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At this year’s GFSI Conference, I was fortunate to lead a fireside chat with Rick Buttner, Senior Director of Supply Chain Operations for Subway’s Independent Purchasing Cooperative (IPC). The intent of this discussion was to help our peers consider the implications of an increasingly global and complex supply chain on food safety, and to examine possible ripple effects around the world that could be caused by new regulations and initiatives from the U.S. Food and Drug Administration (FDA).

These changes are significant, but they are even more challenging amid the backdrop of the COVID-19 pandemic, which made protecting food difficult because of skyrocketing consumer demand for products and a lack of inventory visibility. Each are key factors limiting traceability. Essentially, 2020 showed that there is work to be done to effectively respond to rapidly shifting consumer priorities.

During our discussion, Rick’s insights spanned three main areas: the importance of collaboration, regulatory preparedness, and overcoming pandemic-related challenges.

The Importance of Collaboration

At IPC, the purchasing co-op owned by Subway franchisees in the U.S., Canada, and Puerto Rico, Buttner and his colleagues are inspired every day to maintain a focus on food safety for the customers that enjoy Subway foods.

“When we have to pull product during a recall, we want to do it as quickly as possible,” said Buttner. “We can’t live with putting anyone at risk.”

IPC’s team is renowned for its dedication to using GS1 Standards to facilitate widespread data sharing and supply chain visibility that contributes to a food safety culture. Additionally, their focus on collaboration is very much in-line with GFSI’s work to harmonize and simplify the food supply chain by reducing inefficiencies and duplication of work efforts. The key, says Buttner, is to view vendors more like strategic partners.

“We invite them to share their own needs and requirements and we do the same for them. In many instances, they’ve built plants and produced products specifically for us, which has been a great working relationship. It’s a very different model from other organizations that I’ve been involved with,” Buttner explained.

IPC encourages partners to join and participate in the Foodservice GS1 US Standards initiative, so that everyone can take a holistic view of the impact of standards and stay focused on collective goals.

“GS1 US invites operators, suppliers, and distributors to the same table to discuss problems for the industry,” he said, noting that while they all have their own unique viewpoint, they work together in a powerful way to understand how to make progress.

Regulatory Preparedness

The discussion also centered on the FDA’s encouragement of more tech-enabled and data-driven traceability through the New Era of Smarter Food Safety initiative and the pending food traceability rule, section 204 of the Food Safety and Modernization Act (FSMA). While the rule is expected to be final in 2022, IPC and many others in the foodservice industry have been taking action over the past several years since FSMA’s initial passage to improve the way food is traced and data is collected.

“We have been laser focused for the last five years to gain traceability insights into the products being delivered to our restaurants. We’re asking suppliers to put good GS1-128 barcodes on their cases—the quality of the barcodes has been a challenge at times but we’re getting beyond that—and we’re challenging distributors to scan those barcodes at the time of delivery into our restaurants,” said Buttner.

With key data elements being pulled from GS1-128 barcodes (barcodes applied at the case level in the food system typically encoded with expanded traceability information like batch/lot or expiration date), the operator can start collecting traceability data that keeps them informed of exactly where each product is, facilitating faster and more efficient recalls and product freshness.

Impact of the Pandemic

Like many in the food industry, Buttner describes IPC’s pandemic experience as a major learning opportunity, helping them gain a better understanding into the gaps in their traceability program.

“We thought we were doing a really good job with traceability, but when the pandemic hit and we wanted to trace ingredients, we learned pretty quickly that we still had a long way to go,” he said.

He explained that tracing ingredients from pandemic hot spots like China and Italy early on was a challenge due to the quality of data being shared in the supply chain.

“Making sure that our suppliers and distributors are capturing good information all the way back to the very beginning of the supply chains is important, so that when things like this do strike, we have the information in our hands,” he explained.

Making Global Progress

Ultimately, Buttner said that the global nature of the supply chain can be an obstacle at times.

“We source product from every continent in the world except Antarctica. It’s always harder to hold partners to a standard that the US supply chain requires when regulation varies by country,” he said.

Buttner says they do their best to ensure that everyone in their strategic partner network is doing their job. “I believe that we’re making progress. This is what’s driving food safety, and this is driving a culture of traceability that our industry needs today,” he said.

For more resources on food traceability and how GS1 Standards support food safety, please visit www.gs1us.org/foodsafety.

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