The United States House of Representatives (HR 2749) is called the “Food Safety Enhancement Act of 2009” is apparently not without its problems. No one is speaking out against the bill, although "the proposed implementation worries some because it assumes equal responsibility for everyone along the food supply chain, particularly food warehousing companies and 3PLs, whose sole responsibility is to store the finished products." The complete article is accessed at:

http://www.foodlogistics.com/publication/article.jsp?siteSection=8&id=3051

Overall, this argues for a cloud-based solution to food safety. A cloud evens out reponsibilities, since all signed up for the cloud agree to share data, responsibilities, etc. Costs are distributed fairly, as parties can pay according to numerous factors--not only responsibility, but for example relative profit, relative risk, etc. This may help to address the following concerns:

"Other concerns in the industry point to the House bill’s overly broad traceability requirements and the introduction of civil monetary penalties for things like record keeping errors that could carry fines up to $250,000 for each violation. Furthermore, new fees include a registration fee of $500 per facility and another $175,000 per company, which is significant for companies with a number of facilities."

To address, simultaneously, concerns relating to record-keeping, auditing, track and trace, and potential fines, one solution that satisfies Occam's razor is a cloud-based approach, where the auditable data and associated risks are shared across the supply chain. Fines in this scenario are far less likely, since non-compliance is more difficult to hide, and more rapidly ameliorated.

Cheers,

Steve