Field notes
Field notes on food traceability
What we're learning about FSMA 204, retailer audits, and what small food producers actually need to survive the July 20, 2028 traceability deadline.
- 14 min read
Cyclospora, iceberg lettuce, and the traceback the lab test couldn't do: an FSMA 204 teardown for leafy-greens producers
FDA traced the 2026 Cyclospora iceberg lettuce outbreak to one supplier using distribution records and patient interviews, after the lab sample came back a false positive. Here is that same traceback run on a fictional small leafy-greens grower, exactly where it breaks, and how to fix it before a buyer asks.
FSMA 204Cyclosporaleafy greensiceberg lettucetracebacktraceability lot codesmall food producersoutbreak - 10 min read
The FSMA 204 KDE checklist: what to capture at receiving, transformation, and shipping
Every Key Data Element FSMA 204 requires at each Critical Tracking Event, straight from 21 CFR 1.1340, 1.1345, and 1.1350, translated into the columns a small producer actually keeps.
FSMA 204KDECTEtraceabilitysmall food producers - 13 min read
The 24-hour traceback drill: an hour-by-hour FSMA 204 mock recall for a small producer
A clock-running, hour-by-hour FSMA 204 mock recall for a small food producer. One fictional creamery lot, an FDA 24-hour traceback request, exactly where the trail breaks, and how to run the traceback exercise yourself.
FSMA 204mock recalltraceback24 hour tracebacksmall food producerstraceability lot code - 11 min read
Wegmans supplier traceability requirements: the four asks, decoded
Wegmans supplier traceability requirements run ahead of FSMA 204 and are live now. The four concrete asks (EDI 856 ASN, SSCC, GS1-128, FTL self-ID), decoded for a small producer.
Wegmanssupplier requirementsFSMA 204ReposiTraktraceabilitysmall food producers - 8 min read
Does FSMA 204 require GS1? GTINs, barcodes, and what small producers actually need
FSMA 204 does not require GS1, GTINs, or barcodes. FDA's rule is technology-agnostic. Here is what the rule actually mandates, why everyone assumes GS1, and when a small producer genuinely needs it.
FSMA 204GS1GTINbarcodestraceability lot codesmall food producers - 7 min read
FDA's June 15 lot-level traceability meeting: the pain points the industry raised
FDA held its June 15 lot-level traceability meeting and published the discussion paper behind it. Here are the real pain points the industry flagged, and why almost none of them are about you if you are a small producer.
FSMA 204FDAlot-level traceabilitysmall food producerspublic commenttraceability lot code - 7 min read
How to assign a Traceability Lot Code: chevre, almond butter, and fresh-cut greens (worked examples)
Three worked examples of how to assign a Traceability Lot Code under FSMA 204, with the exact lot code format, when you assign it, and where it has to travel.
FSMA 204traceability lot codeTLClot code formatworked examplessmall food producers - 9 min read
Costco supplier traceability requirements (2026 edition)
Costco supplier traceability requirements sit above FSMA 204 and are enforced now. The program layers, where small producers fail, and an audit prep plan.
Costcosupplier auditsFSMA 204traceabilitysmall food producers - 9 min read
TLC vs. KDE vs. CTE: the three FSMA 204 concepts producers keep mixing up
TLC vs KDE vs CTE under FSMA 204, explained in plain English. What each term means, where it lives in your operation, and a worked chevre example.
FSMA 204traceabilityTLCKDECTEsmall food producers - 9 min read
ReposiTrak supplier onboarding: a 7-day playbook
A small producer's survival guide to ReposiTrak. What it checks, what to answer fast, the four traps that cost a week, and a day-by-day plan.
ReposiTraksupplier onboardingFSMA 204Erewhonretailer auditssmall food producers - 11 min read
How to pass a Whole Foods supplier audit
Whole Foods stacks four audits, not one. What each one checks, where small producers usually fail, and a 2-week prep plan to pass cleanly.
Whole Foodssupplier auditsFSMA 204GFSIsmall food producers - 9 min read
FSMA 204 vs HARPC: the difference for small producers
HARPC prevents contamination before it ships. FSMA 204 traces it after. Here's how to tell them apart and what records each one demands.
FSMA 204HARPCHACCPfood safety basicssmall food producers - 10 min read
What is a lot code on food? The FSMA 204 TLC, explained
What a lot code on food actually is, how lot coding works, and how an everyday lot code differs from the FSMA 204 Traceability Lot Code (TLC).
FSMA 204lot codelot code traceabilitytraceability lot codesmall food producersfood safety basics - 8 min read
What your retailer's FSMA 204 questionnaire is asking for
A plain-English breakdown of the data retailers want under FSMA 204: what to send, what to skip, and the three fields that decide your shelf space.
FSMA 204retailer auditstraceabilitysmall food producers