ASNs do not, cannot – and will never – include critical information required by the FDA under the FSMA 204 food traceability law. In a recent interview with Progressive Grocer, Frank Yiannas, former Deputy Commissioner for Food Policy & Response at the FDA and architect of FSMA 204, explained this “potential problem” with ASNs in more depth. “Everyone wants to simplify and are trying to confirm what foods are truly received, but doing it with ASNs alone does not comply with a receiving event,” Yiannas said.
It’s dangerous for retailers to assume that ASNs can serve as a “shortcut” to food traceability. Doing so could lead to real regulatory and financial harm. Incomplete or inaccurate traceability data from incomplete or inaccurate ASNs will not be tolerated by the FDA and it will not be tolerated by major retailers and wholesalers who have already announced their traceability programs. If faulty data is passed through the supply chain, as an industry, we won’t be any closer to a safer, more transparent food supply chain.
9 Reasons Why ASNs Alone Won’t Work for Food Traceability
ASNs Can be WRONG and Typically Don’t Include What the FDA Needs
ASNs provide detail from the shipper before delivery. But what’s intended to be shipped doesn’t always sync with what’s actually delivered. To create complete traceability records, the FDA requires accurate information about what was actually received…information that simply can’t be printed or transmitted on an ASN because it’s not KNOWN when the ASN is created. The ASN contains no confirmation of receipt and therefore no confirmation that the product that was promised was the product that was delivered. Data required by the FDA such as units of measure, quantity and Traceability Lot Codes (TLCs) could be missing or inaccurate at the time of delivery. Additionally, the FDA requires the DATE of receipt to be included on traceability records; that information is simply not known until delivery occurs.
Intensions Won’t Work for Food Safety
ASNs indicate what the shipper intends to send, but not what actually gets loaded and transported, and then checked in at the warehouse, store or restaurant where it’s received. This critical distinction becomes a problem for food safety, and won’t meet the requirements of the FDA or of the many traceability programs announced by retailers and wholesalers across the country.
In the event of a traceback investigation, accurate information of what was truly received at the store or distribution center will serve the retailer better than what was intended to be sent there.
If Inventories Are Wrong, ASNs Will be Wrong
The data in an ASN can originate from perpetual inventory systems. While these systems are excellent for managing stock levels in theory, they might not account for real-world, real-time discrepancies. Shrink, damage, theft and errors in inventory management processes can lead to situations where the actual contents of a shipment differ from what has been printed or sent electronically on the ASN. As a result, the ASN can reflect outdated or inaccurate inventory data.
There Is No Such Thing as a Standard ASN
ASNs have no standardized creation process, content requirement or timing. What’s included in the document may originate from a perpetual inventory system, purchase order verification process, production run or the format of the ASN might be driven by the customer’s requirements. This variability makes the origins and accuracy of the ASN unknowable. Relying on ASNs for food safety undermines traceability, as inconsistency and lack of verification of the document could introduce risks, rather than mitigate them.
ASNs Have an Error Rate of 5-10%
For the average retailer with:
1 Distribution Center
300 suppliers responsible for sending traceability data
5 Traceability Lot Codes (TLCs) per supplier
2 deliveries per week into the distribution center
If just 5% of the data transmitted has an error, which is an extremely conservative rate, then the retailer would be responsible for identifying 7,800 errors per year. If the retailer chooses to accept or doesn’t have these errors corrected by the supplier, then the chain of traceability is broken and the retailer is exposed to undue risk.
Error correction is a daunting task for both large and small operators and can create a “traceability nightmare,” requiring time-consuming, labor-intensive work to physically verify each lot code, counts and more.
What could become more of a nightmare for retailers, though, is the regulatory, legal and financial threats that come from noncompliance with FSMA 204. Will loads need to be rejected and sent back if they’re missing the correct traceability data? If the retailer accepts a delivery without traceability data, are they assuming the risk? According to leading food safety attorney Shawn Stevens, the answer is yes. Retailers need to think carefully about doing business with suppliers who cannot – or will not – do traceability.
There is no prescribed way to create an ASN and so a variety of known errors and inaccuracies can occur, including:
- Inconsistencies between book inventories and physical inventories
- Different product may be physically shipped than what was indicated on the ASN
- Data input errors, among others
A complete traceability solution would validate supplier shipment data when it is sent, to flag missing or incorrect information and send rapid notifications to get errors corrected immediately and protect your company.
Is There a Better Traceability Data Source?
Over the years, ReposiTrak has developed technology that solves the ASN problem by collecting traceability data from other sources to create complete traceability records. While there is no singular data source that meets every requirement of the FDA’s FSMA 204 food traceability final rule, there are sources beyond the ASN to consider. The true solution is utilizing a technology that can locate, organize and store the required traceability with little to no impact on workflows or overhead costs.
Are Bill of Lading (BOL) Driven Systems Enough?
Bills of Lading (BOLs) include the exact quantities, lot codes and other shipment details confirmed against what is actually loaded onto the truck. For that reason, BOLs provide the most reliable snapshot of the shipment’s actual contents for traceability purposes. By integrating BOL data into systematic data-sharing protocols including Electronic Data Interchange (EDI), shippers can automatically populate receiving traceability data elements in real time. This eliminates the need for manual reconciliation and significantly reduces traceability errors.
Traceability is NOT an Electronic Data Interchange (EDI) Problem
Traceability is not an EDI problem. EDI is simply a data-sharing protocol used to take in data from one company in the supply chain and share it with another. Traceability is about capturing, organizing and storing detailed records of the journey of a product from its origin to the end consumer. While EDI is a valuable tool for transmitting the required information between trading partners, traceability requires the integration of that data into the framework defined by the FDA and/or by the retailer, wholesaler/distributor or restaurant operation who is receiving the data.
You Can’t Do Traceability Without Collaborative Data Sharing
For the transition to traceability to succeed, shippers and receivers must work together to establish protocols for BOL data sharing. Systematic, automated data transmission ensures that receivers have access to accurate shipment information immediately upon delivery. This approach not only improves traceability but also enhances overall supply chain efficiency.
To conclude, ASNs are valuable tools for operational efficiency, but they fall short when it comes to food traceability recordkeeping. The BOL is the better reflection of shipment accuracy. By adopting BOL-driven systems and fostering collaborative data sharing, organization and storage, the food supply chain can achieve the level of traceability required to meet regulatory demands and protect public health.
For more information on the ReposiTrak Traceability Network, contact ReposiTrak Chief Customer Officer Derek Hannum at dhannum@repositrak.com.
