A conversation with Provision
🎧 Listen to the full interview in the audio player below, or read on for our key takeaways from their conversation.
Chapters
Full transcript is at the bottom of this page
00:00:00 Introduction and overview of FSMA 204
00:00:43 Kevin Davies introduces Provision
00:02:12 Why Kezzler partners with Provision
00:02:59 Challenges in the produce supply chain
00:06:21 Digitization and compliance solutions
00:11:34 Tools and strategies for growers
00:18:10 Data sharing and interoperability
00:23:45 Focus on pack houses
00:25:46 Key success criteria for traceability programs
00:28:27 ERPs vs. specialized traceability tools
00:30:31 Conclusion and future collaboration
How can produce suppliers and retailers meet the upcoming FSMA 204 traceability requirements while streamlining their operations?
The Food Safety Modernization Act (FSMA) Section 204 will bring some critical changes to the produce industry. With compliance deadlines approaching, growers, packers, and retailers are working to implement digital traceability solutions. These solutions are intended to not only meet regulatory requirements, but also enhance food safety and supply chain transparency.
To answer the above question, our very own Frederic (Fritz) Clulow, GM of the Americas at Kezzler, sat down with Kevin Davies, CRO at Provision, to discuss how the industry is preparing for FSMA 204.
They explore the role of digital solutions in overcoming common compliance hurdles, as well as:
- The biggest challenges growers and retailers face in meeting FSMA 204 compliance
- How digitization and data-sharing streamline traceability
- Why pack houses are a critical piece of the compliance puzzle
- How interoperability between solutions like Provision and Kezzler helps unify traceability across supply chains
The full transcription of the interview can be found at the bottom of the article.
The compliance challenge: FSMA 204 and the produce supply chain
FSMA 204 mandates end-to-end traceability and requires detailed, standardized recordkeeping for high-risk foods, but many growers, packers, and retailers are still figuring out how to comply.
Why is this so difficult?
- Data capture and standardization: The industry lacks a common approach to recording and sharing traceability data.
- Pen-and-paper workflows: Many growers still rely on manual recordkeeping, making it difficult to track and share data in real-time.
- Diverse and fragmented operations: A single supply chain often involves multiple tools and systems that don’t communicate with each other.
“When we see some of the clients that we work with today who have hundreds of growing operations under centralized packhouse umbrellas, really, I think that the data sharing and having unified data standards between those operations could be the greatest complexity that these operations face as they move into implementing solutions this year.”
– Kevin Davies, Provision
One of the biggest hurdles is ensuring pack houses—which play a pivotal role in consolidating traceability data—are fully equipped to meet compliance standards.
“Where we really see as the area for focus in the produce supply chain is the pack houses. A lot of the pack houses that we’ve seen haven’t yet necessarily started their implementation for FSMA 204. But they’re really a key point of custody in the traceability chain because they’re generating the TLC.”
– Kevin Davies, Provision
Frederic echoed this challenge, noting that even large enterprises struggle with standardization.
“The real challenge with FSMA 204 is that there is no single approach that works across the board. A retailer, for example, might get a thousand shipments from different suppliers, and every single one might have slightly different data formats. It’s hard to build a system around that unless you have true interoperability.”
– Frederic Clulow, Kezzler
The role of digitization and data management in compliance
Moving from paper-based records to digital systems is essential for FSMA 204 compliance, but the process is not always straightforward.
Kevin explained how Provision helps growers, packers, and shippers digitize compliance data and integrate FSMA 204 compliance and traceability into their existing food safety and sustainability programs.
“Many of them are already doing harvest logs for Primus GFS or Global Gap, or whatever it may be for their food safety program. So really, it’s just a question of, ‘How can you integrate FDA-required key data elements into existing records so that you have the cleanest possible execution, effectively unifying traceability with food safety and sustainability requirements?’’”
– Kevin Davies, Provision
Why is digitization critical?
- Reduces manual errors in data entry
- Enables real-time record-keeping for audits and compliance
- Creates a single source of truth for all traceability data
By transitioning from manual data collection to automated, digital systems, companies can reduce manual errors in data entry, improve compliance efficiency with real-time recordkeeping, and enhance food safety transparency with a single source of truth for all traceability data.
“Digitization is what makes compliance not just easier but also more valuable. If companies can leverage their FSMA 204 compliance data for operational improvements, that’s a win-win.”
