The Future of FSMA Compliance Is Powered by AI

1906 was a bad year to be a butcher.

It had been twenty-three years since Otto von Bismarck banned all American pork products from Germany, with France, Italy, Spain and more following. Using trichinosis as a pretext, the Pork War highlighted an early example of the new pressures a globalized economy could introduce as one of America's biggest international markets shut it out completely. American pork exports to Europe fell from roughly $70 million to $43 million.

More locally, this was also the year of The Jungle.

With unfathomable, horrific stories set inside the Chicago meatpacking stockyards, Upton Sinclair's novel was turning public opinion against the consumption of meat en masse. It wasn't just the journalistic storytelling, but the dark mirror it turned toward capitalism in America was causing people across the country to question where their food came from, often for the first time in their lives. More tangibly for the Chicago packers, Germany and France reinstated bans on American meat.

And where some sought to reflect and consider the future of the industry, others saw an opportunity.

Regulation favors the incumbent

Since 1906, there's been a darkly consistent pattern in the American food supply chain: wrongdoing is exposed, lawmakers react, and small producers close:

• Ralph Nader's "We're Back in the Jungle" in 1967 pivoted the lens to USDA transparency, which led to Lyndon Johnson's Wholesome Meat Act addressing slaughterhouse standards to address the nearly 10,000 slaughterhouses in America. Fifty years later, we had ~2,758.
• In 1993 Jack in the Box introduced E.coli to the American public. The answer was HACCP - for meat that means taxpayer-funded USDA Food Safety & Inspection Service (FSIS) inspectors monitor slaughter production, with additional rules added in 2007 to restrict plants from paying for their own inspectors, essentially starving out small plants where the public didn't want to justify the spend.

Outside of food, this trend continues with GDPR, Dodd-Frank, Sarbanes-Oxley and more.

The latest of these is FSMA - the Food Safety Modernization Act. The nuance here is that FSMA is an FDA-led act, while HACCP and the Wholesome Meat Act were USDA-focused. While the USDA's methods tend to lean on physical presence of inspectors, the FDA is primarily using record-keeping, transcription and audit logs to achieve their goals.

This is where food producers should be looking to apply AI as a no-brainer solution.

Centralize and Automate

Any business who manufactures, processes, packs or holds food for consumption has to register with the FDA and follow FSMA guidelines. These guidelines include:

"Food facilities are required to implement a written preventive controls plan. This involves: (1) evaluating the hazards that could affect food safety, (2) specifying what preventive steps, or controls, will be put in place to significantly minimize or prevent the hazards, (3) specifying how the facility will monitor these controls to ensure they are working, (4) maintaining routine records of the monitoring, and (5) specifying what actions the facility will take to correct problems that arise."

There is also an impending new rule - FSMA 204:

"The Food Traceability Rule requires persons who manufacture, process, pack, or hold foods on the Food Traceability List (FTL) to maintain and provide to their supply chain partners specific information – called Key Data Elements – for certain Critical Tracking Events in the food's supply chain. … All records required under this rule, along with any information required to understand the records, must be made available to the FDA within 24 hours after a request is made (or within a reasonable time to which the FDA has agreed)."

This is slated to go into effect in 2028, and depending on the FDA's level of enforcement threatens to be a massive risk for businesses, especially smaller ones who don't have the means to hire full-time internal team members for auditing and record-keeping purposes.

The FDA said as much themselves:

"some small firms may incur annualized costs that exceed one percent of their annual revenue"..."[this] will have a significant economic impact on a substantial number of small entities."

There has been no shortage of well-meaning observers calling attention to this, most recently in the published “The New Era of Tech-Enabled Traceability”: Tensions between the FDA’s Data Governance Vision and the Lived Realities of Food Producers, where they correctly call out that producers are:

"...transformed into data workers tasked with maintaining granular compliance with complex informational infrastructures alongside their existing professional responsibilities."

Which is all correct...though I don't understand how this paper was written in 2026 without acknowledging AI as the leading solution to the core problem the article is centered around.

I've been implementing operational solutions across the food supply chain for years, and January 2026 is about when AI solutions finally become reliable enough to not just be a hypothetical solution, but clearly the best one by a mile. Every day I hear about workers shaving off hours from tedious, manual data entry workflows, and solutions I've implemented work the first time in a way that still shocks me to this day.

When transitioning existing workflows to this new paradigm, I take the approach I call centralize and automate. The change management flow I follow generally looks like this:

• First - the scope of responsibility needs to be as narrow as possible. If you have multiple associates, analysts and operators who all share in the manual data entry work, the transition will be easier if there is one person who has the full scope of the task being automated.
• Second - give the person responsible the tools or support they need to create the automation they need. Sometimes people will naturally pick up the AI-native tool kit and can run with it themselves, other times they benefit from a forward-deployed engineer supporting them.

The end result is that the owner of this process should now be empowered to scale their work dramatically with tools designed specifically for their working style. That's the amazing part that makes people rave about these tools - software that was previously far too expensive and niche to be viable is suddenly available to anyone.

In the past year I've built workflows for:

• Lot Record automation
• Product Formulation Statement generation
• Bill of Lading capture
• Weights / grades / processing notes transcription
• Farm / Plant / Warehouse communication automation
• Vendor quality reporting
• Production & yield analytics

And many other solutions addressing billing, pricing, sales and more. I'll write more about these in the future.

We're still in the earliest innings of what these tools are capable of, but this may finally be the moment where well-meaning regulation doesn't automatically penalize the smallest producers in an already consolidated American food system.