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Taking Traceability To The Next Level

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Traceability is nothing new for the agricultural sector, but the scope and intensity of such efforts are on the rise. This trend involves a diverse set of drivers including concerns (social justice, illegal fishing, and food safety), and as well as aspirations (sustainability and climate action). There are some unique challenges depending on the food/crop involved and there are some issues that cut across those divides. Four specific examples of enhanced traceability will be considered in this article along with an interesting new tracking technology. These involve cotton, seafood, fresh produce, and “Climate Smart Commodities.”

Sustainability and Ethical Considerations for Cotton-based Products

A wide range of products are made with biofiber from cotton, and many brands seek to offer consumers cotton-based apparel and household items that are clearly linked to both sustainable farming and ethical manufacturing. The US cotton industry has been at the forefront of sustainability in terms of practices no-till farming, integrated pest management, precision fertilization and irrigation. It is often said that “sustainability is a journey, not a destination,” and that “you can only manage what you can measure.” The National Cotton Council has been a long-term participant in multi-stakeholder sustainability programs such as Field-To-Market, and so a great many American cotton farmers employ “outcome-based metrics” to track their resource use-efficiency (land, water, energy…) and footprint reduction (greenhouse gas emissions and other environmental improvements). Using the “Fieldprint Platform” set of metrics, they have documented an 82% industry-wide efficiency increase since 2017. This is exactly what many brands are looking for to document their sustainability claims in terms of Scope-3 greenhouse gas emissions as well as other environmental goals. But the unique challenge for this industry is that once the cotton crop moves past harvest and ginning it typically enters an extremely complex global system for the subsequent steps of spinning, weaving, and sowing before it reaches the consumer market. There are some notable examples of unfair practices like forced or child labor – scenarios to which no responsible consumer-facing brand would wish to be tied.


That is why the US cotton industry developed a voluntary Cotton Trust Protocol system which maintains traceability from the gin level through all those manufacturing steps so that legitimate and documentable claims can be made about the entire process. One-point-one million acres of US cotton have been enrolled in this combined sustainability/traceability program within its first two years.

Addressing the issue of illegal activities in the global seafood industry

The seafood industry has some unique and problematic challenges. It’s “wild caught” segment is essentially a hunting process that goes on all around the world in both territorial and non-territorial waters. There are some systems in place to manage and regulate fisheries at a country or regional level, but there are tens of millions of people involved and there is no over-arching mechanism to enforce any uniform standards for how and where the fishing is done. By some estimates as much as 30% of the global seafood supply involves some form of “IUU,” which stands for activities that are Illegal, Unreported or Unregulated and that isn’t an acceptable situation to many consumers and brands and so there are efforts underway to address this problem.


There is an organization called the Institute of Food Technologists whose members include academics and food industry scientists. IFT has been engaged in various product source and identity issues since the early 2000s, including the FDA’s Food Safety Modernization Act (FSMA) initiatives. In 2013 they formed the Global Food Traceability Center and since 2017 IFT in partnership with the World Wildlife Fund, an environmental NGO, created and convened the Global Dialog on Seafood Traceability. Together they have been developing rules for the digitization of information related to seafood traceability and facilitate data transfer through the many downstream exchanges that occur in that industry from boat to market. Many customers require information from their suppliers but in the absence of universal data standards there can be a problem in which the headache and cost of complying with different software requirements becomes a barrier to full market access. The goal of GDST has been to establish data standards so that key traceability information is more universally sharable. They also are structuring the data to facilitate connections to data from NOAA which is helping to identify questionable entries based on geolocation data. The GDST guidelines were published in March of 2020 and were updated two years later. As the system gains momentum on a voluntary basis, it gives seafood supply-chain customers the ability to get the data needed to avoid playing any role in selling IUU-compromised seafood.

Preparing for the next stage in produce safety regulation

Fresh fruits and vegetables have many health benefits, but the unique challenge for that part of the food supply is that it lacks the sort of “kill step” that could eliminate human pathogens. The incidents are rare, but there can be food poisoning associated with various bacteria and viruses. A dramatic example was an incident involving spinach that killed several people in 2006. The produce industry is highly motivated to minimize this kind of risk and to be able to quickly identify the source of the contamination and trace exactly where it has ended up along the value chain. If there is ambiguity about the source and scope of the incident, there can be a dramatic impact on sales of fruits or vegetables even well beyond the specific crop in which an event occurred. Starting in 2009 the US Produce industry, led by the International Fresh Produce Association, Canadian Produce Marketing Association and GS1, launched its own voluntary Produce Traceability Initiative (PTI) using standardized barcoded case labeling and standardized data tracking methods. That system is now used on at least 70% produce cartons and cases or produce in the US market including most of those coming in from Canada and Mexico.

