The March toward Traceability

During a career that has spanned food safety efforts at Walt Disney World, Walmart, and most recently as deputy commissioner for food policy and response at the U.S. Food and Drug Administration (FDA), Frank Yiannas has been a longtime advocate for transparency and traceability in the food supply chain. 

An architect of the FDA’s Food Traceability Final Rule (also known as the Food Safety Modernization Act, Section 204), released in November 2022 and set to be enforced in January 2026, Yiannas is a proponent of tech-enabled traceability, a standardized, data-driven approach to recordkeeping aimed at ushering in faster, more precise recalls and outbreak investigations and curbing the impacts of foodborne illness on consumers. 

We recently caught up with Yiannas to get his take on where things stand as companies along the supply chain work toward compliance. While it may not yet be clear exactly where things are headed, Yiannas says, “the traceability train has left the station, and I don’t think it’s going to stop.” Below is an edited excerpt of the interview.  

You’ve been a champion of food safety your entire career. Why does traceability along the food supply chain continue to be so critical?

The food system is impressive but has this one Achilles heel. That, for me, has been a lack of traceability and transparency. We’ve seen this in outbreak after outbreak. You can think back to outbreaks that gave us the Food Safety Modernization Act (FSMA), which was signed into law in 2011. And even today, you see the almost daily or weekly recalls and outbreaks that are happening as we speak—Listeria in deli meats, kids poisoned with lead. So, traceability matters because it’s extremely protective to public health.

We’re fewer than 20 months away from the enforcement deadline for the food traceability rule. What’s your assessment of how companies are doing to prepare?

I talk to folks in the food industry every day, and I’ve seen more progress made on food traceability in the past year than I have in the past decade. We have a large, decentralized, and distributed food system. A lot of nodes—farmers, producers, processors, and distributors—are working to try to comply with the rule. They’re putting plans in place. [Regarding] the rule itself, people understand it and know what foods are on the Food Traceability List. They understand the important concepts, like key data elements and critical tracking events, and so we’re well on our journey. I would say that the last mile, what happens at distribution and how the traceability lot codes [descriptors that uniquely identify a batch or lot of food as it moves through the supply chain] get captured from the distribution center to point of service, is probably the hardest part of this. And so, that’s where I think you still see a little bit of concern. But by and large, we’ve gotten started and we’re making progress. Now is not the time to slow down. 

What about H.R. 7563, known as the Food Traceability Enhancement Act? What’s in the bill and what would be the practical impact of this on the traceability rule?

A few representatives in the House introduced this bill. It asks the FDA and the industry to do 12 more pilots on food traceability, and it says to the FDA that once you do these pilots, we would allow you to enforce a compliance date two years after. So, in essence, it delays the rule. Secondly, there’s language in the bill that says the FDA would not be allowed to require traceability lot codes at distribution centers and at point-of-service, grocery stores, and food service. In my view, if you don’t require traceability lot codes, you essentially gut the rule. You won’t be able to do true public health tracebacks. I can say this with confidence and authority because I was at the FDA overseeing the food outbreak and response process. When you are responsible for trying to identify the food that’s making people sick and maybe even causing harm and death, that’s a lot of responsibility on your shoulders. And anybody that’s done that knows that having a traceability lot code makes a world of difference. 

What’s your sense of the support for or against this bill and has there been any research to reflect this?

A recent Harris Poll showed that a majority of U.S. adults are opposed to efforts that would narrow the scope and delay enforcement of the traceability rule. The American consumer wants food traceability, and they want this rule in particular to go into effect. That voice needs to be heard. Also, I think many of those in industry understand that there’s a real return on investment here. When you run more transparent and traceable supply chains, you can improve operational efficiency and reduce shrink.

How can the food science community help promote greater traceability?

The food science community plays a critical role in continued modernization of the food system. I always say food security is national security. There aren’t too many topics more important than our ability to continue to modernize and make the food system the best that it can be. And I think leveraging principles of traceability and transparency, to the extent that we enable it with technology, is good for the future of food in terms of safety, efficiency, and sustainability. So, the food science community should continue to advocate for greater traceability and transparency and continue to develop standards so that our food system can work smarter together. 

What’s your vision for the future—where are we headed next?

I firmly believe that food traceability shouldn’t divide us; it should unite us. I can’t stress enough how true I think this principle is. We shouldn’t be debating food traceability. We should all be united around [the idea that] a more traceable food system is good for everyone. 

To learn more about the FDA’s traceability rule and steps to take to achieve compliance, view IFT’s commodity-specific food traceability videos; read an analysis of the rule in this IFT white paper; and hear from Blake Harris, technical director of IFT’s Global Food Traceability Center about how industry can best prepare.

An extended version of this conversation with Frank Yiannas will air this fall on IFT’s Omnivore podcast. Meantime, watch for a second installment on the Food Traceability Final Rule, featuring an industry perspective, here on our Brain Food blog.