Identifying FTL Items
While your organization is defining what solution to handle for all your FSMA 204 needs, there is certainly a lot of work to be done prior to loading data into any system.
FSMA 204’s trickiest Food Traceability List (FTL) item is by far tree nuts and peanut butters. These include all forms of nut butters, including shelf stable, refrigerated, frozen, and previously frozen products. Examples include (but are not limited to) almond, cashew, chestnut, coconut, hazelnut, peanut, pistachio, and walnut butters. This does not include soy or seed butters. No other single FTL item has as many SKU’s as this.
Searching your item list from your Master Data Management System for the word “Peanut Butter” or “PB” for example, can yield some wild results. This can include everything from peanut butter flavoring (which is not in scope) to items that have been processed (which are also not in scope). Try this with Coconut and Hazelnut and challenges can become even more tricky since at times the word “butter” is not added to product names yet are in nut butter form according to the ingredient statement.
Which system should a retailer start to look at to identify FSMA 204 FTL items? Master Data Management? Purchasing (Looking at last 12-18 months data)? ERP? EDI? WMS? Some retailers proactively created their own product specification databases that outline product ingredients. Should they search ingredient statements there? What if your product database only contains your private label products and not all your products?
Nut Butters can be stand-alone containers, or they can be in granola bars, cereals, yogurts, candy, ice cream, snacks, dipping cups, cookies, cakes. It can be in the fresh bakery or in can be in the frozen foods aisle. Almost every aisle in the grocery store could be in scope with nut butters alone.
To identify FTL items you are currently handling will take some work and some executive decisions.
So where should retailers begin? Do you seek out information from suppliers to help them identify SKU’s that are in scope? Or, do you look at your own data sources? Could it be both?
These are decisions that likely need to be made in cooperation with General Counsel and executive leadership.
A realistic answer might be, “Both.”
To reduce the amount of downstream data complexities, #2 might help you sleep better at night and reduce complexities down the supply chain. Here is why:
If you rely on suppliers to self-identify and an FTL item is missed, the downstream impact to correct this can take much longer. It is typically harder to add an item than delete an item. And often when you need to add an item it occurs at the most inconvenient time.
Option #2 is the path of erring on the side of caution. But communication with the supplier is critical to obtaining KDE’s for each item you identify as FTL.
However, Option 2 could dramatically increase the number of SKU’s for which you are collecting extra data.
To do both means that you may have a larger list than the law requires but you have much less than if you were relying solely on your own data.
Either option is going to take a highly coordinated effort. But this is necessary work that can be done prior to choosing a solution or even while you are choosing / defining your solution requirements.
First, create an internal company communication to all stakeholders alerting them to FSMA 204 and the products and categories on the FTL list and ask them to help you identify your products that are subject to FSMA 204. While you may presume to know that answer, ask the question and confirm it anyways. Nut butters can be in flavors and other seemingly insignificant ingredients. The more people that are typically involved in creating a product specification, the more should be involved in identifying any ingredient (especially nut butters) subject to FSMA 204.
Second, we recommend communication via your supplier portal to all suppliers letting them know about FSMA 204 and what items are on the FTL. While it is not your job to do this, it may help communication start earlier than might happen otherwise.
Next, we recommend you give suppliers specific direction as to how to get their information / data to your “System of Record” for item management. For some, that may be an MDM system. For others, that may be by the GS1 Global Data Synchronization Network (GDSN) or even something else. If you are not ready to receive that information yet, set a date for them you expect to need that from them so they can begin planning internally now. It is okay to say, “We expect to have our FTL Item Update Guidance Document ready by November 1, 2024 and would expect to have all suppliers update their items by December 1, 2024.” This helps organizations plan and helps direct everyone towards the objective.
Resist the temptation to have your suppliers send you their FTL items on an unspecified XLS format. Meaning that if you are asking your suppliers to provide you something in excel, make sure it is an agreed upon format by your organization that is useful to upload into your System of Record. Otherwise, you might have 2,000 excel spread sheets that now all need to be re-formatted.
The next biggest challenge with excel can be the lack of data validation. While this can be solved with macros or xml, those have other challenges where some organizations are not allowed to download 3rd party excel files with macros or xml for security purposes.
As more and more manufacturers become aware of FSMA 204, communication around self-identifying FTL items becomes more and more prevalent. While it is great to receive communication on this, that has to be balanced against suppliers that are not self-identifying. It may also feel chaotic to get multiple unexpected notifications about one company’s products. Once this information is received, now what? How do you use it? The earlier you can adopt your standard format for suppliers, the easier it will be to help them get data to you.
We recommend using a survey solution with your supplier community. Share-ify offers this capability to Enterprise subscribers. The following questions in a survey may be a helpful start to better understanding your suppliers’ current dispositions.
Knowing all of this helps to understand what kind of KDE’s you may be receiving / creating / managing and can help get your arms around who you should be focusing your communication with.
If you are like most retailers, you have a large group of suppliers utilizing EDI. However, you also have a vast (and possibly bigger) number that do not. So how do you address receiving data from each to meet the requirements of FSMA 204? Interoperability from non-EDI suppliers through the supply chain is a stumbling block for many. To learn more about Share-ify’s solution for this, go to https://share-ify.com/interoperability.