In 2011 Congress passed the Food Safety Modernization Act (FSMA) which tasked the FDA to develop a comprehensive traceability system for products with higher risk for food poisoning. The produce industry is one of several industries has been very involved with the FDA to align their rules with the progress that has already been made under their existing PTI system. In November of 2022 the FDA published “FSMA 204 Final Rule” which will go into full effect as of January 2026. It will require very rapid traceback capability for 10 fresh, fresh-cut and deli-salad produce items that are considered to be at highest risk. Electronic sortable spreadsheets with key data elements will have to be available within 24 hours of health incidents and full tracking is required at each “critical event” in the system from “field to store or restaurant.” The most complex stages for tracking are at “distribution centers” and in the “back room” at a retail outlet because of the diversity and rapid movement of items at those steps in the chain. The produce industry has surveyed buyers, and most would prefer to get to the point where they can apply the new traceability standard to virtually all produce and fully integrate that with their own inventory management systems and software. The industry sees enhanced produce safety through traceability is seen as an example of how “a rising tide raises all ships.”

Anticipating Consumer Interest in “Climate-Smart Commodities”

Many modern consumers would like to be able to “vote with their dollars” for positive climate action and there are many efforts underway to enable such choices. The USDA solicited grant proposals for the development of “Partnerships for Climate Smart Commodities” (CSC) and have invested $3.1 billion in 141 projects. The teams receiving the grants include academic and extension researchers, technology companies, NGOs and downstream customers. They are developing cropping systems with a positive climate impact through energy savings, reduced, greenhouse gas emissions and/or soil carbon sequestration. As of now there is no governmental process in place to define “climate smart,” but voluntary standards will be needed to head off concerns about “greenwashing” and misleading marketing. As this category evolves one of the challenges will be the need for “identity preservation” so that the harvested crop can be segregated and then traced through whatever post-harvest steps are necessary to generate the consumer product. With some crops that is already normal practice for other reasons. For instance, wheat is handled this way based on very specific variety- and season-specific quality characteristics. For efficiency reasons many of the largest acreage crops such as corn or soybeans, are handled today as pure “commodities” and to segregate by growing system would require changes in infrastructure and probably add cost. While consumers may be willing to pay some kind of premium for items that represent meaningful “climate action,” it is important that this category does not evolve into an elite niche option because that would fail to make this a driver for significant overall climate impact – something that would need to involve many tens of millions of acres of cropland. That may require some innovative means of traceability – for instance knowing the mix of growing practices from all the farms feeding into a single grain elevator and tracking the proportion which comes from “climate smart” operations. Even in this very early phase of the endeavor, it is encouraging that IFT, the same organization that took on the traceability challenges of the seafood industry among many others, is on the teams for two of the projects that have won the USDA Climate Smart Commodities funding. It remains to be seen whether there will be a need for some sort of regulatory oversight for this category, but in the meantime it appears to be following the industry driven, pre-competitive model seen in most of the examples discussed above.

A New Technology For Traceability

While highly functional traceability often comes down to a full understanding of complexity, to rational data standards and the various motivations for voluntary compliance, there is an interesting new technology option that could be used to enhance traceability. Past advances such as bar codes and RFID chips are very important for inventory management and traceability, but they usually require on-site human actions such as individually scanning items at the pallet or case level at various stages in the distribution chain. There is a company called Wiliot that has developed what it calls “ambient IoT” (Internet of Things) which is essentially a tiny computer powered by radio waves which can automatically transmit information to local receivers without the need for human intervention. The tracking units will cost less than 10 cents each next year and the receivers generally cost less than fifty dollars. Thus it is s conceivable that every pallet or even every case arriving at a distribution center or a retail back room could update the inventory tracking database about its location. These units can also track what has happened enroute in terms of temperature – a key parameter for food waste prevention. Wiliot sells the Iot Pixels and monitor units as well as the Cloud services for the data they generate. They will produce 200 million of these tags for a variety of uses in 2023 and anticipate being in the 2-10 billion range by next year. One might easily imagine a useful role for these units with classified government documents, but it will be interesting to see where this ends up being for food traceability.

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