Insider Knowledge on the FDA's Traceability Rule FSMA 204 and Its Implementation with Andrew Kennedy from iFoodDS | Episode 97

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Andrew Kennedy: In terms of the perception of the FDA is it's a huge organization, right? Which is true. There are a lot of people this morning. We heard from the presentation, 3, 500 people in the audit inspection area. But really when you look at the Foods Program, like the core people leading the Foods Program, it's not a large group.

So I think there's like between 50 and a hundred or so of the key leaders in the Foods Program that do a lot of the work. And so for example, the office of food policy and response that I was in 30 people

intro: And nobody likes getting sick That's why heroes toil in the shadows keeping your food safe at all points from the supply chain to the point of sale Join industry veterans francine elshaw and matt ragucci for a deep dive into food safety It all boils down to one golden rule don't Eat. Poop. Don't eat poop.

Matt Regusci: Hello, hello, Francine.

Hey, Matt.

We are at the Food Safety Consortium, and we have another amazing guest. He's amazing to me in multiple different ways. I've known Andy Kennedy for many years. He and I were partners together just recently at New Era Partners with iFoodDS. Helping consult people with FSMA 204.

Yeah, I truly love this man. He is a great person and I'm excited to introduce you to our audience.

So Andy, tell us a bit about yourself.

Andrew Kennedy: Thank you Francine and Matt for inviting me to the podcast, finally. How long have we been talking about this?

Matt Regusci: Literally Francine and I started this podcast the same day or maybe two weeks after we started together.

We had been working together for many years before that and other projects, but we started together at iFoodDS February 1st of last year. Two weeks later, Francine and I started Don't Eat Poop.

And you're right. You have never been on an episode.

Andrew Kennedy: No, no. Cause I needed plausible deniability. That was 100 percent correct.

Cause I needed to be able to tell my boss, I have no idea what this Don't Eat Poop thing is. I have nothing to do with it. And if I went on the podcast. It would be hard to claim that.

Matt Regusci: That is true. Literally, when I told Andy the name that we were creating for the podcast. And he laughed and then said, are you sure that's a good idea?

Francine L Shaw: So did Francine.

Andrew Kennedy: But it's on brand. It's on brand.

Francine L Shaw: Yeah.

Andrew Kennedy: But seriously, Matt, you are the wind beneath my wings.

Francine L Shaw: Oh.

Andrew Kennedy: You're the reason why we create New Era Partners.

Because when I came out of the FDA, I completely forgot what it was like to work in the real world, and you reminded me pretty quickly.

Matt Regusci: Yeah, I think it was like, Oh, we should create this company. We can go off on our own and all of these things. And then I was like, yeah, it's a great idea. Let's do that. We started putting everything together. And then I was like, Andy, are you sure we want to do a startup again? Or should we go pitch this idea to a bunch of companies?

Francine L Shaw: And then Matt calls me and says, Francine, we need to talk about Don't Eat Poop.

Matt Regusci: Probably the same week.

Francine L Shaw: And I'm like, excuse me, because I've got all this shit, excuse me, that I put together for Don't Eat Poop and all this work that we need to talk about this. I've talked to Andy and I'm like, what?

Andrew Kennedy: Well, Francine, you can see I got to name the company. Not Matt.

Matt Regusci: I think it was a collaboration. There was a whole bunch of different names that you sent over and I was like, why don't we put these things together? And then you were like, Oh, let's do this. New Era Partners was definitely, the created by you as the name and it was a really unique name. Why did you name it New Era Partners, Andy?

Andrew Kennedy: So going back to my time at FDA working with Deputy Commissioner Yiannas. So when I first started at FDA, this was October 2019, which is a great time to start working at the FDA, by the way, I have horrible timing. So yeah, so on a side note, I had all these suits, I got an apartment, I'm all geared up and ready to go.

And then three months later, COVID happened. I'm sitting at home, in my PJs, front of my laptop, no suit, suit's just hanging in the closet. Anyway, so bad timing on getting started. But when I first started at FDA, Deputy Commissioner Yiannas says, okay, and I was there for working on the traceability rule.

That's really what I was excited about, joining FDA. I'm like, this'll be awesome. We'll work on FSMA 204. That'll be great. And then Frank sits me down and says, "okay, Yeah, I know you're excited about the rule, but I got this other thing that I'm really excited about. It's called the New Era of Smarter Food Safety."

