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Complying With the Food Safety Modernization Act

RFID can help U.S. produce farmers cost-effectively meet the FDA's mandate.
By Michael McCartney
Oct 30, 2016

Sept. 19 marked the first implementation date of the U.S. Food and Drug Administration's Food Safety Modernization Act (FSMA), designed to regulate national and international foods to prevent or minimize food-borne illnesses. Now, large U.S. produce farmers are required to document the location and condition of perishables, and all steps from harvesting to processing and transporting.

While U.S. farmers have been aware of FSMA for several years, most have not begun to automate processes to make compliance easier. Many still rely on manual paper-driven processes, which are labor-intensive and error-prone and don't provide visibility into product movement. Instead, growers have hired more people to comply with the mandate. This is an outdated and costly approach. With minimum wage expected to increase during the next three years to $15 an hour, growers will need to automate to control labor costs. That's particularly true in California, where beginning in January 2017 farm laborers will be paid overtime after 40 hours.

The FDA is focused on food safety and not how companies comply with the FSMA rules. I believe a passive RFID track-and-trace solution could help farmers meet FSMA compliance and address their business issues. A passive RFID tag could be placed on field bins at the first point in the harvest process and read with a handheld device to document date, time and location of products. The tag could then be used to track and document movement of perishables until they are passed on to the next participant in the supply chain.

RFID read distances and accuracy are no longer challenges and what remains is the cost issue. An RFID label costs five cents while a bar code or QR label is typically less than two cents each when purchased in comparable quantities. But if farmers do an economic analysis that takes all costs into consideration—including labor, training, cost of errors and time to correct those errors, recall expenses and brand tarnishing—they will find that it's cost-effective to invest in an RFID solution.

In addition, a farmer could use the RFID solution to achieve internal benefits. Recently, for example, Jim Gross, an account manager at Cool Pak, implemented an RFID solution for a tree fruit grower to track field bins in and out of a processing plant. The grower's IT department, he says, began using it to monitor product quality. The solution, he adds, improved inventory accuracy, saved labor and will provide valuable data to identify specific times to add labor and new equipment.

If a food-safety incident were to occur, the ability of all participants in the supply chain to track the perishables' history immediately could minimize health issues. And rather than recall a hundred thousand boxes from a 10-acre parcel, for example, the farmer could isolate the affected consumer unit. That could save a grower's company and its brand reputation.

Michael McCartney is managing principal at QLM Consulting, which specializes in automated food safety and traceability systems.

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USER COMMENTS

Patrick Malley 2016-10-30 09:24:57 PM
Michael, fantastic article. I agree with you that there is a huge opportunity to move forward from pen & paper/barcode based systems in horticulture. I have developed a product called Binwise that ticks all of the boxes that you have indicated in your article, plus a few more, and I would be happy to discuss it with you further. Check out www.dataphyll.com Regards, Patrick

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