Vertical Trace Exercises in Food Safety:
- M. DuBose
- 7 hours ago
- 6 min read
How to Apply Them During Internal Audits
Vertical trace exercises are becoming a key expectation across FDA, USDA, and GFSI-benchmarked certification schemes. As the industry shifts towards better digital traceability and the Food Traceability Rule (FTR) (FSMA Section 204(d) compliance, companies need to show they can trace a product both forward and backward. When we talk about traceability within a process, companies must be able to trace a finished product, ingredient, packaging, through every step of their process. This involves linking ingredients, processing steps, equipment, personnel, packaging, and distribution into a clear chain that can be verified.
“A vertical trace is more than a paperwork drill. It is a clear look at how well your team understands the life of a product from the moment it enters your facility until it leaves your door.” ~ Debby Newslow
Debby often reminds teams that traceability is not just a theoretical exercise. It is a real demonstration of how well a facility knows its own processes. A vertical trace exercise is one of the best tools for showing that understanding.
What Makes Vertical Trace Exercise Different
A traditional traceability test focuses on one step forward and one step back. It answers two questions:
Where did this come from?
Where did it go?
A vertical trace exercise goes further. It explores the entire internal journey of a product. It connects raw materials to finished goods by following the product through each stage of production. This includes batching, blending, equipment use, sanitation status, reworking, packaging, labeling, storage, and distribution.
A vertical trace exercise is not the same as a mock recall. A recall simulation tests communication and response during a crisis. A vertical trace exercise checks the integrity of your records and your process flow.
“When you can trace a product through every step of your own process, you prove control. You also prove that your documentation reflects reality, which is the heart of any strong food safety system.” ~ Debby Newslow
Why Vertical Trace Exercises Matter in 2026
FDA’s Food Traceability Rule (FTR or many times referred to as FSMA 204)
The Food Traceability Final Rule requires standard recordkeeping for foods on the Food Traceability List (FTL). It highlights Key Data Elements (KDE) and Critical Tracking Events (CTE). The rule aims to help quickly identify sources of contamination and respond faster to outbreaks. The FDA's New Era of Smarter Food Safety initiative promotes digital traceability as a basic requirement for the future of food safety.
Traceability Expectations Across GFSI -Recognized Schemes
GFSI-recognized certification programs such as SQF, BRCGS, FSSC 22000, GLOBALG.A.P., PrimusGFS, Canada GAP, and IFS all share a common purpose. They are designed to ensure that certified sites maintain a traceability system that can quickly and accurately track materials and finished products throughout the supply chain. While each program has its own structure and terminology, the core expectations are consistent because they are all benchmarked to the same GFSI requirements.
Across these programs, certified sites are expected to maintain clear identification of materials, link production records to lot codes, and demonstrate the ability to trace products forward and backward. Facilities must also be able to complete a traceability exercise within a reasonable time frame and show that quantities of materials and finished goods can be reconciled. These exercises typically include raw materials, work in progress, finished products, and any rework or processing aids used during production.
GFSI-recognized schemes also expect organizations to verify their traceability system on a routine basis. This usually involves conducting a documented test that includes mass balance, reviewing how information flows through the process, and confirming that records are complete and accessible. The goal is to ensure that, in the event of a withdrawal or recall, the site can quickly identify affected product, determine where it went, and provide accurate information to regulators, customers, and supply chain partners.
Although the specific wording may differ from one program to another, the intent is the same. A certified site must be able to demonstrate control, transparency, and timely access to information. This alignment across GFSI recognized schemes helps create consistency for global supply chains and supports the industry’s ability to respond effectively when traceability information is needed.
CDC and USDA‑FSIS Lessons Learned
CDC outbreak investigations consistently show that incomplete or inconsistent traceability records slow down response efforts. USDA-FSIS stresses the need to link production records to specific lots to support rapid traceback in meat and poultry investigations.
How to Conduct a Vertical Trace Exercise
A vertical trace exercise should feel like walking the product through your facility from start to finish. It is a structured review of how well your documentation reflects reality.
Select a Finished Product Lot
Choose a lot that is not recent. Debby often suggests selecting something from three to six months earlier. This prevents the exercise from becoming a memory test and encourages using records.
Trace Backward Through All Inputs
Identify every raw material, ingredient, processing aid, and packaging component used in the batch. Verify supplier lot codes, receiving records, COAs, and storage conditions. Make sure that the quantities used match production records.
Trace Vertically Through the Process
This is the key part of the exercise. Follow the product through each internal step. Examples include batching, blending, thermal processing, cooling, metal detection, packaging, and labeling. Check equipment logs, sanitation records, calibration checks, and personnel assignments. Debby often says that a vertical trace reveals whether your process flow diagram truly reflects what happens on the floor.
Trace Forward to Distribution
Identify all customers who received the finished product. Confirm shipping records, bills of lading, and any transportation controls.
Reconcile Quantities
This is a major focus for GFSI benchmarked food safety standards auditors. Inputs must match outputs with reasonable allowances for yield loss.
Document Findings and Opportunities for Improvement
Record the time taken to complete the exercise. Note any missing records, inconsistencies, or unclear documentation. Debby's approach emphasizes using these findings as teachable moments rather than failures in compliance.
What Auditors Will Be Looking For
Third Party Auditors (i.e., GFSI guidelines, USDA-FSIS, and FDA investigators) look for similar elements during a vertical trace exercise.
Record Accuracy and Completeness
Auditors expect records to be clear, complete, and linked by lot code. They will check for gaps in documentation and inconsistencies between departments.
Time to Completion
Depending on the Food Safety Standard or Regulation, typically auditors expect a full traceability exercise to be finished within four hours. With today’s technology, this is a fair requirement.
Quantity Reconciliation
Auditors will verify that the amount of raw material received matches the amount used and that finished product quantities are reasonable.
Alignment With FTR Requirements
Even if your product is not on the Food Traceability List, auditors increasingly expect facilities to understand Key Data Elements and Critical Tracking Events. The industry is moving toward digital traceability, and auditors will ask how your facility is preparing.
Evidence of Internal Verification
Typically, auditors will want to see that vertical trace exercises are part of your internal audit program, not just an annual requirement.
How Vertical Trace Exercises Strengthen Food Safety Culture
Vertical trace exercises help teams grasp the full life cycle of a product. They show how decisions in one department affect another. They reinforce the importance of accurate documentation and build confidence. When a facility can smoothly complete a vertical trace exercise, it shows control, competence, and readiness.
“A good vertical trace shows you what is working. A great one shows you what needs attention. Both are valuable, and both move your program forward. Keep in mind we do not want to wait until a real emergency/recall to identify flaws in our processes and systems.” ~Debby Newslow
Debby often says that traceability is a mirror. It reflects the true state of your system. A strong vertical trace exercise demonstrates that your team knows its process and can prove it.
Sources
Safe Quality Food Institute. Traceability Rule and FSMA 204 resources.
FDA. Tracking and Tracing of Food and FTR (FSMA 204) Final Rule.
HACCP Wise Consulting. How to Conduct a Traceability Exercise for SQF and BRC Compliance.
CDC Outbreak Response and Prevention Branch.
USDA‑FSIS Guidance on Product Tracing and Recall Support
Comments