And I kind of waited a beat. I'm like, is he pulling my leg? We're going to do a rule and we're going to do a startup within the FDA? And I didn't think FDA was really big on startups. I had to wait for a second to see if he was going to laugh and say, just kidding. No, he's let's basically build a tech startup within FDA to talk about how technology and culture and other aspects of what he had learned in the food industry from Disney and from Walmart, what he could apply to the FDA and bring that culture into the FDA. So the New Era of Smarter Food Safety was really inspirational. And so I had the opportunity to co-lead Tech-Enabled Traceability under the New Era of Smarter Food Safety, and it just imprinted on my brain.

So when I came out, all I could think about was New Era. So that's where New Era Partners.

Matt Regusci: New Era, and then you and I are partners. So let's just tack that at the end.

Andrew Kennedy: I didn't say I was very creative. But I, at least I didn't put poop in the name.

Matt Regusci: Poop is a creative. You said that in like, grammar school.

Francine L Shaw: It's done well for us. It's done well for us.

Andrew Kennedy: All right. Fair point. So next startup. I'll let Matt name it.

Matt Regusci: Oh no. New Era Partners is doing good. It's doing really good.

Okay. So before you worked at the FDA and helped develop New Era of Food Safety and the FDA's Traceability Rule FSMA 204 before that you were at FoodLogiQ.

And so FoodLogiQ is now Trustwell. For those of you guys that know, and that's a huge traceability company and that's where you and I initially met, was my company was a channel partner for your company. What was the biggest difference in working in an actual technology company and a startup? I mean, you started, you were a co-founder of  FoodLogiQ.

What was the biggest difference in working in a technology company as a founder and trying to do something like that in the FDA?

Andrew Kennedy: Yeah, great question. So in terms of the perception of the FDA is it's a huge organization, right? Which is true. There are a lot of people. This morning we heard from the presentation 3, 500 people in the audit inspection area.

But really, when you look at the Foods Program, like the core people leading the Foods Program, it's not a large group. So I think there's like between 50 and a hundred or so of the key leaders in the Foods Program that do a lot of the work. And so, for example, the Office of Food Policy and Response that I was in, 30 people total, all in, everybody.

So it really did feel like a small company within a much larger organization, more of an intrapreneur kind of opportunity. And we had, since we had our leadership from Deputy Commissioner Yiannas, who was coming from Walmart starting up blockchain traceability at Walmart. And with a small group of people at OFPR we create like a little technology hub inside OFPR to start working on these things. So one of the projects that kind of came out of OFPR was looking at imported foods with AI. So we're on the AI thing a while ago. So that was 2018, 2019 working on AI to look at imports and use an AI filter to decide which imported seafood to inspect. So as you can imagine, you have a limited number of inspectors. But if you use AI to predict, and that was the name of it, predict which ones to inspect you can increase your efficacy. In fact, I think over 600% increase in efficacy using AI. Wow. So what we found is using technology tools, you can get more efficient with the same headcount.

So we applied that same idea inside the  Office of Food Policy and Response. We shadowed outbreak investigations and developed technologies that could help improve trace back investigations. And that's being launched now as the PTS that will come out from FDA and you'll be able to see these tools that were developed by FDA they're going to open source it. So that technology was incubated using the know how of the core team and the technology that had been developed within OFPR putting the two of those things together to create like a new idea, a new era of technology, as it were.

Matt Regusci: You have a lot of cool stories about the FDA during COVID because it was a crazy time for you.

Part of the role of the FDA came opening up supply chain, right? Is there any stories or anything you could tell about that you worked on during COVID that either was part of just original FDA or just something unique that had to happen that you guys did because of COVID?

Andrew Kennedy: Yeah, great question. So one of the things that we did during COVID was we created an outreach program to call, you know, firms in the industry that were being impacted by COVID.

So we had to develop a whole tool to analyze all the locations in the food industry and then predict, using that predict methodology, which ones we should call and ask how they're doing with COVID. And we had a series of questions where we capture information about what was going on the food supply chain.

And so we had a group of inspectors who were grounded because of COVID. So they couldn't go anywhere. So they were doing outbound calling and collecting all this information week after week. We started applying machine learning AI to the results and the data, and it was interesting what we were way out in front of.

So some of the things that we saw like food inflation. We started seeing the impact of food inflation because of different parts of the food supply chain being constricted because of labor issues because of availability. So we saw that happening early. So that was like 2020. We saw the kinks in the supply chain causing problems with availability of certain foods.

So we saw that early and we also saw the meltdown that was happening at the ports. So the port of LA became a huge choke point for imported food because just getting product off the ships became a real problem. So we saw that early detection. So it was incredible organizational effort to reach out to the industry, do outbound calling, collect the information, analyze it.

