From November 2021 through January 2022, the CDC opened two investigations concerning the foodborne illness Listeria, that contaminated leafy green produce manufactured by large scale growers (FDA). Packages of salads, leafy greens, and lettuces have been linked to the spread of Listeria across the U.S. for the past seven years, infecting 17 patients and killing two people. This kind of foodborne illness is a serious threat to producers and suppliers of produce. In an effort to prevent such foodborne illnesses from spreading, the FDA implemented the Food Safety Modernization Act (FSMA) back in January of 2011 and has recently proposed more robust food traceability protocols for the year 2022. These new requirements will apply to all areas of traceability that grow, produce, process, and package such produce.

In order to provide better traceability for produce, the FDA expects records to be maintained with Key Data Elements (KDEs) like account numbers, location of production, batch numbers, etc. In an effort to maintain visibility, the FDA also requires that KDEs are tracked with Critical Tracking Events (CDEs) through the supply chain (shipment numbers, receipts, lots etc.). The hope is that these protocols will provide a record of the produce’s lifespan, creating evidence and a clear report of each step of contamination. Providing such information is crucial in the prevention of foodborne illness. These data trackers allow for the CDC to track down produce more efficiently in cases of contamination.

Such food traceability requirements will directly affect the foods on the FDA’s Food Traceability List. Suppliers, and growers of produce such as lettuce, leafy greens, melons, tomatoes, cucumbers, and peppers will be required to provide their reports and tracking data for where these items are produced and where they ended up. If suppliers do not comply with new regulations they will be issued a warning and may be subjected to fees at the authority of the FDA. In addition, violations will be published and the FDA can suspend their facility.

These new protocols can be costly, though, and there are many factors that are going to affect how each supplier is expected to provide traceability of their produce. The FDA is allowing the public to comment on their upcoming requirements until the end of February. Factors of price, reliability, systematic implementation, and data maintaining protocols are being relayed to the FDA. This will allow them to publish regulations that maintain the integrity of supply chain security, whilst enacting higher standards for sanitation. These comments will affect the new regulations the FDA will put in place for the upcoming 2022 year for produce.

Right now, the protocol for redacting foods that have been linked to bacteria exposure or foodborne illness carriers is by finding manufacturing dates, warehouse locations, and batch numbers. When Listeria started infecting consumers, between November and January, the CDC recalled all packaged salads and leafy greens that had been packaged in specific growers’ facilities and batches. The current issue with this protocol is the lack of visibility and control for where the produce ends up. This leaves room for further spread and contamination of the virus. With new protocols, the FDA’s hopes to increase visibility in food tracing to directly identify which foods, locations, shipments and lots were involved and where these contaminated products ended up. The CDC has not had great success in tracking down produce in the past, “CDC investigated this outbreak in 2019 and 2020 but was unable to gather enough data to identify the source in the past,” (FDA Investigation). With more robust rules on food traceability going into effect in the 2022 year, the FDA is hoping to conduct more reliable investigations for contaminated produce.

Karman Eckelbarger

Karman Eckelbarger is currently an Intern at ALC Orlando, FL. Karman is currently enrolled as an English major at the University of Central Florida and hopes to graduate with a Bachelors in Fall 2022