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Figuring Out The Food Safety Modernization Act

Food Safety

U.S. FDA (Food & Drug Administration has announced new requirements for food traceability and documentation for the Food Safety Modernization Act (FSMA) which have been published in the Federal Register. The need to swiftly identify and remove potentially contaminated food requires the people who manufacture, process, pack, or hold foods on the Food Traceability List (FTL) to maintain records and provide information to the FDA within twenty-four hours. While full compliance isn’t required until January 20, 2026, we strongly encourage our customers to begin building compliance programs and documentation as it becomes available.

 

High-risk foods currently include:

Food Traceability List
Description

Cheeses, other than hard cheeses, specifically

 
  • Cheese (made from pasteurized milk), fresh soft or soft unripened
Includes soft unripened/fresh soft cheeses. Examples include, but are not limited to, cottage, chevre, cream cheese, mascarpone, ricotta, queso blanco, queso fresco, queso de crema, and queso de puna. Does not include cheeses that are frozen, shelf stable at ambient temperature, or aseptically processed and packaged. 
  • Cheese (made from pasteurized milk), soft ripened or semi-soft
Includes soft ripened/semi-soft cheeses. Examples include, but are not limited to, brie, camembert, feta, mozzarella, taleggio, blue, brick, fontina, monterey jack, and muenster. Does not include cheeses that are frozen, shelf stable at ambient temperature, or aseptically processed and packaged. 
  • Cheese (made from unpasteurized milk), other than hard cheese[1]
Includes all cheeses made with unpasteurized milk, other than hard cheeses. Does not include cheeses that are frozen, shelf stable at ambient temperature, or aseptically processed and packaged. 
Shell eggs Shell egg means the egg of the domesticated chicken.
Nut butters Includes all types of tree nut and peanut butters. Examples include, but are not limited to, almond, cashew, chestnut, coconut, hazelnut, peanut, pistachio, and walnut butters. Does not include soy or seed butters.
Cucumbers (fresh) Includes all varieties of fresh cucumbers.
Herbs (fresh) Includes all types of fresh herbs. Examples include, but are not limited to, parsley, cilantro, and basil. Herbs listed in 21 CFR 112.2(a)(1), such as dill, are exempt from the requirements of the rule under 21 CFR 1.1305(e).
Leafy greens (fresh) Includes all types of fresh leafy greens. Examples include, but are not limited to, arugula, baby leaf, butter lettuce, chard, chicory, endive, escarole, green leaf, iceberg lettuce, kale, red leaf, pak choi/bok choi, Romaine, sorrel, spinach, and watercress. Does not include whole head cabbages such as green cabbage, red cabbage, or savoy cabbage. Does not include banana leaf, grape leaf, and leaves that are grown on trees.  Leafy greens listed in § 112.2(a)(1), such as collards, are exempt from the requirements of the rule under § 1.1305(e).
Leafy greens (fresh-cut) Includes all types of fresh-cut leafy greens, including single and mixed greens.
Melons (fresh) Includes all types of fresh melons. Examples include, but are not limited to, cantaloupe, honeydew, muskmelon, and watermelon.
Peppers (fresh) Includes all varieties of fresh peppers.
Sprouts (fresh) Includes all varieties of fresh sprouts (irrespective of seed source), including single and mixed sprouts. Examples include, but are not limited to, alfalfa sprouts, allium sprouts, bean sprouts, broccoli sprouts, clover sprouts, radish sprouts, alfalfa & radish sprouts, and other fresh sprouted grains, nuts, and seeds.
Tomatoes (fresh) Includes all varieties of fresh tomatoes.
Tropical tree fruits (fresh) Includes all types of fresh tropical tree fruit. Examples include, but are not limited to, mango, papaya, mamey, guava, lychee, jackfruit, and starfruit. Does not include non-tree fruits such as bananas, pineapple, dates, soursop, jujube, passionfruit, Loquat, pomegranate, sapodilla, and figs. Does not include tree nuts such as coconut. Does not include pit fruits such as avocado. Does not include citrus, such as orange, clementine, tangerine, mandarins, lemon, lime, citron, grapefruit, kumquat, and pomelo.  
Fruits (fresh-cut) Includes all types of fresh-cut fruits. Fruits listed in § 112.2(a)(1) are exempt from the requirements of the rule under § 1.1305(e).
Vegetables other than leafy greens (fresh-cut) Includes all types of fresh-cut vegetables other than leafy greens. Vegetables listed in § 112.2(a)(1) are exempt from the requirements of the rule under § 1.1305(e).

Finfish (fresh and frozen), specifically:

 
  • Finfish, histamine-producing species
Includes all histamine-producing species of finfish. Examples include, but are not limited to, tuna, mahi mahi, mackerel, amberjack, jack, swordfish, and yellowtail.
  • Finfish, species potentially contaminated with ciguatoxin
Includes all finfish species potentially contaminated with ciguatoxin. Examples include, but are not limited to, grouper, barracuda, and snapper.
  • Finfish, species not associated with histamine or ciguatoxin
Includes all species of finfish not associated with histamine or ciguatoxin. Examples include, but are not limited to, cod, haddock, Alaska pollock, salmon, tilapia, and trout.[2] Siluriformes fish, such as catfish, are not included.[3]
Smoked finfish (refrigerated and frozen) Includes all types of smoked finfish, including cold smoked finfish and hot smoked finfish.[4]
Crustaceans (fresh and frozen) Includes all crustacean species. Examples include but are not limited to shrimp, crab, lobster, and crayfish.
Molluscan shellfish, bivalves (fresh and frozen)[5] Includes all species of bivalve mollusks. Examples include, but are not limited to, oysters, clams, and mussels. Does not include scallop adductor muscle. Raw bivalve molluscan shellfish that are (1) covered by the requirements of the National Shellfish Sanitation Program; (2) subject to the requirements of 21 CFR part 123, subpart C, and 21 CFR 1240.60; or (3) covered by a final equivalence determination by FDA for raw bivalve molluscan shellfish are exempt from the requirements of the rule under § 1.1305(f).
Ready-to-eat deli salads (refrigerated) Includes all types of refrigerated ready-to-eat deli salads. Examples include, but are not limited to, egg salad, potato salad, pasta salad, and seafood salad. Does not include meat salads.

 

Issues surrounding food safety, combatting food-borne illness and avoiding contamination are critical parts of the job for perishables shippers and their facilities. Any failure in the chain of custody can result in serious losses of time and value as recalls and contamination spread through the supply chain. Forwarders should be a central point in the shipment where the information comes together to provide for up-to-the-minute statuses on all cargo. 

 

Knowing the requirements and having a process in place that protects our clients, Edward J. Zarach & Associates offers you an expert in your corner. We can help answer your questions, identify problems and provide solutions before they arise, and help you find valuable partners in the event you need to make changes to your supply chain. Having a single point of contact ready to work with your logistics plan to increase efficiency and ensure compliance with your shipments sets you apart from the competition. If you’re ready to take your perishable shipments to the next level, contact your Zarach representative today.

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