So that was... it was... I took that away to think about, like, how could we apply that proactively to enlarge organizations to manage giant supply chains and be proactive about what's going on in our supply chain. How can we be proactive and think about what are the risks and how do we analyze it and go out and get that data before something happens rather than wait for something to happen to your supply chain.

Matt Regusci: So when you saw that and you got... saw where those choke points were during COVID. What did you then do with that data? What were you able to were you able to implement any changes with that?

Andrew Kennedy: Yeah. So one example was there was a location that was being impacted by state and local officials because they didn't really understand the full impact of closing manufacturing facilities.

So for example, a canning facility, a facility that actually makes the cans that vegetables and fruit would go into. So they actually make the cans. Well, there are only a handful of facilities that make the cans. And if you don't have the cans, when you go to harvest the corn and the peas and the vegetables, If you don't have the cans, you have no place to put them.

And you can't just put them to the side and wait six or eight months. When you harvest fresh peas or fresh corn, literally, you have to put them in the can right away, retort them, and put them on the shelf. So if you don't have the cans, no canned food. And canned food is a really important element of USDA's food program.

So a lot of the food that USDA sources and sells and provides for low income households and for school lunch programs is canned. So we knew we had a limited window for harvesting, and if this canning facility couldn't produce the cans because the workers couldn't get in there and do their job, that it would have ripple effects and to the rest of the industry.

So prioritizing that with state and local officials to communicate to them the importance of keeping this facility open. You know, that was something that we did and outreach to those local officials and say, Hey, look, heads up. This is a very important facility for the food supply chain.

Francine L Shaw: Wow. No, no, I was, no.

Andrew Kennedy: I can't believe it. I left you guys speechless. Francine's actually speechless.

Matt Regusci: Sure, Francine's actually speechless.

Francine L Shaw: No, it's just something I would have never really thought about. Clearly it's important. Clearly, it's just not that, I'm sitting here thinking, why, why couldn't they freeze it?

But it doesn't work like that. I live on a farm, you know what I mean? So in my mind, well, if I can't can it, I'm going to freeze it. But the real world doesn't work like that. Manufacturing and processing doesn't work like that. So, yeah.

Andrew Kennedy: Yeah, and these facilities are giant and they really do all their harvests within a few weeks during the fall.

So right now those facilities may be doing pumpkins and then they'll be shut down in a month when it gets too cold. So yeah, it was interesting for me to learn about how the food supply chain really works when it breaks. That's when you saw like on the food service side when restaurants close all the demand for crops that were grown and specifically harvested for restaurant chains.

They have a different spec than retail. The onions are bigger, for example. So you have these giant onions because if you're a restaurant, it's great to have a big onion because less things to chop up. But if you're a retailer, you don't want a giant, you have an onion bag with three onions. Retailers don't want that. Consumers don't want that. So the specs are different.

So you had all this food that was grown for food service. That had a hard time finding a home in retail when retail had all the demand and food service had no demand. So like working with industry to allow relabeling a product and moving product from one industry to the other and making those connections. It was really interesting challenge and how you rewire food supply chains that have been like designed over time to be ultra efficient for getting food moved around the supply chain.

Francine L Shaw: Right. Well, and all those restaurants that weren't open, you know, like you said, that food had to go someplace, right?

Andrew Kennedy: Yeah. Yeah. It's so it was, I learned a lot in that process about all the impacts, the ripple throughs. It's like Jenga bricks, you know, you pull one brick out and the whole thing falls apart.

So our food supply chain is a lot like that. You take out one little brick. Just happened in Western North Carolina with the hurricane that came through. There's like ultra pure silicone that's used in semiconductor manufacturing comes from this, like one little town in Western North Carolina, and that plant was destroyed.

And so I think 60 percent of the pure silicone was no longer available. So that has ripple through effect to the semiconductor industry. So we, we have these choke points. So we don't find out about until something bad happens. So my learning was like, how can we be proactive and think about those things ahead of time?

And I think, you know, AI machine learning, but also traceability data will help highlight visually you can see where those choke points are.

Matt Regusci: So you were in industry and tech industry too.

Then you went into the government for a few years and then you went back into industry. A lot of people listen to our show are career food safety people.

What would you advise to them if they're thinking maybe I should go into the government for a little bit. Do you think that was helpful for you to go into the government for a few years? And should other people do it? We hear about just career bureaucrats in there, right?

