AIM North America Comments on FDA Requirements for Additional Traceability Records for Certain Foods
02/24/2021

Dedicated to developing interoperable technical guidance and standards.

Online PR News – 24-February-2021 – Pittsburgh, PA – AIM North America (AIM NA) [https://www.aim-na.org/], the premier alliance for the automated data capture technologies industry, including barcode, RFID, IoT, NFC, and RTLS, submits comments on the FDA’s Requirements for Additional Traceability Records for Certain Foods.

These comments [https://www.aim-na.org/uploads/5/9/7/2/59729915/aim_na_submission_to_the_fda_requirements_for_additional_traceability_records_for_certain_foods.pdf] stem from the increasingly globalized, complex supply chains that have resulted in less visibility into food sourcing for customers and regulators. These trends are driving the need for digital transformation through the adoption of technology to bring automation, integrity, and data management solutions to supply chain traceability.

“Digital technology can enhance the ability to identify, respond to, and prevent food safety issues such as outbreaks,” stated Jeanne Duckett, who serves as the AIM NA Food Supply Chain work group Chair, along with her role at Avery Dennison in Transparency Initiative Development. “Given recent food incidents, the use of digital technology has become even more needed, as it can help to make full product data accessible throughout every stage of the food supply chain in the event of a recall” Duckett continued.

The proposed rule, “Requirements for Additional Traceability Records for Certain Foods” (Food Traceability Proposed Rule) [https://www.fda.gov/food/food-safety-modernization-act-fsma/fsma-proposed-rule-food-traceability?utm_medium=email&utm_source=govdelivery] is a key component of the FDA’s New Era of Smarter Food Safety Blueprint [https://www.fda.gov/food/new-era-smarter-food-safety/new-era-smarter-food-safety-blueprint] and would implement Section 204(d) of the FDA Food Safety Modernization Act (FSMA) [https://www.fda.gov/food/guidance-regulation-food-and-dietary-supplements/food-safety-modernization-act-fsma].

This is excellent step on the part of the FDA to quickly implement source traceability, trace forward and implementing targeted recalls.

AIM NA’s comments noted the following key points:

1. Leverage on the work that FDA has already done with other consensus-based standards groups such UDI and DSCSA.
2. Use Globally Unique Identifier contained in a Data Carrier (i.e., 2D Barcode, RFID, NFC, digital watermark, etc.) attached to item and captured automatically at defined points.
3. Focus on permissioned access to data throughout the supply chain to end consumers.
4. Terms –importance of aligning on definitions for commonly used terms to promote the common understanding.
5. Food Traceability List clarification
6. Clearly defining product recall.

“AIM NA and our members are committed to advancing food safety utilizing new and emerging AIDC technologies that enable end-to-end traceability for the safest possible food supply chain,” shared Debangana Mukherjee, AIM North America Chair and Director of Business Development & Sales at CISC Semiconductor.

Read our final comments [https://www.aim-na.org/uploads/5/9/7/2/59729915/aim_na_submission_to_the_fda_requirements_for_additional_traceability_records_for_certain_foods.pdf] and contact AIM NA with any questions.