Challenges and Solutions in Lot-Level Food Traceability; Public Meeting and Request for Comments

James Forshay, an owner-operator of a small fresh-cut produce business, supports maintaining strict lot-level traceability requirements as a means of protecting small businesses from broad, costly recalls. He argues that while flexibility is needed for practical implementation, it should not compromise data precision and suggests providing small operators with plain-language guidance and model records.

Dot Foods, a large food industry consolidator, supports the use of GS1 Standards to implement the Food Traceability Rule under FSMA Section 204. They argue that standardized data and exchange protocols are essential for ensuring consistency, interoperability, and efficient data sharing across the supply chain.