and challenges • This is not one forward – one back traceability…this requires data sharing with your customers/stores • Your current systems do not support sharing KDEs and storing them for easy retrieval • The Re
Slide 20: Ben Miller, Ph.D., MPH / Derek Hannum
Ben Miller, Ph.D., MPH Derek Hannum VP of Scientific and Regulatory Chief Customer Officer Affairs DHannum@repositrak.com Ben.Miller@AchesonGroup.com 435-645-2230 507-703-1885 REPOSITRAK.COM | ACHESONGROUP.COM
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