– Frederic Clulow, Kezzler
Why collaboration and interoperability matter: Kezzler and Provision
No single platform can fully handle FSMA 204 compliance alone. Traceability requires multiple systems working together, which is why the partnership between Provision and Kezzler is so valuable. Provision and Kezzler’s solutions work together to unify data across multiple systems and stakeholders.
By integrating Kezzler’s traceability platform with Provision’s compliance tools, supply chain participants can:
- Ensure seamless data-sharing between suppliers, packers, and retailers
- Enable API-based interoperability instead of relying on outdated, batch-based EDI systems
- Unify data across fragmented operations to provide end-to-end traceability
“Kezzler, we think, is a best-in-class platform to unify data for many platforms. I think that it’s important to think downstream that there will be many traceability tools that need to connect together. You never see one tool that’s used throughout the chain. Even within one operation, you might see different tools used for receiving the transformation. So I think that having the ability to connect the API to a platform like Kezzler to get a single view can be a critical way to combine data across a network into kind of one easy place to conduct a trace back.”
– Kevin Davies, Provision
It’s perhaps redundant, but crucial to keep stressing the importance of interoperability—the industry is moving away from outdated batch processing methods.
“We’re not in a world where EDI and batch data transfers can keep up with the speed of modern supply chains. Real-time, API-driven traceability is what companies need to actually make FSMA compliance functional.”
– Frederic Clulow, Kezzler
Final takeaways and next steps
As FSMA 204 deadlines approach, companies in the produce supply chain need to take action by:
- Standardizing data collection: Implementing consistent data formats across suppliers and packers.
- Digitizing compliance efforts: Moving away from manual recordkeeping to integrated software solutions.
- Ensuring interoperability: Partnering with solutions that seamlessly connect through APIs to provide a holistic traceability view.
📢 Want to learn more? Listen to the full conversation above or dive into the full transcript below.
📞 If your company is preparing for FSMA 204 compliance, get in touch to discuss how Kezzler and Provision can help.
You might also find this interesting
- Our eBook “From compliance to opportunity: FSMA 204”
- Our blog “FSMA 204: A catalyst for supply chain digital transformation”
- Our blog post “EPCIS 2.0 and the interoperable future”
- Learn more about how GS1 standards simplify integrations
Chapters
00:00:00 Introduction and overview of FSMA 204
00:00:43 Kevin Davies introduces Provision
00:02:12 Why Kezzler partners with Provision
00:02:59 Challenges in the produce supply chain
00:06:21 Digitization and compliance solutions
00:11:34 Tools and strategies for growers
00:18:10 Data sharing and interoperability
00:23:45 Focus on pack houses
00:25:46 Key success criteria for traceability programs
00:28:27 ERPs vs. specialized traceability tools
00:30:31 Conclusion and future collaboration
Full transcript of the conversation
00:00:00 Introduction and overview of FSMA 204
Fritz: Kevin, thank you for joining me today. I think the topic du jour, of course, is the Food Safety Modernization Act, Section 204. So, I think what we want to do today is be able to go and try to understand a little bit what FSMA 204 really means within the produce space and how that connects, I think, to a big piece of the puzzle.
Which is grocery retailing, right? How do we go about getting data feeding that data, not only in, in homogenizing that data set, not only for the producers, but also eventually for the retail space.
But before we start, I want you to be able to introduce yourself and for those who are not familiar with you and the great work that Provision has been doing, if you could give us a 30,000-foot view of what Provision does.
00:00:43 Kevin Davies introduces Provision
Kevin: Yeah, thanks for having me, Fritz. FSMA 204 is a big topic. It has been for years, but I think that there’s a lot of organizations in the produce supply chain shifting from analyzing requirements to actually implementing solutions this year.
So it’s timely for us to talk through some of the challenges they’re facing and how we can build a better solution for the produce supply chain.
So yeah, my name is Kevin Davies. I’m the CRO at Provision. I oversee our sales and marketing groups here. And Provision is a compliance software that’s used for data capture, largely in the produce supply chain. Our core usage, where we really founded the company, was in food safety.
So we helped growers, packers, and shippers to digitize their food safety programs for daily record keeping and SOP management, largely tackling their GFSI certifications. So Global Gap, SQF, Primus GFS, and the likes. What we found is that in the produce supply chain, we started getting pulled into traceability early on.
