Critical Tracking Events explained
The rule attaches records to seven events, not to whole companies. Each event has its own set of Key Data Elements, and one identifier, the traceability lot code, ties them all together down the chain.
A Critical Tracking Event (CTE) is a point in the supply chain where FSMA 204 requires you to keep records. There are seven: harvesting, cooling, initial packing, first land-based receiving, shipping, receiving, and transformation. At each one you record its Key Data Elements (KDEs), the specific fields the rule names. Which events apply to you depends on your role.
The lot code is the spine
Before the events make sense, hold on to one idea: the traceability lot code. It is assigned at initial packing, at first land-based receiving, and at transformation, and it travels with the food from there. Every shipping and receiving record carries it, so investigators can follow one lot forward and backward across every handler. If you take only one thing from the rule, make it this: capture and pass the lot code.
The seven events
Harvesting 1.1325(a)
For a person who harvests an FTL food. You record the location description for the immediate subsequent recipient, the commodity and variety, the quantity and unit, the location description for the farm where harvested, the field or growing-area name (or container name for aquaculture), the date of harvesting, and the reference document type and number.
Cooling, before initial packing 1.1325(b)
For cooling a raw agricultural commodity before it is initially packed. You record the recipient location, the commodity and variety, the quantity and unit, where it was cooled, the date cooled, the farm where harvested, and the reference document.
Initial packing 1.1330
The heaviest event, because this is where the lot code is assigned for a raw agricultural commodity. You record what you received and when, the harvest details (farm, date, field, and the harvester's business name and phone), where and when it was cooled if applicable, the traceability lot code you assign, the product description, the quantity packed, where and when it was packed, and the reference document.
First land-based receiving 1.1335
For a food obtained from a fishing vessel. The first land-based receiver assigns the lot code and records the product description, quantity, the harvest date range and location (such as a NOAA catch area), the landing date, and the reference document.
Shipping 1.1340
You record the lot code, the quantity and unit, the product description, the ship-to location (the immediate subsequent recipient, other than a transporter), where it shipped from, the date shipped, the lot-code source location or a reference to it, and the reference document. Critically, most of these KDEs must also be provided to the recipient, which is how the data moves down the chain.
Receiving 1.1345
The mirror of shipping. You record the lot code, the quantity and unit, the product description, the immediate previous source location (other than a transporter), where it was received, the date received, the lot-code source location or reference, and the reference document.
Transformation 1.1350
When you combine or change FTL foods into a new product. For each input you record the lot code, product description, and quantity used; for the output you assign a new lot code and record where and when transformed, the product description, the quantity and unit, and the reference document.
Which events are yours
You are only responsible for the events your role covers. A packer records initial packing; a distributor records receiving and shipping; a manufacturer records transformation plus shipping and receiving. The report maps your role to its events and gives you a fill-in template for each, so you are recording the right fields and nothing you do not need. See the full role-to-event map in our methodology.