July 8, 2021

FoodLogiQ Commentary on USDA's Supply Chains for Production of Agricultural Commodities and Food Products

Read FoodLogiQ's public comments on Executive Order 14017 for building resilient supply chains regulated by the USDA.

On February 24, 2021, President Biden issued Executive Order 14017, ‘‘America’s Supply Chains’’. The order focuses on the need for resilient, diverse, and secure supply chains to ensure U.S. economic prosperity and national security. Such supply chains are needed to address conditions that can reduce critical manufacturing capacity and the availability and integrity of critical goods, products, and services. E.O. 14017 directs that, within one year, the Secretary shall submit a report to the President, through the Assistant to the President for National Security Affairs (APNSA) and the Assistant to the President for Economic Policy (APEP), on the supply chains for the production of agricultural commodities and food products.

FoodLogiQ has submitted public commentary to the United States Department of Agriculture (USDA) to offer guidance on how future regulation can enable greater resilience within the agricultural food system. Read an excerpt of our commentary below.

Digital Approach

Taking a new approach to supply chain, leveraging technology and other tools to create a safer and more digital, traceable food system can be achieved. We are doing this today at FoodLogiQ, with our cloud-based FoodLogiQ Connect platform, which enables supplier management through documentation and assessments, gathering transactional event data to support case-level traceability, and managing recalls from notification through to action, gathering site-level information regarding product retrieval and/or destruction.

To enable a transparent supply chain, companies need data. They need systems that provide the critical information they need to foresee and avoid supply chain disruptions. To this end, FoodLogiQ recommends:

USDA/AMS – and the Administration – need to promote digitization of the entire supply chain, especially for agri-food businesses that produce or manage critical and essential products, per E.O. 14017
USDA also should promote digital literacy and proper master data, transactional data, and physical event data.
USDA/AMS should promote more efficient and traceable electronic data capture to make it easier for businesses to transition their paper-based businesses to digital ones and enhance the quality of data in the process.

One of the most significant challenges to achieving the actionable and reliable food supply chain information that drives resilience and transparency is the absence of a clearly defined product data set. Having this foundation in place will allow uniform adoption by industry stakeholders.

Some key areas to note:

Focus on the fundamentals of supply chain visibility: Globally Unique Identifier contained in a Data Carrier (i.e. 2D Barcode, RFID, NFC, digital watermark, Bluetooth® etc.) attached to item and captured automatically at defined points across food supply chains (i.e. Commission, Receiving, Shipping, Transformation, Consumption) with an agreed upon set of attributes.
Clearly defined protocol for tracing and recalls of products from the industry – what information will be provided – Brand, Location, Item Number, Traceability Identifiers (i.e. Batch/Lot), Dates, and define the roles and responsibilities of both the notifier and the receiving parties.
Define standardized data syntaxes and format for an interoperable exchange of information between the parties exchanging it.

Technology adoption and use in the food industry has matured greatly and continues to evolve. The USDA needs to encourage the adoption of a common "language" to be used in order to share information between the supply chain partners, thus removing barriers, increasing speed of data exchange, and eliminating different interpretations. Clear examples of what information will be shared and in what form will help eliminate errors and drive adoption.

Standards Enabled Transparent Supply Chains

FoodLogiQ encourages USDA to adopt policies to facilitate the use of technology to address supply chain capability by requiring or incentivizing the use of global unique identifiers that can be used to trace each end-consumption item; specifying the minimum content to be tied to global unique identifiers; and requiring the use of technology to capture and share required information electronically.

Technology providers will need to create viable solutions that address different company’s capabilities, from low to high tech, exploring a range of systems from existing technologies such as EDI and barcodes, to RFID, blockchain and cloud technologies. With enhanced, technology-driven data management and automation, we can greatly increase the amount of data about the supply chain, action food safety issues quicker and with more precision, reduce food waste, and build more transparency between trading partners and end consumers.

Increasingly globalized, complex supply chains have resulted in less visibility into food sourcing for customers and regulators. These trends are driving the need for digital transformation through the adoption of technology to bring automation, integrity, data management and traceability. Digital technology can enhance the ability to identify, respond to, and prevent food safety issues such as outbreaks, fluctuating market demand, minimize waste, labor, or resources utilized in production.

