Traceability is a system in which fruits and vegetables can be traced from the field to the buyer by lot through unique codes. A lot code could be a number, number-letter combination, or some other designation that is unique to the lot. Each farm should have a traceability system in place that allows the grower to track the produce from the field (one step back) to the buyer (one step forward).
Who Should Have a Traceability System?
Every farm. Being able to identify and recall a defined lot of contaminated product not only protects consumer health, but also helps reduce your losses by not having to recall everything in the marketplace. In case of a foodborne illness outbreak or customer complaint, you will be able to identify what products you have in the marketplace, determine when they were sold, and recall them if necessary. A working traceability system is an asset to your farm because it can be used to settle customer complaints and questions about the product that was sold. If you direct market at farmers markets or other places where the buyers are anonymous, develop a system to track what you took to market (where it came from and when it was harvested) and document what was sold (crop, volume, date, and location). If you have an on-farm market, keep track of what you put out for sale and how much is sold each day. Other benefits of a traceability system include keeping track of inventory (e.g., first harvested, first out) and expected income from sales.
What is a Lot?
A lot is a distinct and limited portion of a crop. A lot could be defined as all of the same crop harvested from the same field on the same day. Some farms may find that this definition results in lots that are too big, so they may choose to divide the harvest further, thereby making several different lots. It is most important that you develop a lot system that makes sense to you and works for your farm. Operations with packing lines should use a clean break to differentiate between lots, otherwise the lots are not truly distinct. A clean break is a break in production where all food contact surfaces on the production line are cleaned and sanitized with a documented process (1). However lots are defined, each lot must be assigned a unique lot number. The lot number should be on each container in the lot and recorded on the invoice. The benefit of having the lot number on the container is that in the case of co-mingling with other lots, each container is identifiable.
Lot Code Specifics
A lot code is a unique identifier of a designated lot. The code (which can include numbers and letters) should incorporate the date. Many growers find using the Julian date useful when developing lot numbers. From the lot number, you should be able to identify the following information about the lot:
- Commodity/produce item
- Farm location where produce was grown
- Field where produce was harvested
- Harvest date
- Harvest crew
- Packinghouse used (if any)
- Packing date (if different than harvest date)
- Packing crew (if different than harvest crew)
Growers can use existing farm and planting maps to establish field numbers to reference in harvest logs that track harvest and packing dates. If the farm only has a few employees, the employees can be grouped together as one harvest crew responsible for picking and packing all produce on the farm. All of this information should be linked to the lot number. Please see Sample SOP: Traceability for an example of how to develop a lot code.
Most farms are not required to label each piece of produce under the Federal Food, Drug, and Cosmetic Act, but each farm should consider labeling each container that leaves the farm. This makes traceability of lots more efficient and effective.
Even growers who qualify for an exemption from the FSMA Produce Safety Rule “must prominently and conspicuously display, at the point of purchase, the name and complete business address of the farm where the produce was grown, on a label, poster, sign, placard, or documents delivered contemporaneously with the produce in the normal course of business, or, in the case of Internet sales, in an electronic notice” (2). This means that growers who sell at farmers markets or have a CSA could meet this labeling requirement by making a sign with their farm name and address to hang at their booth or pick up site.
Traceability System Options
Traceability options range from paper systems to electronic ones; choose the system that works best for you. Growers can use simple systems like grocery store labeling guns for marking all the containers of a particular lot. Markers and self-adhesive mailing labels can also be used. Electronic traceability systems can be purchased, but are not required. Electronic systems often use barcode technology with GTIN numbers. As the need for traceability grows, commercial options may increase and become more affordable, making them a reasonable option for small farms.
Testing the Traceability System
Every traceability system should be tested to make sure it is effective. One way to do this is to contact a buyer and ask about a particular lot code(s). The buyer should be asked how much of the lot(s) remains in their possession and how much has been sold. It is important to tell the buyer you are testing your traceability system. Document the buyer’s response to your request about the selected lot code(s) and match it with your farm information. If produce is sold through direct markets, the traceability test may include devising a way to contact a set of customers, such as through e-mail lists or by posting signs at the direct market stand. Collection of information could be done through emails, phone calls, or the postal service.
The information in the template food safety plan, SOPs, and recordkeeping logs are examples you can use. They are not intended to be used directly. Tailor each to fit your farm operation and practices. These documents are guidance for risk reduction and for educational use only. These documents are not regulatory and are not intended to be used as audit metrics. These documents are subject to change without notice based on the best available science.