Service memorandum FD-TR-01
FSMA 204 Seafood Traceability Data Review
A defined review of key data elements, traceability lot codes, and representative receiving-to-shipping records for seafood processors and distributors. The review identifies missing fields, inconsistent identifiers, and broken lot links.
The initial engagement covers one United States site, one product family, and up to ten representative lot journeys. Activities and possible exemptions are checked before the sample is accepted.
Regulatory note
FDA states that Congress directed the agency not to enforce the Food Traceability Rule before July 20, 2028. Coverage still depends on the food, activity, and available exemption. Those questions must be checked for each operation.
FDA Food Traceability RuleReview schedule
The sample is set before records are transferred. Sanitized material moves through an agreed channel after the statement of work and NDA are in place.
| Work item | Issued at completion |
|---|---|
| Coverage questions | A record of foods, activities, and possible exemptions requiring specialist review. |
| Field mapping | A source-to-output map of key data elements, critical tracking events, and traceability lot codes in the sample. |
| Lot-link review | A missing-data and broken-link report with assigned owners. |
| Work estimate | One agreed sample output and an estimate for implementation work. |
Limits of the engagement
Excluded services: facility audit, legal opinion, FDA approval, emergency response, and findings about activities outside the agreed sample. The client remains responsible for its records, decisions, and regulatory duties.
Working method
- Scope confirmationConfirm the site, product family, operating activities, systems, sample size, and responsible contacts.
- Sanitized intakeReceive the agreed record sample through an approved channel after contract and NDA review.
- Record examinationMap source fields to outputs, follow representative lot links, and record unresolved questions.
- Findings meetingReview missing data, owner assignments, correction work, and the proposed next scope.
Continuing record work
The review measures work that may remain after software is installed. A continuing agreement would state its sites, supplier volume, exception volume, response time, and technical review schedule.
Operating work considered
- Supplier record onboarding and follow-up
- Data checks and unresolved exception work
- Output preparation and trace exercises
Working commercial assumption
US$3,000 per month for a defined service schedule. That figure remains a test assumption until buyer discussions and delivered work establish a support level.
Technical oversight
The offer, sample limits, activity questions, public claims, and delivery scope require written approval from a named seafood traceability professional before paid work begins.
Initial inquiry
Request a scope discussion
Send basic operating information only. Do not attach supplier pricing, credentials, employee details, or live production records.