For example, the time it takes to identify the source of a contaminated food product can be drastically reduced compared to the status quo processes for recalls. Given recent food incidents, the use of digital technology has become even more needed, as it can help to make full product data accessible throughout every stage of the food supply chain in the event of a recall. In addition to being able to implement precision recalls, supply chain visibility allows for identification of all impacted products, detailing where products came from and where they have been sent to at the batch/lot or case level.

Neither a single method for collecting all food supply chain data nor a single repository for holding and sharing such information is feasible. Interoperability is necessary (though not sufficient) to create a traceable food supply chain.

ISO based standards, including GS1 standards, allow for both physical and digital identities to facilitate a system that enables flexibility of approach in capturing and sharing supply chain content that is universally recognized by others in the supply chain. Such standards must support and encourage the use of technology [and automated collection] and be designed to be flexible, and facilitate the adoption of emerging technologies. Given the diversity that exists in the food supply chain, interoperability is necessary for achieving scalability, lowering adoption costs, and preventing the exclusion or elimination of smaller supply chain participants.

The use of standards for data carrier, data format and defined protocols to manage the exchange of information steers the enlargement of an ecosystem of companies specialized in the design and market of those standardized components, thus bringing down the total cost of the solution since multiple choices are available for market adoption. The federal government should consider adopting standards to set the baseline content – or data points – needed to facilitate a food supply chain that is both visible and actionable. These standards should require such baseline content to be physically or digitally tied to each end-consumption item entering the food supply chain in a manner that can be digitally captured.

Interoperability Enhances Collaboration

By establishing baseline requirements, each supply chain participant should be able to collect and share the same information (e.g. unique identifier, lot, batch, etc.) regardless of their technology choice.

Without interoperability, a vast amount of critical food supply chain data remains in silos, preventing a visible supply chain. Additionally, the producers and growers at the beginning of the food supply chain tend to be small businesses, particularly as compared to the large distributors and retailers participating further down the line. Often these smaller participants are asked to comply with multiple transparency and traceability requirements, which can be burdensome to meet. Industry collaboration driven by interoperable standards is necessary to lower the technological, financial, and resource barriers to adoption and participation, particularly for smaller companies. Standardization will also reduce the need for customization allowing for a more seamless and scalable onboarding processes for participants deploying transparency and traceability solutions.

To help demonstrate the scalability that can result from harmonized standards, USDA can take certain actions, such as conducting pilots with multiple participants from NGO’s, supply chain members and technology partners.

Once standards are in place to ensure physical and digital identities are being utilized to tie universal baseline content to each end-consumption item, USDA should mandate the capture of such content at each Critical Tracking Event in the supply chain where the product either changes states or owners. To ensure actionable transparency, USDA must move beyond the one-step-forward, one-step back approach to ensure that baseline content is captured from end-to-end, or farm-to-fork. Missing information resulting from non-participation can cause dangerous delays in responding to food safety incidents and limit the ability of participating stakeholders to fully-capture the benefits of supply chain transparency. Any USDA traceability requirements should facilitate the use of technology to electronically and easily capture and share the required information. As food supply chains become more globalized and complex, paper [and non-automated] records have become increasingly inadequate tools for tracking supply chain data.

Building a Stronger Food System

As we move forward, companies need to adopt technology that offers visibility and transparency where it’s needed most. They need tools to communicate across supply chains that promote food safety and prevent disruptions.

The United States needs resilient, diverse, and secure supply chains to ensure our economic prosperity and national security. Pandemics and other biological threats, cyber-attacks, climate shocks and extreme weather events, terrorist attacks, geopolitical and economic competition, and other conditions can reduce critical manufacturing capacity and the availability and integrity of critical goods, products, and services.

Resilient supply chains must focus on the adoption of technology to bring automation, integrity and data management solutions to supply chain traceability. The role of government in this arena is to facilitate the use of technology and establish standards that allow for new technologies to work together seamlessly.

Digital technology can accomplish many of the goals the EO outlined—building secure, resilient and secure supply chains to address the needs of the 21st Century.

We request that the USDA consider the following points: