Pilot Program

FSMA 204 Pilot Program

Please watch this video to learn more about PFT, these pilots, and how to participate! Participation is open to PFT members and non-members alike! Let’s Pilot Together!

About PFT Pilots

The PFT Pilots Committee works to identify challenges that industry is facing in implementing FDA’s Food Traceability Rule, to develop agreed-upon methods – in the form of pilot invitations – that industry can use to work on solving those problems.

Instead of coordinating the design and execution of individual pilots, PFT provides a consistent framework for pilot and reporting of pilot learnings to enable greater visibility and improved ability to compare learnings across pilots. The Pilots Committee facilitates comprehensive and consistent collection of individual pilot learnings to share those learnings with FDA and industry, with pilot participant consent.

Pilot participants may share their learnings on a PFT call, as well as post their learnings on the PFT resources page for the benefit of industry members across the supply chain.

Is your company conducting FSMA 204 implementation exercises? Consider sharing your learnings through one of PFT’s pilot programs! 

Learn more about our current pilot program below.

Why Participate?

Learnings from pilots may help inform industry and FDA’s continued implementation of FDA’s Food Traceability Rule.

Pilot 1: Lot Code and Lot Code Source Flexibility

The Partnership for Food Traceability (PFT) is inviting food companies to participate in a pilot program focused on practical approaches to Traceability Lot Code (TLC) and Traceability Lot Code Source (TLCS) implementation under FSMA 204.

Key Points

  • Companies who are completing TLC/TLCS pilots are especially encouraged to share their findings.
  • Findings can be shared via 1) PowerPoint template, 2) Word document using the PFT report template mentioned in the appendix of the invitation, or 3) companies can submit a report for PFT to create an anonymized general summary.
  • Companies can choose which audiences they would like the findings to be shared with, either 1) with PFT members only, or 2) publicly on the PFT website.
  • There are multiple deadlines for sharing findings.

Pilot Proposal for Lot-Level Flexibility:

Pilot 2: Industry Testing Electronic Sortable Spreadsheets

The Partnership for Food Traceability (PFT) is inviting food companies to participate in a pilot program to test their ability to complete an electronic sortable spreadsheet (ESS), Based on the requirement to share an ESS with FDA within 24 hours of a request during an investigation.

Key Points

  • This pilot provides a framework for companies to test their ability to generate accurate electronic sortable spreadsheets of applicable CTEs with accurate KDEs within 24 hours.
  • Companies can choose to test generation of the data using machine readable formats.
  • Companies can choose to have an anonymized or hypothetical version reviewed by the PFT Pilot Committee Working Group for educational feedback.
  • Findings can be shared via Word document using the PFT report template mentioned in the appendix of the invitation, or companies can submit a report for PFT to create an anonymized general summary. Companies can choose which audiences they would like the findings to be shared, either 1) with FDA only, 2) with PFT members only, or 3) publicly on the PFT website.
  • Participation in this pilot grants access to PFT Pilot Participant Office hours where interested companies can discuss current milestones and challenges related to Traceability Rule Implementation, as well as share results.

Pilot 3: Intercompany Data Sharing

The Partnership for Food Traceability (PFT) is inviting food companies to participate in a collaborative pilot program on interoperability.

Key Points

  • Companies will test their ability to send and receive accurate and timely Traceability Rule data in a feasible manner.
  • Companies can choose to measure the success of data sharing using PFT provided templates and example analysis questions.
  • Findings can be shared via Word document using the PFT report template mentioned in the appendix of the invitation, or companies can submit a report for PFT to create an anonymized general summary. Companies can choose which audiences they would like the findings to be shared, either 1) with FDA only, 2) with PFT members only, or 3) publicly on the PFT website.
  • Participation in this pilot grants access to PFT Pilot Participant Office hours where interested companies can discuss current milestones and challenges related to Traceability Rule Implementation, as well as share results.
  • Have the opportunity to test your system with your trading partners before the go-live date in 2028; this important milestone will allow for visibility into the current gaps that need to be addressed before the compliance date.

Completed Pilots:

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