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Prior to her current role as vice president, supply chain strategy and insights at digital solutions company Trustwell, Julie McGill spent 16 years with GS1 US, where she helped develop traceability standards that today are enabling food value chain enterprises to better comply with the U.S. Food and Drug Administration’s (FDA) Food Traceability Rule (FSMA 204). While at the international non-profit, McGill led the Foodservice GS1 US Standards Initiative, collaborating with manufacturers, distributors, operators, and trading partners to establish a foundation for traceability and supply chain visibility.
Food Technology chatted with McGill about the impact on the food system as companies shift from one-step-forward, one-step-back track-and-trace systems to the end-to-end (E2E) traceability mindset encouraged by FDA.
Have there been any promising advances in moving the needle toward harmonization of common standards, language, and identification in terms of capturing and sharing data efficiently?
Big picture, when we talk about traceability and harmonizing standards, industry partners—whether it be at the executive level, IT, or operations—are concerned about interoperability. They have existing systems today that capture a lot of this information. They want to make sure that the tools that they put in place not only can satisfy the needs of their own company, but they’re able to talk to their trading partners. In the early days of GDSN [Global Data Synchronization Network, a standardized system that allows trading partners to share product data], where everybody was trying to figure out how are we going to share product information, data was in silos and behind walls. In advance of FSMA 204, GS1, other standard-setting groups, and food trade organizations upped their game when talking about food traceability standards, including creating common lists of attributes and protocols for sharing data, and so on.
So, we’ve had a couple of advances that are particularly impactful. You've probably heard of the Produce Traceability Initiative, it’s been around since 2008 or 2009, but it really started with foodborne illness outbreaks in produce in 2006. There was a recall that investigators thought was tomatoes, but it wound up being peppers. So, the produce industry realized they had to get a better handle on how they tracked and traced products. They came together as an industry [and] decided what standards they were going to use and how they were going to identify products so that they could do lot level tracking.
Then, as we look ahead a couple of years, the Global Dialogue on Seafood Traceability, or GDST, is a similar advance in setting or harmonizing standards in which the seafood industry came together. There are a lot of issues with seafood, including counterfeiting and sustainability, so the industry came together to come up with some shared standards. They took it one step further and put together GDST certification programs for solution providers. It really is a way to show that our solutions can exchange these different messages, and if you’re both GDST certified, see if our solutions can talk to each other.
Were you part of the seafood traceability pilot for interoperability conducted by GS1 a few years ago?
Yes, a few years ago, GS1 US, in collaboration with the GDST and the Institute of Food Technologists, led Phase 1 of a traceability interoperability pilot for seafood, which brought together solution providers FoodLogicQ (which is now part of Trustwell), IBM Food Trust, SAP, Wholechain, Insite Solutions/Norpac, and ripe.io. We came together to see if we could exchange traceability data for seafood between all our solutions. Using Electronic Product Code Information Services (EPCIS), which is the GS1 standard for sharing traceability data, we were able to do that. Phase 2 was a pilot with actual stakeholders, which included Walmart, Beaver Street Fisheries, Bumble Bee Seafoods, and Chicken of the Sea. We had data points from harvest all the way to point of sale, and each solution and each partner had a different piece of the data. Everyone captured the data and then we shared the data. The interoperability pilot showed that traceability solutions providers can talk to each other and share this standardized data, enabling stakeholders to trace that same fish back to all points across the supply chain.
I will say there are lots of folks, me included, who are encouraging the industry to do more pilots like this ahead of FSMA 204 to show that the solutions and the standards are there. Now we need to bring the two together to show industry that these solutions can be used to meet FSMA 204 compliance. Because again, FSMA 204 is not just about data capture. There's a sharing component as part of the rule as well.
How has FSMA 2024 affected the way food and beverage companies consider using tech-enabled traceability solutions?
Many of the traceability event attributes outlined by FSMA 204, especially shipping and receiving, capture 75% of the information needed for compliance: Who did I get it from? How much did I get? What is it? What date did the event happen? But the rule’s Traceability Lot Code (TLC) requirement has added a new attribute into the mix because this is information that many companies were not sharing before, specifically the TLC lot code source or source reference. And even if you were capturing that data inside your operation’s four walls, you certainly weren’t sharing that across the supply chain and your supply chain partners weren’t asking for it.
As a result, many companies are looking at what digital systems they are using today, identifying the gaps, and looking at how to integrate tech-enabled traceability solutions that complement their existing tech stacks, enabling them to share necessary data with their customers. Today, they’re trying to figure out, where do I put it in my systems? How do I share it with my customers, and how do I ensure data accuracy and security throughout all supply chains? It’s kind of like the telephone game. I have a piece of information at the beginning, but does it still look the same at the very, very end? And so, when you think about things like manual data sharing, that’s where things can break down very quickly. If folks can do this electronically, then if you start with accurate data, you should end with accurate data. That’s a big reason why there is a big push toward integrating tech-enabled traceability technologies, not only to capture the data, but to enable supply chain partners to share it.
What factors should food and beverage companies consider when selecting tech-enabled traceability solutions?
Again, companies don’t need to replace what they’re doing today. The first factor to consider is, how does any given traceability solution complement my tech stack? Can it integrate with any of my current systems? It’s common for companies to have huge amounts of data but it’s in a dozen different systems. So, you’ve got to look at interoperability of traceability systems and determine whether you can introduce solutions that can pull all this data together and aggregate it into that sortable spreadsheet.
Also, people are today collecting data from their partners, and those partners might be using portals or any number of online tools. To comply with FSMA 204, we must share this data. Now you need to consider not only ease of use, but also capture versus compliance. How you analyze for compliance and determine that supply chain partners have sent you everything you need to be compliant is going to become more important. I think a lot of people as they start this journey are very focused on capture, but you must make sure that you're keeping an eye on monitoring for compliance and auditing and so on. We recognize not everyone’s in the same place. I might be a big grocer, and my big suppliers can do application programming interfaces (APIs) and electronic data Interchanges (EDIs), but the small local guy who sells me lettuce in June and July, what does he need? Does he need a mobile app? Does he need a portal? Does he need a spreadsheet? How can I support that?
Just as customers come in different shapes and sizes, so do traceability providers. As you’re choosing a partner, make sure that the solution has the capabilities your company needs to continuously improve your systems in terms of compliance, data sharing, and even other business activities. For example, I can get data lots of different ways, but I need to validate that data against the FSMA 204 requirements. In other words, if you key it in spreadsheet, through API or EDI, or another way, the validations must be the same on my end and yours. And if I need to send it somewhere else, can that receiver receive that data and understand what they’re looking at? My advice is to look for traceability platforms built on a foundation of GS1 standards—Global Trade Item Numbers, Global Location Numbers, ISO code lists, and so on. Those are very important because when we're sharing data, a code that means something to me inside my four walls might require a decoder ring on the other side to understand what they’re looking at. That’s where standards really enable not only data sharing, but interpreting the data itself.
Finally, when looking at a solution, don’t just think about where you are today. You want a system that can not only complement what you have in place but also can grow with you as technologies and data requirements change. Because I honestly think this is the tip of the iceberg. So, when you look at a traceability system, don’t think about it solely in terms of regulatory compliance or food safety. Consider how you can use or manage data you collect to improve connected systems in the business such as inventory management, sustainability, freshness or quality, and food waste reduction. As I tell folks all the time, it’s an exciting time to be in the food industry in terms of new technologies.ft