As well as some of the other compliance requirements faced by growers, packers, and shippers, like IPM and sustainability. So traceability has been a part of the fold for us for years and was actually, you know, core to how the company was founded.
Eric, our CEO, actually founded Provision when he won the Maersk food track competition. Maersk is the largest food shipping company in the world, and Eric helped to design their compliance solution for traceability back in 2018.
00:02:12 Why Kezzler partners with Provision
Fritz: Wow, that’s great. And for those of you who are not necessarily familiar with the relationship between Provision and Kezzler: we operate more on an abstracted layer—we are not part of the execution layer. Kezzler itself, really—if you want to think about things—is on the data fusion side of things so that we will connect into different platforms and then be able to ingest that data and connect information that is traditionally siloed within the industry to be able to present a single source of truth.
And this is why we work with companies like Provision. To be able to acquire information upstream, particularly in the produce divisions, so that we can then connect that to transactions further down downstream without the transformation process—supply chain and logistics transactions—and be able to present a unified whole to the brand owner.
00:02:59 Challenges in the produce supply chain
Fritz: But I’m going to throw you a little bit of a curveball here because FSMA 204 is fast approaching, right? We’re really, if we want, a year away. And what we are seeing is that there’s definitely a lot of companies that are still trying to make sense of FSMA 204. Some are just getting started with things.
How do you see the space in produce and retail being ready for the compliance deadline?
[00:03:24] Kevin: Well, I think that there was some wishful thinking for years that, you know, perhaps we would see further deadlines. So, you’re right that it is time to take action for groups who haven’t already done so. I would say that thinking of it in the produce supply chain within any 1 operation, the data requirements don’t seem too challenging. But it’s really when you look at it from a network perspective that the complexity comes in.
So when we see some of the clients that we work with today who have hundreds of growing operations under centralized packhouse umbrellas, really, I think that the data sharing and having unified data standards between those operations could be the greatest complexity that these operations face as they move into implementing solutions this year.
[00:04:13] Fritz: One of the challenges that we definitely see is along the data management side and data management capture, right? I mean, this is an industry— and I think this is true, whether you’re dealing with cucumbers, you’re dealing with peanut butter bars and confectionery, or more sophisticated products—there is a dearth of digitization, right?
And for a solution like ours, obviously we need to have a digital layer to plug into to acquire some of this information. And by and large many of the operations— not going to say all of them— but it is not unusual, I would say, to see operations running on pen and paper. Right? What does that look like?
And, and, you know, you hinted at this, but what does that look like within, let’s say, upstream the produce space?
[00:05:01] Kevin: Well, I think that the challenge in the produce space is how highly regulated they are already. So, comparing a grower to a manufacturer, there’s really much more red tape around the growing operations today.
So if I put myself in the shoes of our California leafy greens clients, they need effectively like a prescription written for them to apply any inputs to their land. These are called RECs. And they need to basically convert these prescriptions for their pesticides and herbicides into product usage reports that they submit to the county.
They need to do testing for residual limits. They get additional inspections from the California leaf greens marketing association. They have audits for their food safety certification, and now they have new requirements for integrated pest management and sustainability. You know, we’ve seen one of our clients, the largest blueberry operation in North America, get asked for scope three emissions reporting.
So really, they already have layers upon layers of requirements. And I think that’s the challenge for produce—how do we add one more thing to that mix? And I think to your point, traceability is a bit of the straw that broke the camel’s back when it comes to pen and paper, because there’s much more sharing of data that’s required for FSMA 204 compliance.
00:06:21 Digitization and compliance solutions
Kevin: I think that the operations who have figured out how to get by with antiquated systems for other types of compliance, they’re now looking to bring the whole system into a digital solution.
So I think that when we think of what’s the best execution for, you know, produce growers, packers and shippers, I really think that they need to firstly start by taking the Venn diagram of overlapping requirements.
Many of them are already doing harvest logs for primus GFS or global gap or, you know, whatever it may be for their food safety program. So really, it’s just a question of: how can you integrate FDA required key data elements into existing records so that you have the cleanest possible execution, effectively unifying traceability with food safety and sustainability requirements?
