As the number and quality of attempts to increase seafood consumption increase, more and more people consume the seafood they consumed or have a positive feeling about consuming, primarily what they are fed with, where they come from, the conditions where they come from, and of course, the protein in the seafood that comes to their plate as a crop. They began to ask more and more questions about whether there was anything other than meat and other nutritious vitamins and minerals as a source of food.
In order to ensure that the processes from farm to plate are shared with the end consumer in a clear and unambiguous manner, since the questions that are asked regularly and wondered for answers, can contain many non-transparent and open to abuse content, especially from species-based substitute products and from landing to hunting methods and the sustainability of these methods. Some initiatives started to be carried out on the basis of technology and operations.
The USA is one of the largest consumers of seafood and has institutions that are the authority to set some accepted standards in the world. Many institutions in the country, especially the FDA, are working together on this issue. While it may seem like there is some time now for the alarm to sound in 2024, manufacturers in the US realize that time is running out as they begin to fully understand the need for food traceability. Of course, we are not directly responsible for a rule that comes into force in the USA, but if we want to preserve the benefit and income from seafood, and even plan to increase it, especially if we want to sell products to the USA in important items such as shrimp and sea bream - bass, we also follow their rules. We have to adapt ourselves.
The big question: How and in what form will this data be obtained?
It took the FDA nearly 10 years to come up with rules on food traceability, and everyone knows that change is not easy. For example, a seafood producer is expected to keep certain records on a regular basis, and when FDA officials want to see any data, it must provide it within 24 hours. But for now, the most important question that the aquaculture industry needs to answer is how and how to obtain these records for every product that comes to our plate.
This law is part of the Food Safety Modernization Act (FSMA), which was signed in 2011 to reform food safety laws in the United States. Criticized for its delay, the rule authorized mandatory recalls to the FDA and expanded access to food safety records. It also instructed the FDA to identify high-risk foods and the records manufacturers must keep. Despite all these authorizations, there was no set of guidelines published by the FDA, and in the light of the lawsuits, the FDA will publish these guidelines until November 7, 2022, and companies working in the seafood industry will be obliged to comply with these rules within 2 years after the emergence of the rules.
Spinach, peanut butter, and eggs top that list, and when the FDA runs its risk ranking model, seafood is on the list. All finfish, crustaceans and mollusks from aquaculture or hunting, with the exception of catfish, are included in this list.
There are also companies that are already investing in digitalization and tracking of food for food safety. But digitization is, as expected, costly and requires lots of hard and software, including software licenses, cables, scanners and printers. While large-scale companies have a high chance of financing this and recovering this investment on a schedule they set themselves, it is thought that small-scale producers will face the main problem and access problem. It is also necessary to consider how small and medium-sized businesses and family businesses that already operate with certain profit margins will make this investment, which is necessary to provide the data requested by the FDA in a sustainable manner.
Is the solution event-based traceability?
Speaking at a public meeting in December 2020, Frank Yiannas, deputy FDA commissioner, mentioned that there is going to be a lot of talk about data and standards, and that it has to do with keeping end consumers away from food contaminated with contaminants. The FDA does not require a dataset of digitally produced records, but there is not much other efficient way to manually keep the parameters of aquaculture at any scale in an orderly and sustainable manner. If we consider that only the water in which the cultivation is made has about twenty parameters, there does not seem to be an easier way than to create data sets that can be made meaningful and presented as soon as possible, by digitizing them again.
The system proposed by the FDA is based on CTE’s - critical tracking events in the supply chain and requires capturing KDE’s - key data elements along the way. It also requires the creation of a "lot" identified by a specific code, such as "lot", "production work" or, in the case of growers, those harvested within a 24-hour period.
The key question is whether the FDA system requires everyone to capture and store data in exactly the same way at every step. With a common template that allows manufacturers to simply correlate data from data collection sources installed in various units of the facility, disruptions in data collection and transmission can be avoided. However, considering this will necessitate the development of a specific information technology design standard.
To give a very simple example, the average oyster takes between five or seven steps from the moment it leaves the farm to the moment it is placed on a plate where it is served on ice in a plate. So, if the FDA needs to speed up backtracking from a restaurant where a customer got sick, the system needs to have "interoperability" which can be circumvented by leveraging cloud technologies.
This current move is not the first to have been issued regarding seafood. In 1997, seafood processors authorized by the FDA adopted Hazard Analysis Critical Control Point (HACCP) principles, which require companies to identify food safety hazards and create plans to control them. Considering the investment made by large-scale producers for HACCP, it seems unlikely that they will have difficulties in adapting to the new rules, but it is emphasized that if some rules and requirements that will completely change the existing structure are included, this may cause a major problem affecting the sector.
Why do companies and people hesitate to share their information over the cloud?
Although information technology infrastructures supported by cloud technologies are thought to offer a good solution for data sharing with the FDA and other stakeholders, business owners and companies have reservations about uploading data to the cloud. Among the main reasons for this is the concern that the data could be directly accessible and that competitors may have access to the companies' data. It is not possible to have any of these things in a well-managed cloud server, but it is necessary to work on improving the perception of the subject well.