Andrew Kennedy: So what I found out my personal journey, you know, being out in the tech world, doing startups and not having that government experience, I really enjoyed seeing what it's like to actually be work within the government.

And some of the things I learned because we had to work on the traceability rule. The lawyers, the public health people inside the FDA really taught me a lot about how these rules are created. And then doing comment response, comment response, you learn a lot about the world from reading 2000 different comments about the traceability rule, good and bad.

But what I found out was how passionate people are about traceability. Which I didn't fully appreciate until we went through that process. Just how many people are invested in the effort around creating a traceability rule. And so that kind of opened my eyes like, oh, this is a big deal. This rule, we haven't had a traceability rule since the bioterrorism act of 2002.

And honestly, the world had a bigger fish to fry back then. So the traceability rule didn't make any waves and if people didn't pay as much attention to it. But this time around, I think FDA did a great job of communicating more like a business does with a product launch. Really get the information out there, get the resources out there.

So I think Frank and I helped infuse the effort with a little bit of that marketing savvy. Let's get the information out there. And then I certainly learned a lot in understanding the implications when you create a rule, the things you have to think about. Whereas in a small company your impact is so small you can try different things and see if they work, when you're writing a rule you can't iterate. Like, you get one shot at it and that's it. It is locked down.

Once you've published that final rule. That is it. It's gonna stay that way for a long time and so changing my mindset from iterative development, the move fast and break things model to you gotta get this right, you have one shot at it. It changes the way you think about something, the way you communicate, the words you use.

So, that was really good discipline for me in thinking about the implications of what we're doing.

Francine L Shaw: So, that one line we were talking about in Chicago that the FDA needs to write in, one shot with that one line they got to get it right, because if they mess it up.

Matt Regusci: We were at an FDA conference, like a local regional FDA conference.

A few weeks ago, and we did a talk on stage. I said that the FDA could change the industry instantly by writing in one legislation to be the FDA could be most likely should be Congress. Congress passed a law that says all regional municipalities and states have to implement the newest edition of the FDA code for food safety at its minimum, and that would be it. That would be one law written up, and the FDA wouldn't have to take years to do it. It's already done it.

Francine L Shaw: One line could fix it all. One line. Just one line could fix it all.

Andrew Kennedy: It sounds so easy.

Francine L Shaw: And we were solving the world's problems up there, the U. S. 's problems up there, in one line. We had it.

Andrew Kennedy: Absolutely. It was funny, like the working groups, like I've been in a lot of working groups. GS1 working groups, PTI working groups, been in a lot of working groups. There is something different about a rule writing working group within the FDA because you really do have that sense like we write this rule, we get it done, we get the comments, we update it, publish it, and then this thing is going to be locked down for a really long time.

So the dialogue in a working group like that. People question every word. They think about the ramification, the cost, the implication for this part of the industry. Bring in subject matter experts from every part of the food industry to evaluate it and say, all right, what haven't we thought about? So Francine, that's what you need to do with your one line.

You need to bring in all the people that will be impacted by that and ask them the question. If we say this, what happens? I pull this Jenga brick, what happens? Do we still have the structure or.

Francine L Shaw: Impacts everybody differently? Yeah, and everybody's gonna look at it differently and all the viewpoints are different.

Andrew Kennedy: Yeah, absolutely but it's so valuable having that 360 feedback from a bunch of different resources telling you, okay, if you say this, this is all the downstream ramifications that it has for our niche of the industry. So anyway, learn so much from that process and that feedback. And you don't get that in a startup.

It's just like Matt and I going, Oh, that looks good. Press send. It's just one line. Just, publish. Publish.

Matt Regusci: Publish. Publish. Yeah, and then everybody's like, that's terrible. Why'd you do that? I don't know. Matt told me to do it. Hey, Matt, change it. Let's change it. We can change it now. Let's change it.

Francine L Shaw: AI.

Andrew Kennedy: That's right. Yeah.

Matt Regusci: That's kind of how we started New Era Partners.

Andrew Kennedy: No, we didn't have a very rigorous decision making process.

Francine L Shaw: What do you prefer? Government or private sector.

Andrew Kennedy: I prefer private sector from the standpoint that well, especially being there during the pandemic. It's a very stressful job, and it's especially during the pandemic because we didn't have travel, so we didn't have face to face interaction.

So my personal experience, it was very isolated. So because we weren't in White Oak, we weren't in the main office anymore. We were just at home. So it was a challenging environment and the day never ended. Like, it started early and went super late and it was very focused because we had the rule. We had New Era Smarter Food Safety and we had the pandemic.