[00:07:12] Fritz: That sounds great, I think, in theory, but in practice, right? So I’ve now been to many farms as have you, right? And we’re dealing with an environment that is not necessarily the most permissive for digital solutions due to reasons ranging anywhere from the skill set, language barriers, connectivity barriers, lack of infrastructure…
So how do you bridge that gap between: I have an operation and I am growing a specific set of produce, and now I have this additional requirement and in essence is, well, it doesn’t mandate digitizing my information— it is very much pushing me to do so. And I have all this other set of requirements that I’ve been managing with whiteboards and paper and folder…
And now I am forced to find a way to unify all this, but I am stuck because I have a limited workforce, limited skills, and language barriers. How do you resolve all that?
[00:08:10] Kevin: Yeah, you’re totally right. Produce growers face not only the most regulatory requirements and compliance challenges, but also the most challenging infrastructure to actually execute these solutions.
We like to think of challenges to digitization in three different segments.
When you look at the food traceability list, you’ll see commodities that are commonly grown by indoor growers: the tomatoes, the cucumbers, you’ll see commodities that are commonly, you know, just harvest-only outdoor growers, i. e. they’re not field packing.
But then you see commodities that are commonly field packed by outdoor growers, you know, like leafy greens that would be grown in Arizona, and that kind of is the spectrum from least to most challenging. A lot of the indoor growers that we work with, you know, the Local Bountis, the Muccis of the world, they actually have pretty strong infrastructure in place.
They have year round label at labor that tends to be domestic. They have decent connectivity. They’ve got, you know, tablets already deployed in their facilities.
So the indoor growers are really poised for success and traceability, and some of them have already solved it years ago. But as you move kind of across that spectrum, I mentioned towards, you know, field pack outdoor growers, really what we see there is a lot of H-2A labor where there’s language barriers.
There’s short term seasonal contracts that create a perpetual training challenge. Oftentimes they’re operating in like Internet deserts where we don’t even see Starlink deployed at critical mass yet.
There’s a big connectivity challenge, and oftentimes we’re not yet seeing a lot of penetration for hardware. So you see that some of the staff are expected to capture data on their own phones, which might be years old. So even when you put yourself into the scene of what it’s like day to day, they might be operating in a high glare environment while they’re moving with sun reflecting on their screen, like just the actual physical challenge of just having good data entry is really high.
And I think the added complexity is that for a lot of these field pack outdoor growers, there’s also no IT team. So there’s a big question of, you know, how can they properly structure their data? How can they properly share their data? Assuming that there’s no professional resource who can set that up for them.
So I think that all of this creates a high standard for not only the software that is deployed, but also the services that surround the software to, you know, help with data structuring, = create connectivity for, for data sharing, even advise some of the hardware choices and ultimately train the teams who are going to be using the solution in field.
I think all that’s required to actually overcome some of these barriers.
[00:11:06] Fritz: That’s great. And, and, I think it bears saying that in the U. S. we get produce from a very diverse array of countries, right? And we’re having those challenges here in the U. S., but as well, we source produce from Mexico, Latin America, Asia.
So what tools does Provision have, to enable growers to overcome some of those challenges, some of those barriers in terms of language and being able to have a workforce that can operate and digitize their data?
00:11:34 Tools and strategies for growers
Kevin: Well, where we start with Provision is by acknowledging the importance of configurability.
So the FDA has required key data elements. They do not require what records those key data elements could live within. And so at Provision, what we do is we really build each client workspace custom to their own food safety program. So that there’s as seamless of a transition as possible between their paper records and their new digital solution.
We really want to look to have a high level of continuity between the data they’re already capturing, they’ve already successfully deployed for years to achieve their certifications and compliance so far. We want that to be, you know, as similar as possible to their FSMA 204 solution.
So the first step for us to have a successful deployment is unifying compliance programs, and that’s unifying food safety records with traceability records and IPM or sustainability records.
What we then look to do is then have a highly, highly usable suite of tools that work like guardrails around those familiar records. So some of the guardrails that we look to deploy are task tracking. So you’re able to create very clear assignments in Provision with deadlines that link directly into the corresponding record that has to be completed.
And those can go to either individual assignees or they can go out to teams. Teams is a really popular way to ensure there’s no missed records. You might not know which person is going to show up for a certain shift within the harvest crew, but you can assign a task to your harvest crew and ensure that a traceability record is done and it will automatically move into an overdue status for a manager if it’s missed.
So managers can have peace of mind that they’re not missing critical tracking events for FSMA 204.
Once the operators actually enter into those records, we really put ourselves in the shoes of a non-technical ESL temporary worker and ensure that they have enough in-app guidance to actually complete a record they’re seeing for the first time. Which might, by the way, be inside the first ever enterprise software they’ve ever used.
