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FSMA 204: Transaction Capture Upstream (Farms, Coolers, Initial Packers)



As a tomato myself, I am not directly involved in the process of transaction data capture at the Farms, Coolers and Initial Packers. However, I do understand that as part of the FSMA 204 ruling there are a number of Key Data Elements (KDEs) that will need to be collected, stored and shared at the point of Harvesting, Cooling and Initial Packing.


Produce farmers need to note (Sorry, I can only talk Produce 🙁) that the FDA has taken away data requirements early in the crop cycle and only need KDEs starting at the point of Harvest (When I’m gently plucked off my plant!). See below:


Harvesting KDEs:

  • Location description for my recipient (other than a transporter)

  • My name & variety

  • Quantity & unit of measure (UOM)

  • Location description of the farm where I was harvested

  • Name of the field or growing area where I was harvested, OR Other info identifying the harvest location; at least the field or growing area name

  • Date of my harvesting

  • Reference doc type and number

The folks Harvesting me also need to provide the following info to the Initial Packer:

  • Business name

  • Phone number

  • Harvesting KDEs (See above - except for reference document type and number)

Cooling KDEs: Once Harvested, I need to move to these amazing coolers which keep me fresh and where the following KDEs are needed:

  • Location description for my recipient (other than a transporter)

  • My name & variety

  • Quantity & UOM

  • Location description of where I was cooled

  • Date of cooling

  • Location description for the farm where I was harvested

  • Reference doc type and number provided to the Initial Packer

My loving Cooler folks need to provide the Initial Packer (next step) with the following info:

  • Cooling KDEs (except the reference doc type and number)

Initial Packing KDEs: After my cooling spa treatment, I am typically moved to the Initial Packers who then dress me and my friends into these cool-looking packages. To address FSMA 204, my packers need to capture the following KDEs.


  • My name & Variety

  • Date they received me

  • Quantity & UOM

  • Location description of the farm where I was harvested

  • Name of the field or other growing area where I was harvested OR Other info identifying the harvest location at least the field or growing area name

  • Business name & phone number of my harvester

  • Date of my harvesting

  • Location description where I was cooled (if applicable)

  • My Date of cooling (if applicable)

  • Traceability lot code (TLC) the packer assigned me and my friends

  • Product description of my package

  • Quantity & UOM of my package

  • Location description where I was initially packed (i.e., TLC source), and (if applicable), the TLC source reference

  • Date of my initial packing

  • Reference doc type and number

In summary, the process of capturing data upstream involves several easy steps (Critical Tracking Events/CTEs) across Harvesting, Cooling and Packing. Within these CTEs you need to see which KDEs you currently track and which ones you don't, then start tracking the KDEs you don't. Once you have all the KDEs lined up, you need to make sure you have the right process discipline and systems to capture, store and share this data as required. Depending on the size or type of your business you could use rudimentary methods like paper docs, excel sheets or as the FDA has suggested, specialized tech traceability software like TagOne that are designed to automate much of the data entry and verification process.


#FSMA204Compliance #FSMA204Requirements #FoodSafety #TransparencyAvengers #TrustButVerify #TagOne #TransparencyMatters #TraceabilityMatters #MyFoodJourneyMatters #MyFoodSourceMatters #NothingToHide

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