The Partnership for Food Traceability (PFT) will host an in-person workshop Sept. 9-10, 2026, in Washington, D.C., focused on lot-level tracking and preparation for FSMA 204.

The interactive workshop will bring together food supply chain stakeholders to explore implementation challenges and practical solutions related to capturing, maintaining and sharing traceability data. Discussions will also address interoperability, reducing data exchange friction and approaches that support both regulatory requirements and business needs.

The workshop will be held at Leavitt Partners’ offices, beginning at 11:30 a.m. on Sept. 9 and concluding by 2 p.m. on Sept. 10. FDA participation and remarks are anticipated throughout the event.

Registration is complimentary, but space is limited. Register by Aug. 31.

Learn more here.

Product recalls and safety failures frequently harm businesses beyond the company responsible for the problem. Here’s an example: the wave of children’s-product recalls in 2007 helped prompt the Consumer Product Safety Improvement Act’s broadly applicable testing and certification requirements, imposing compliance costs across the children’s-products industry. Empirical studies also find that automobile recalls can reduce supplier firm value and sales of nonrecalled models of the same brand, while seafood recalls temporarily reduce purchases of unrecalled brands of the affected species.

These effects are generally described as economic “category spillover” or “product-harm spillover.”  For the U.S. economy, fresh produce, however, may represent the most important example of “product-harm” spillover because domestic growers can simultaneously experience an immediate collapse in demand, destruction of perishable crops, reduced near-term planting schedules and continuing food-safety costs, even when an outbreak is traced to an imported product.

The 2022 hepatitis A outbreak associated with strawberries imported from Mexico provides a clear quantifiable example. Although California strawberries were neither implicated nor recalled, in a Western Growers report, we estimate that California growers lost approximately $125 million in wholesale revenue during the five weeks following the U.S. Food and Drug Administration’s (FDA) initial public-health advisory. Prices for conventional and organic strawberries fell nearly 30 percent beyond what could be explained by normal seasonal and supply conditions. The losses were especially impactful because the advisory was issued near the beginning of California’s peak strawberry season and initially did not clearly identify the strawberries as imported.

The current (2026) Cyclospora outbreak profoundly demonstrates the severity of spillover effects for domestic fresh produce. Although a portion of the outbreak was associated with iceberg lettuce from Mexico, California growers supplied most of the lettuce available during that period. Nevertheless, the most recent data released from Numerator estimates a loss of roughly $280 million in consumer spending on fresh produce for every month that concerns regarding Cyclospora continue. The same poll estimates that around 6.5 million households stopped buying salad mixes and kits in July, and per-household spending was down 10.7 percent. California growers reportedly destroyed approximately one-third of harvest-ready lettuce crops, laid off workers and experienced canceled orders during the first active weeks of the outbreak.

Fresh produce is particularly exposed because it is often marketed as an interchangeable commodity. Consumers recognize “lettuce,” “strawberries” or “cantaloupe,” but usually do not know the grower, growing region or country of origin—particularly when eating in restaurants or purchasing processed or mixed products. Although federal country-of-origin labeling applies to covered fresh and frozen fruits and vegetables at qualifying retailers, restaurants and other foodservice establishments are exempt, as are commodities incorporated into processed foods. When a public-health communication identifies a commodity without clearly identifying its origin, supplier, brand and distribution period, a lack of clarity pushes many consumers to avoid the entire category.

Unlike automobiles, toys or other durable products, fresh produce cannot be held until consumer confidence returns. Crops are planted months in advance, harvested within narrow windows and rapidly lose their value. When demand disappears, growers must accept sharply lower prices, leave crops unharvested or destroy market-ready food. Thus, consequences extend to farm workers, processors, cooling facilities, distributors, shippers and rural agricultural communities. Even a relatively short advisory can eliminate an entire season’s profit.

Negative economic spillover impacts also include domestic growers bearing food safety expenses, such as enhanced audits, testing, training, equipment improvements and other compliance costs that may not be imposed consistently (or at all) on foreign growers (even in the foreign region and with the commodity that was associated with an outbreak or recall). If the responsible foreign farm and importer (region or country, when applicable) do not face equivalent investigation, corrective-action and verification requirements, domestic growers suffer a double economic penalty: they absorb the market losses caused by the imported failure while continuing to finance a more demanding prevention system.

If these spillover effects are not addressed, consumer consequences will extend beyond temporary shortages. Repeated, broadly communicated outbreaks can erode trust in entire produce categories and encourage consumers to purchase fewer fresh fruits and vegetables. This is particularly concerning because federal nutrition policy continues to include objectives to increase fruit and vegetable consumption, while research associates inadequate consumption with greater risk of chronic disease.

As a result of continued consequences of negative economic spillover, consumers also face reduced choice, less reliable domestic availability and higher long-term prices. Growers confronting repeated losses may plant fewer acres, avoid open-market production or be forced to shut their doors. Reduced domestic capacity would further increase reliance on imported produce, compounding the situation. USDA estimates that imports already supplied approximately 59 percent of U.S. fresh-fruit availability and 35 percent of fresh-vegetable availability in 2023, compared with 50 percent and 20 percent, respectively, in 2007.

