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Food Manufacturing Q&A: Food Safety and FSMA Compliance with ReposiTrak CEO Randy Fields

At May’s Food Safety Summit, Food Manufacturing had the opportunity to speak with representatives from ReposiTrak about the company, food safety and FSMA compliance. After the show, FM was able to correspond with ReposiTrak CEO Randy Fields on those topics.

At May’s Food Safety Summit, Food Manufacturing had the opportunity to speak with representatives from ReposiTrak about the company, food safety and FSMA compliance. After the show, FM was able to correspond with ReposiTrak CEO Randy Fields on those topics. Here’s what he had to say:

Q. Why is it now more important for manufacturers to work with trading partners to ensure food safety?

A. First, with the Walmart settlement in the Jensen Farms case, everyone in the downstream supply chain is liable, even if they were not aware they were selling tainted product.  Second, the U.S. Department of Justice has now formally announced that it is partnering with FDA to bring criminal sanctions against food companies and food company employees when they sell food products that cause human illness. Third, the first compliance dates for FSMA’s Preventive Controls rules are fast approaching in September.  Lack of compliance with FSMA is considered a “prohibited act” and like Sarbanes-Oxley, senior executives will be held responsible.

Q. How can manufacturers best work with their suppliers and customers to ensure FSMA compliance?

A. FSMA is all about prevention and only documentation can prove that required plans have been written, executed and corrective actions taken where necessary.  It’s important to embrace transparency and provide documentation of compliance to downstream supply chain partners, especially if you control a hazard.  At some point, refusing to share proof of food safety practices and audits through a verified platform will cause manufacturers to lose business to those who do.

Q. What track and trace best practices are there for manufacturers? 

A. FSMA requires that companies at a minimum understand where a product coming into their facilities has been, and where it’s headed to, better known as “1 forward and 1 back”.  This is the minimum of what all supply chain product owners should know about the movement of products.  The best practice is to have the ability to trace products from the consumer and back to “dirt” to protect the supply chain from intentional adulteration or illegal sourcing.  Many of the systems on the market today rely on using bar codes or other standard product identifiers to capture product movement. However, the visibility to a product’s path is blocked if a trading partner is not utilizing those identifiers, which is a significant problem the industry is trying to deal with.

Q. What technology is available for manufacturers to help with compliance?

A. Compliance is all about document management. If it’s not documented, it didn’t happen! There are several options on the market today that say they help to automate records collection and management, so companies can toss their file cabinets and binders. There are systems with varying levels of sophistication, from an electronic storage box to systems that can review a document to confirm its contents, much like that of a human. Either way, automating the collection and management of food safety records is essential to comply with FSMA, as it mandates more record keeping for most companies than they have ever done before.  And, the FDA expects that any FSMA related document to be available within 24 hours, even for documents that are two years old.  Looking forward, technology can be leveraged to link food safety compliance with a company’s accounting and purchasing system. This linkage would ultimately eliminate risk by ensuring that POs with any supplier deemed out of compliance are immediately held.

Q. How do vendors like ReposiTrak support the compliance and track & trace process for manufacturers?

A. ReposiTrak supports manufacturers with a comprehensive platform that includes both Compliance Management and Track & Trace. Our Compliance Management System has two key differentiators that drive interest and adoption by clients.  First, ReposiTrak enables an active approach to managing required documentation by combining its technology with a dedicated in-house team.  The team follows up on outstanding compliance issues via phone calls and emails to speed results.  In fact, suppliers new to ReposiTrak reduce non-compliance by over 70% in their first six months on average.  Second, ReposiTrak replaces the need for human review by reading inside each uploaded document and compares contents vs. requirements to detect inaccuracies and/or misrepresentation.  This feature enables customers to reduce the resources needed to manage their required documentation and goes beyond competitive systems that function more like an electronic storage box.

ReposiTrak’s Track & Trace technology tracks data from existing documents, such as ASN, delivery receipts, invoices, bills of lading, etc.  It combines this data with scan label data where possible, for increased accuracy.  Relevant data such as product name, identifier, from/to locations, date of shipment, quantity shipped, used, or sold, is pulled each time a product moves to a new location, or “node” in the supply chain to provide visibility to its path.  Importantly, ReposiTrak can trace a product with or without out the use of standard product identifiers like those from GS-1.