So one of the big themes for us is having live SOP guidance. I used to oversee a crew of workers who were doing about 3000 records a month. And the challenge that I had in that operation is that we were training them on dozens of policies and procedures, and they would forget about half of them by the time they’re actually doing record keeping.
So what we’ve done at Provision is kind of flipped the paradigm. Instead of SOPs living in a binder on a shelf, which ultimately just leads to guesswork, we actually interlink the company’s policies and procedures with their record templates. And what that allows is anytime a worker is inside a record, they can view the corresponding guidance while they’re in the task.
So the nice thing is that you can have the reinforcement that’s required of what data to capture, where to find it, how to be compliant, without them needing to visit binders or go back to the field house and ask their manager.
Translation is also a key theme for us. We see that there’s often many different languages that are spoken in the field. Provision is built to hook into Google Translate, so there’s 109 supported languages that can instantly flip.
So data can be captured in someone’s native tongue, but brought back into English for an auditor and manager or any other language that might be required for review.
What we then focus on is the data structure. So we’re able to configure Provision so that things like locations or varieties can be auto filled, and we can actually automatically convert native language to structured data.
So an example is, global location number might be a really good way to structure location data for referencing the field that it was harvested in. But you wouldn’t actually want people to have to memorize global location numbers. So in Provision, you’re able to use native language. Like maybe you’re in field A, block 1, row 1, and that’ll automatically convert to a GLM.
We’re able to do a similar thing for actually automating TLCs. You could integrate Provision with GS1 if you wanted to use a GS1 128. Or, you know, alternatively, we can produce our own globally unique IDs in the application using the data in the records. And then all of this kind of fits within rules.
So you can set rules in Provision that will automatically prevent incomplete submissions. And you can also set soft limits that might actually just flag data that is out of compliance or typo, whatever it may be.
So at the end of the day, what this does is it gives managers the peace of mind that they can have independent crews out for an entire day’s harvest, producing clean, compliant data that they can flow through to the pack house without needing to do a lot of manual review and, you know, binder flipping.
Fritz: I think that’s great. I think the fact that you have an application that is in many ways reactive to the environment and the operating procedures in place, I think will greatly facilitate a lot of that data acquisition. I love that you mentioned GS1. I’m going to do a shameless plug here. Absolutely shameless.
To whoever is listening to this, if you have not taken a look at the GS1 implementation guidelines for FSMA 204, I highly recommend it. They’re incredibly helpful.
Of course, FSMA 204 does not mandate any particular standard, any one set of symbology, but the GS1 workgroup has done a tremendous job pulling together ideas and concepts and frameworks within which companies can deploy a tool for compliance, but that sort of brings me into another topic, right?
Because GS1 is all about making data interoperable. I have my data and I give you the means to access that information, you know, read what’s on the label through a barcode, but also be able to share information through EPCIS and things like that. And we’ve touched upon the upstream, the farms, the growers, the producers.
But many times they don’t work in isolation, right? So they’re part of a bigger chain and whether that chain feeds into a transformation process, a production process, or whether that feeds into (directly) retail, it becomes essential to be able to share information between different parties. In many ways that is the universe we exist in, right?
So Kezzler in itself is really meant to aggregate transactions and information and data points from different sources, different operations, and be able to coalesce them into a single source of truth to provide one click traceability.
00:18:10 Data sharing and interoperability
Fritz: But can you provide some view as to how you work with companies like Kezzler to be able to transact information and be able to provide that unified view?
[00:18:21] Kevin: Yeah, you know, the sharing of data is a critical part of FSMA 204. One of our clients is a major retailer that has more than 2000 locations. And when you put yourself in their shoes, you know, they’re wrangling data from tens of thousands of suppliers. And it’s really important that data’s structured in a way that it can flow all the way downstream without breaking the chain of traceability.
In our work with that retailer, we like to have two complementary approaches. The first is a digital sharing of data through ASNs that goes through the distribution center into the way that our application is used for their transformation.
But in complement to that, we always need to plan for, you know, what if there’s direct to store distribution? What if there’s an error in the distribution center data? How can we have physical labeling to actually support the lack of digital data? And I think that, to your point Fritz, GS1 labels are a really good way to ensure that we have the persistent ability to scan data in if it’s not digitally transacted in advance.
