How Indoor Farms Can Prepare for FDA’s Food Traceability Rule

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In November 2022, the U.S. Food and Drug Administration (FDA) released their Food Traceability Final Rule. In it, the FDA makes clear all additional traceability recordkeeping requirements for food manufacturers, processers, packers that deal with high-risk foods, as per their Food Traceability List.

In summary, all of the companies above are given until January 2026 to develop and maintain records containing key data elements that are connected to the different “Critical Tracking Events” (namely: (1) harvesting, (2) cooling (before initial packing), (3) initial packing, (4) first land-based receiver, (5) shipping, (6) receiving, and (7) transformation).  

The FDA’s goal is to ensure that they are able to quickly identify and then remove potentially contaminated food in an effort to combat and lower foodborne illnesses and deaths.

Why Is The FDA’s USDA Traceability Final Rule Relevant to Indoor Farms?
In the summer of 2021, one of the largest indoor farms in the United States, BrightFarms, became the source of a Salmonella outbreak, affecting 31 people in four states. Ultimately, it signaled to the agriculture industry that perhaps indoor-grown greens could also be vulnerable to contamination. Following the FDA’s investigation, Brightfarms recalled their salad greens and made it clear that their focus would be on strengthening their food safety and quality.

If we look at the FDA’s Food Traceability List, pictured below, we can see that most crops grown by indoor farms are part of this rule.

 
Source: Food Traceability List

What should be highlighted based on BrightFarms’ experience are two things that the FDA noted:

1. The facility for storing hydroponic growth material (used as nutrients, plant stabilizers, etc) was outdoors rather than in a controlled environment such as a shed, leaving it susceptible to bird droppings and animal intrusion.
2. The farm did not adequately document “that cleaning and sanitizing of equipment, tools and buildings used in growing operations is routinely conducted in accordance with the firm’s procedures.”

Now, combining what we’ve learnt from BrightFarms (including how they improved their food safety standards afterwards) with the FDA’s detailed list, which will now affect food safety standards over the next few years, these are our thoughts:

1. It is important to be certain of what goes into your suite of agriculture input products. Most times, companies try to be as transparent as possible about the elements that are used to produce their inputs.
   
   However, we have also seen a rise of manufacturers who aren’t quite as transparent as they need to be. This puts indoor farms at risk, especially when their products are now going to be under more serious scrutiny through the documentation process that the FDA is applying for all of the indoor farms’ buyers such as food processors, distributors, markets, etc.
   
   
2. There has been feedback that the FDA’s rule process will burden the supply chain, particularly smaller players. In fact, The National Grocers Association (NGA) submitted comments to the FDA, such as the following: “Smaller retailers will be disproportionately impacted by this final rule, as it will be expensive to implement and require additional labor that many stores cannot spare”. Knowing this, indoor farms who are supplying to smaller players should prepare themselves as well by ensuring that they choose agriculture input providers that can easily show, through verified third parties, that their material passes the FDA’s requirements.
   
   Furthermore, as these smaller players work on consolidating info from their food suppliers, such as indoor farms, they’ll need the info quickly and in a manner that’s easily understandable. Therefore, take the time to work with your agriculture input provider to let them know what your needs are in terms of material transparency.

For indoor farms that may be unsure of what type of info they may be able to access, as well as where to begin with the process of choosing agriculture inputs, particularly for organic hydroponic nutrients, as well as compostable grow media, we would be happy to help answer any of your questions here.