We're doing all three at the same time. So there was just a lot of work in that time span. So I am a little bit jaded by that, you know, experience. So I'm sure now it would be totally mellow and cool, but that time window was extremely stressful. So.

Francine L Shaw: When he says by the pandemic, 100%,

Matt Regusci: when he says extremely stressful, I want you guys to know that when he and I were working together, there was a time of four months where you were on the road almost every single week between Meeting with clients, our prospects, talking at shows, providing client reports on supply chain traceability stuff, like non stop, and so to be more stressful than that is pretty fascinating.

Andrew Kennedy: Yeah, no. I'm having fun. Implementing the rule is a lot of fun.

Matt Regusci: Yeah, so okay.

We've talked about New Era Partners, but what are you doing now with New Era Partners and iFoodDS? And how are you, because really we were on the forefront and now you're continuing it on being on the forefront of implementing this rule that goes into effect January 20th, 2026.

What are you doing and how is the industry reacting to it?

Andrew Kennedy: So what's been great is Natalie Hunter stepped up and is leading New Era Partners. She's the managing director. So I could spend more time with the product team. So I have the opportunity to be the first product team being like, iFoodDS. Yep.

And so I'm the chief traceability officer and I swear to God, Matt, I think I'm the first chief traceability officer ever. So I don't think that another one exists. I haven't found one on LinkedIn. So we invented that job title of chief traceability officer specifically for FSMA 204 and for the development of the traceability product at iFood.

So I've been fortunate enough to work with the product team now developing out the software to handle FSMA 204 and build it out to handle a massive supply chain rollout for our customers. So I've built a whole bunch of traceability systems. So you'd think I'd get it right by now, but I learned a lot from the way we built systems at FDA.

Because that idea of scale and security and permanence that we got at FDA, like I brought that to the table to understand how do we infuse a startup with that sort of rigor and scale and security. So it's a little bit different than the last time I did a startup around food traceability where there really were no guidelines, there were no critical tracking events, there were no key data elements, we were making it up as we went along.

Now there's a little bit more structure, a little more rigor, you know what the target is, you know that data is going to be used by FDA, you understand the use cases better, so it's a different effort, but I find it's great because when you go into a client now, they understand what you're talking about when you talk about traceability.

There's a common language. Everyone understands, okay, what are the shipping KDEs? Great. Go through them. And they're not asking what's the traceability lot code anymore. They understand what traceability is all about. So it's changed the conversation a lot having the rule there and being a tech provider into this space.

It's a lot easier conversation. I'm not spending all kinds of time explaining why they need traceability. Now it's, Okay, how are we going to implement traceability, which is a totally different space than when I started traceability in 2006.

Matt Regusci: When we first started with New Era Partners, we were trying to even talk to the warehouse management systems and the ERPs of how this is going to affect their business and how they're going to be able to talk to their clients as they're moving things forward and backwards and all that stuff.

Over the last six months, has that changed? There've been a big direct shift in now you're talking about a common language where now it's more ubiquitous and those software is becoming easier to implement?

Andrew Kennedy: So things have gotten easier in terms of explaining how to share data with each other. So those standards are firming up.

So people are getting a pretty good idea. Okay. I need to share information with my trading partners. So that's getting firmer. What the challenge that we're running into now is the identifiers for products. People are actually having to like scan or use IOT or RFID, but there are a lot of different options and a lot of different technology out there.

So what people are struggling with now is, okay, we're going to do this for a long time. How are we going to mark our cases? Are we going to scan? Are we going to calculate? There's different ways of getting the data from the product itself into the software. So that bridge right now, getting from the physical layer into the digital layer, that is the challenge industry struggling with right now and at huge scale.

So think about the produce industry ships six billion cases a year. That's a billion with a B. That's a lot of cases to mark with an identifier. So the transition, we started years ago with PTI, we started that in 2008. And there are only 4 billion cases marked with PTI labels today.

So there's still 2 billion cases not marked. So that gives you an idea of how long it takes to adopt that. So now the seafood world, the CPG world, the cheese world, the egg world, they have to do it in a year. So it's just unbelievable amount of change in a short period of time for a bunch of industries.

So that's also been a fascinating journey to think about. Again, like with the rule itself, when you make this decision to adopt this data carrier or that data carrier, it gets adopted by billions of cases a year by all these companies and everyone has to scan and capture that information. So that transition from no scanning, no data capture at the case level to rolling it out across the industry.