So we also think that GS1, it can be critical for having globally unique IDs. As you know, there’s more and more products that float down to retailers, the likelihood of someone having the same product or variety on the same date harvested or whatever. We see simplistic TLCs fail if they’re not globally unique.
So I think that GS1 really has a best in class paradigm.
In terms of how we think of data sharing, you know, EDI is an option. But the challenge with EDI is it’s, it’s using FTP protocols from the seventies and it’s scheduled in batches. Like it’s really not the most modern approach to data sharing. It’s slower. It’s harder to maintain.
So at Provision, we like to lean into API connectivity when we can, which enables real-time data sharing, which is much more dynamic and easier to maintain. So we are able to use APIs to connect into other tools. Kezzler, we think, is a best-in-class platform to unify data for many platforms.
I think that it’s important to think downstream that there will be many traceability tools that need to connect together. You never see one tool that’s used throughout the chain. Even within one operation, you might see different tools used for receiving the transformation. So I think that having the ability to connect the API to a platform like Kezzler to get a single view can be a critical way to combine data across a network into kind of one easy place to conduct a trace back.
[00:21:03] Fritz: Yeah, we definitely see a multiplicity of data sharing options and that in many ways is how we built our platform. We knew that depending on the industry and the level of maturity of a specific company, you’re going to be dealing with different standards, right? In some case you may have EDI and as you mentioned, I think EDI really was developed in the 60s, matured in the 70s, was applied in the 80s, and we’ve been dealing with it ever since, right?
So it’s fairly outdated. It was not necessarily designed for the structure and amount of data that we’re being asked to share nowadays, right? And however it is, by far, I think the workhorse of supply chain data inter exchange.
We’ve seen this in pharma, where if you think back 20 years ago, the mainstay was EDI and they’ve slowly transitioned into EPCIS, which is another standard.
It’s a GS1 standard. Now we’re at EPCIS 2. 0, but the industry is still dealing with EPCIS—or pharma, I think, is still dealing with EPCIS 1. 2—and I think its implementation is pretty much non-existent within food and bev. You know, with maybe a few outliers here and there, but predominantly people are still relying on EDI.
But now I think there’s also this black hole where there’s no EDI, there’s no EPCIS, there’s maybe not even API connectivity—it’s still people dealing with spreadsheets. So how can you take some of that information and make sure that it’s accessible?
That’s also something that we’ve prepared for where we have a specific layer, it’s called API gateway, that allows us to, in essence, act as a universal translator, regardless of whatever method you’re using for sharing data and be able to essentially eventually translate all that into EPCIS.
But I wanted to ask for your experience, because you mentioned this retailer. The retail space and food and bev, I think, have had to deal in the past with PTI. I think PTI had (I’m maybe mistaken, but I believe had) some expectations of having some EDI components to get along with standardizing some GS1 nomenclature.
But how do you see the upstream feeding into the retail industry, is retail ready to acquire that information from producers, and is the infrastructure ready for what’s to come with FSMA 204?
[00:23:21] Kevin: You know, what we’ve seen is that the retailers in many cases appeared to be the first to act on FSMA 204. What we’ve seen is that largely a lot of retailers are at the very least in pilot stage right now. Some are already midway through their implementation.
So I think that we’re seeing solutions come together at retail, and it’s to be determined what the failing points and some of those systems are.
00:23:45 Focus on pack houses
Kevin: Where we really see as the area for focus in the produce supply chain, is the pack houses.
A lot of the pack houses that we’ve seen haven’t yet necessarily started their implementation for FSMA 204. But they’re really a key point of custody in the traceability chain because they’re generating the TLC. And in many cases, you have single pack houses who might work with dozens, if not hundreds of growers.
So they are really a point of consolidation for data that is directly having to wrangle growers who might have the hardest implementation ahead of them. So they’re perhaps taking the least technically ready stage of the supply chain and needing to enforce compliance in those networks.
We really focus on these packers and, you know, answering the question: how can we give you network wide visibility into your compliance every day?
We want to ensure continuous market access for a pack house, ensuring that they’re covering not just the traceability requirements, but other data that’s required to flow from their growers. Be that sustainability data or food safety data.
So I think that packers are really the key thing for the industry to focus on solutions for looking into Q1 and Q2 of 2025.