This creates the potential for a self-reinforcing cycle: imported-product failures damage domestic producers; domestic production contracts; import dependence increases; and future failures from foreign operations expose an even larger share of the domestic food supply.

Reducing the impact of economic spillover on domestically grown fresh produce does not mean withholding information from consumers but does require providing better information more quickly. Public health communications should identify country of origin, growing region, supplier, brand, distribution channel and affected dates as soon as the evidence permits—and promptly correct any earlier speculation. Traceability and regulatory accountability must extend through importers to foreign farms and packing operations as required by law. Without these improvements, blameless U.S. growers will continue to bear the economic consequences of imported-produce failures, while consumers ultimately bear the larger costs through improperly managed food safety regulatory oversight, declining confidence, reduced consumption, diminished domestic production and greater dependence on imported food.

Independent outbreak investigations could improve accountability and public trust, but the model will fail without authority, deadlines, funding and transparent recommendation tracking. 

Foodborne outbreaks expose a structural weakness in the American food safety system: responsibility is distributed, but accountability is not. The Centers for Disease Control and Prevention (CDC) coordinates much of the epidemiology; the U.S. Food and Drug Administration (FDA) and the U.S. Department of Agriculture (USDA) regulate different foods; and state and local agencies perform essential interviews, testing and inspections. When an investigation is delayed, inconclusive or wrong, however, no single institution owns the failure to learn. 

Former FDA Deputy Commissioner Frank Yiannas has proposed an independent National Foodborne Outbreak Investigation Board modeled on the National Transportation Safety Board (NTSB). It would investigate across food categories, operate outside agency silos and political pressure, publish clear lessons and use modern data tools. Industry could contribute records and expertise, but the board would retain independence and final judgment. The concept deserves serious consideration. 

The NTSB analogy matters most after a finding is made. NTSB recommendations are advisory, but recipients are asked to respond within 90 days—30 for urgent recommendations—with completed or planned actions and a timetable. Open recommendations require milestone updates or at least annual reporting. NTSB reviews the evidence and publicly classifies the response as acceptable or unacceptable; regulators separately turn selected recommendations into enforceable requirements. Applied to food safety, that process, theoretically, could keep outbreak lessons from disappearing into agency files. 

The Case for an Independent Board 

The greatest advantage is independence. A board that does not also write and enforce food rules could ask whether regulators, companies, laboratories and public health agencies performed as they should. A unified investigation could cross the FDA-USDA boundary, examine failures in surveillance and traceback and distinguish immediate outbreak control from deeper root-cause analysis. Public reports and a permanent recommendation database could reduce premature attribution, show who accepted or rejected corrective action and give consumers and affected businesses a common factual record. 

The model could also improve prevention. Recommendations might address equipment design, sanitation, agricultural water, laboratory methods, traceability, recall execution, risk communication or interagency procedures. A 90-day response requirement would not force agreement, but it would force an accountable answer. FDA, USDA, CDC, states, manufacturers and operators could propose alternatives, while the board judged whether those alternatives achieved the safety objective. 

The Case Against a Simple Transplant 

Food outbreaks are not airplane crashes. There may be no preserved scene, identifiable moment or physical wreckage. Food is consumed or discarded; symptoms may appear days later; records can be incomplete; ingredients cross jurisdictions and borders; and many investigations never identify a vehicle. Creating another federal body could duplicate existing efforts, slow urgent decision-making or create institutional conflict over who leads while people are still becoming ill. 

Nonbinding recommendations are another limitation. Transparency can generate pressure, but it cannot replace enforcement. Equipment changes, new testing, training and traceability systems cost money. Who pays—the manufacturer, operator, grower, retailer, government or consumer—will depend on whether an action is voluntary, contractual or mandated by regulation. Without a regulator’s compliance deadline and inspection authority, a recommendation could remain open for years while the underlying hazard persists. This becomes even more complicated for outbreaks involving imported foods, where an independent board’s ability to investigate, provide transparency and pursue on-site follow-up may depend on foreign governments and actors beyond U.S. jurisdiction, especially if the board’s recommendations are nonbinding.  

Build the Follow-Through Before Building the Board 

Yiannas’s public proposal has not yet answered the decisive design questions. What case count, death, duration or public-interest threshold triggers an investigation? Does the board lead during the emergency or begin an independent after-action review? Can it compel records, samples, testimony and foreign-facility access? How will confidential business information, candid industry participation and victims’ legal rights be protected? Who funds investigations and corrective actions? Must agencies respond within 90 days, maintain annual updates and explain missed deadlines? What evidence is required before a recommendation is closed? 

Congress should pursue the idea, but conditionally. The board should have a narrow investigative and prevention mandate, not duplicate recall or enforcement functions. It should have statutory access to evidence, defined launch criteria, a public recommendation database, 90-day responses, annual updates and explicit classifications for acceptable and unacceptable action. Regulators should remain responsible for converting safety findings into enforceable rules and checking field compliance. Independence without follow-through would create reports. Independence with authority, clocks and public accountability could create learning.  As food safety leaders such as Frank Yiannis consistently remind us, if we continue to repeat our same fragmented approach to outbreak investigations, we can expect the same unsatisfactory public health outcomes absent the necessary progress in prevention to protect consumers in a rapidly changing global food supply.