It's a real challenge, but it's not required by the rule. But what we're finding is a lot of retailers and food service operations are moving towards it. So now it's, okay, how do we do it? So we're in that, how do we do it phase. Which is unbelievably exciting, but also it's daunting. It's because it's such a big problem.

Francine L Shaw: So how do we do it?

Matt Regusci: Yeah, Andy, how do we do it?

Andrew Kennedy: It's easy. Just call me.

Francine L Shaw: We can do it.

Andrew Kennedy: It's easy. Yeah, we just call Matt. Matt makes it happen.

Matt Regusci: We call Matt. Matt would call Andy and he would make it happen. I still remember when you and I were working on a big, like trying to get a big project and they are trying to figure out what a consultant was working on them with this big project.

And the consultant said to this huge company, I don't want to say who they were. There was a couple options. And the consultant was like, why are you considering going with someone who's read about the rule instead of someone who helped write the rule? And that's a huge different value proposition that you brought to New Era Partners and iFoodDS was you didn't have a conceptual knowledge of the rule, you were in the trenches writing the damn thing.

Francine L Shaw: That is an excellent selling point. That is an excellent selling point.

Andrew Kennedy: Well, it depends on how you feel about the rule.

Francine L Shaw: I mean, clearly they were interested, right?

Andrew Kennedy: I've heard both opinions.

Francine L Shaw: Always know your audience.

Andrew Kennedy: The way it was written, it's non technology specific, so that way everyone can play.

So, hopefully the... over time, it will become like, like GFSI. No one talks about how hard it is to implement a GFSI-based quality management system or food safety management system. It just happens. No one complains about it anymore because at first when GFSI was rolled out, it was a big deal and people complained and it was hard, but now it's just how people do business.

And then FSMA came along and supported the effort and codified it. So then it became just how the food industry does business. But when I started in 2006, people didn't have like true quality management systems. They had inspections and they had audits and stuff like that, but they didn't really have kind of your traditional quality and food safety management system based on like ISO principles. Like that didn't exist. GFSI introduced that in what, 2007? And now it's just how we do business. So I think that's where traceability will be in five, six years, where it will just be how people ship product.

And if you don't do traceability, you'll be an outlier. So I think the transition happens quickly. There's like a tipping point where you go from no one does traceability to everyone does traceability. And then if you want access to markets, you have to do it. So.

Francine L Shaw: So this isn't the first time you've been to the Food Safety Consortium.

So tell me what you like about the Food Safety Consortium and what would you change?

Andrew Kennedy: Okay. First thing I would change is get that escalator working.

Francine L Shaw: I know like what the hell I walked up the escalator.

Andrew Kennedy: I have so much trouble walking up and down an escalator. That's not moving. I don't know what it is. I don't know.

Matt Regusci: It's so funny. Rick, who owns this conference, he was super excited about us asking this identical questions we did last year. Yeah. And he said, people are going to complain about the escalator.

Andrew Kennedy: He was right. Yeah. It freaked me out first time I went down it. Going up is okay. Going down is weird. But anyway, escalator definitely change.

What I like about it. I just came out of a giant trade show last weekend that, you know, the global produce show, and that thing is so big that you, it's hard to find the people you're looking for. What's great about this is in 10 minutes, I saw 20 people I knew and was able to quickly say hi to everyone. And they weren't running like from one side of the building to the other, a giant building.

It's everything's right here. So you can have more meaningful, quick conversations with a whole bunch of people you haven't seen in a while. So that's why I love it. It's like really compact. And then you have to go down the escalator without it moving.

Francine L Shaw: And so I'm sure you guys are taller than I am. And these steps, those escalator steps are deep.

You wouldn't notice that, but they are.

Andrew Kennedy: Well, Matt is 6'6" so he does have trouble on this, right? Yeah. People don't know that because this is a podcast. That's super tall.

Francine L Shaw: I was walking up with a guy this morning. This is why this is a conversation and we were talking about the escalator not working and how deep the steps were. And then we get to the top and the top three steps are like four inches.

Matt Regusci: Okay. Andy, thank you so much for your time. That was fun. This is a lot of fun and this is why we love doing and we're going to be here again next year because Rick invited us again next year and this is why we love doing podcasts here is because the value of the people here are just incredible like yourself but we do have some advice for you.

Don't eat poop.

Andrew Kennedy: I will try not to Matt. Thank you very much, Francine.

Insider Knowledge on the FDA's Traceability Rule FSMA 204 and Its Implementation with Andrew Kennedy from iFoodDS | Episode 97
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