[00:25:04] Fritz: Yeah, absolutely. I think that every single limitation has, if you want, a point of failure, so to speak, and I think within this discussion a lot of that, as you hinted, is the pack house because they do consolidate a lot of the product flow.
One of the things I like about Provision obviously is that we’re not only dealing with complying with FSMA 204, but you’re encapsulating everything into the wider FSMA world in terms of quality assurance and food safety, and being able to have a platform that consolidates all of that. So it’s not just a traceability rule, but it’s really the wider FSMA 204.
So you have a platform that allows you to look at things from multiple different angles.
00:25:46 Key success criteria for traceability programs
Fritz: If we go back to the growers or producers, what are the top three things that they should really be on the lookout for when implementing a traceability program?
[00:25:58] Kevin: I would say that the first is usability. We’ve seen some tools that have the capability to ingest traceability data, but they’re far too complex to put in the hands of, you know, a field worker. This is where we see some ERPs or WMSs fail. And I think that there’s a misconception that tools that work at a distribution center can be deployed upstream for data acquisition.
In many cases, any degree of complexity will cause an adoption failure in the fields, and so usability always comes first for us.
The second theme is configurability. I think that a common failing is to have one tool for sustainability, and a different tool for food safety, and a different tool for farm management, and a different tool for trace.
And when you think of having to flip yourself between six, seven different platforms on a farm or in a pack house just to achieve compliance, you’re really introducing a lot of complexity in terms of training your team, but really a lot of separate failing points when you think of maintaining and integrating systems.
Not to mention that it can just be more expensive. So we can, you know, really lean into a focus on configurability to ensure that we’re unifying those food safety traceability and sustainability requirements, which really share a lot of common data requirements.
So what is the lightest possible touch that you can deploy to consolidate data? I think that configurability is key to do that.
And then the final thing that we take a look at as a success criteria is, how is the solution delivered? There are SaaS solutions that work for major customers with IT teams, where you can effectively give them a product and walk away.
This tends to not work in the produce supply chain. We really see services as a key part of enabling success for 204. So, you know, how can we configure a tool? How can we structure the data? How can we set up the data sharing for clients? Can we actually go in field and train those teams?
Having that kind of service delivery that is localized in the native language, boots on the ground, can make a huge difference in actually having these tools adopted and reconfigured, you know, after the management set up so that they actually suit the way the data needs to flow throughout the operation.
[00:28:21] Fritz: You said something that piqued my interest. That was gonna be my last question, but you made a comment that I thought was very intriguing.
00:28:27 ERPs vs. specialized traceability tools
Fritz: And that has to do with ERPs.
Obviously, in the space that we play in being an enterprise level traceability provider, oftentimes we come in contact with ERPs and companies thinking that they can deploy an ERP to their traceability.
In many cases that may be true. Our argument, and I think we’re not the only ones making this case, is that ERPs are a great tool, but people tend to take them as a multi tool. And when you’re a tool that does many things, you never do one thing excellently well, right?
And we are a platform that is bespoke and completely purpose-built for high volume, high throughput traceability. That’s what we do.
And ERPs have different functions and you’re in essence trying to fit a round peg into a square hole when you’re trying to take ERP into the track and trace world. But that is a conversation that I expect to have because of the environment we sit in.
But you said that you’re also seeing some brand owners trying to push an ERP down at the field level, did I understand that correctly?
[00:29:28] Kevin: Yeah. Yeah. And I think that to your point, it can be misguided in certain applications because of the complexity of ERPs. Which, you know, tend to really excel in back office use cases and struggle when they’re used on the move.
So I really think that while ERPs can be configurable enough to add a traceability module, you know, maybe it’s off the shelf, maybe it’s bespoke. I think that where we see the failing point is, is just the usability.
And to your point, are they designed to guide compliance? So are there, you know, calendars that could actually integrate all the task tracking that you would need for not just your trace, but the food safety data that complements it?
Is there in-record guidance? Do you have, kind of, the review workflows? And, does all of this land in the equivalent of a binder that you can use for an audit? I think that those are some of the challenges that we see with ERP implementations.
[00:30:28] Fritz: Yeah, absolutely. We see very much the same.
00:30:31 Conclusion and future collaboration
Fritz: With that, Kevin, thank you so much for your time. We are extremely excited about the possibilities of our partnership between Kezzler and Provision. This is definitely a topic that has come up very frequently in many conversations, and the way we see the world is that FSMA 204 is about cooperation and collaboration between multiple platforms.