When the FDA moved the compliance date for its Food Traceability Rule from January 20, 2026, to July 20, 2028, the reaction split the food industry down the middle. The Global Cold Chain Alliance welcomed the delay as time to run pilots and refine implementation, Consumer Reports food policy director Brian Ronholm argued the extension puts consumers’ health at risk and the Institute of Food Technologists’ Global Food Traceability Center said it was disappointed, and Congress then directed the FDA through its 2026 appropriations act not to enforce the rule before the new date.
The argument centers on recordkeeping, though cold storage operators have a more immediate problem underneath it. A rule that requires lot-level traceability records within 24 hours of an FDA request depends on warehouse inventory that’s accurate to begin with, and temperature-controlled facilities generate recurring inventory errors for reasons a dry-goods warehouse never deals with.
The nine causes below are specific to cold storage. Every one of them will matter in 2028 regardless of which side of the delay debate turns out to be right.
1. Turnover Driven by the Lunchtime Exit
Global Cold Chain Alliance figures have put turnover in North American cold storage facilities at about 33%, nearly nine times the national average for all industries, and a December 2024 Descartes Systems Group survey of 1,000 supply chain leaders found more than three-quarters facing significant workforce shortages, with 37% of those describing the shortage as high to extreme. Industry veterans interviewed by Frozen and Refrigerated Buyer describe a lunchtime exit pattern in which new hires take off their freezer coats for a break and never return to finish the shift. AEW research director Adrienne Ortyl has tied cold storage turnover to higher training spend, more overtime and a “greater risk of errors and accidents,” and inventory accuracy absorbs much of that risk. Every departure resets the learning curve on lot codes, pallet configurations and location rules, which explains why the same variances resurface in the same freezer aisles after each staffing change. Datascan’s supplemental staff arrive pre-qualified, vetted and trained before a count begins, and its warehouse teams scale from 10 to 150 counting staff across multiple shifts.
2. Counting Against the Clock in Sub-Zero Rooms
Workers in sub-zero rooms rotate out to warm up, and personnel slowed by the cold are more prone to injury, which puts natural pressure on every task performed inside the freezer. A counter racing to finish a section before a warm-up break skips the top rack, estimates a partial layer or confirms a quantity without checking the case count on the label. Count plans for frozen zones need more people working shorter rotations, and a full-service team staffed for rotation schedules keeps the count moving without asking any one person to stay in the cold longer than they should.
3. Frost, Condensation and Unreadable Labels
Product that moves between a freezer, a cooler dock and ambient staging collects frost and condensation, and labels that smear, peel or ice over turn a fast barcode scan into a manual keying exercise. Manual entry multiplies transposed digits and wrong lot numbers, and the errors repeat every time the same product makes the same trip.
RFID offers a way around the problem, since tags don’t depend on a clean line of sight to a printed barcode. Walmart’s deployment of Wiliot’s battery-free ambient IoT tags, aimed at 90 million tags by the end of 2026, explicitly targets cold chain compliance alongside inventory accuracy, with sensors reporting temperature and location data together. Datascan’s RFID readers and tags, available through leasing or rental, let a cold storage operator test the approach on its problem SKUs before committing to a broader rollout.
4. Lot Codes and Expiration Dates That Drift From the Records
Traceability under the FDA rule runs on key data elements such as lot codes, and a frozen warehouse that counts cases correctly while recording the wrong lot has an accurate count and a useless traceability record at the same time. Mixed-lot pallets, rework that combines partial cases and first-expired, first-out picking that pulls from the wrong lot all create discrepancies that only surface during a recall or an audit. Datascan’s distribution center counting maintains procedures for lot and serial number tracking and expiration date management, so a count verifies the lot on hand along with the quantity.
5. Catch-Weight Products Counted by the Case
Meat, poultry and seafood frequently sell by variable weight, while warehouses store and count them by the case, and any mismatch between the two units corrupts the record in both directions. A counter who records cases against a location tracked in pounds, or the reverse, creates a variance that looks like shrink when the product never moved. Datascan’s distribution center teams follow documented procedures for each unit of measure and packaging configuration, from individual units to cases, pallets and bulk.
6. Deep Racking That Nobody Reaches Between Counts
Cold storage space is expensive to refrigerate, so operators pack it densely with double-deep, drive-in and high-bay racking that’s hard to reach without a skilled reach truck operator. RealCold chief commercial officer Marty Steinmetz has said demand for experienced reach truck operators is high across the industry, and when those operators are scarce, cycle counts drift toward the locations a counter can verify on foot.
Records for the deepest and highest positions go unchecked for months as a result, and when a wall-to-wall finally reaches them the variance looks like a sudden loss. Pairing supplemental counting staff with the operator’s own equipment drivers during scheduled sweeps keeps every rack position on the rotation.
7. Transfers Between Temperature Zones
Product moves constantly between blast freezers, holding freezers, coolers and dock staging, and every move that happens without a scan leaves inventory in a location the system doesn’t recognize. Transfers made under time pressure to protect product temperature are the easiest to skip logging, since the priority in the moment is getting the pallet back into the cold. Public refrigerated warehouses add an ownership layer to the problem, since a third-party operator storing product for dozens of food companies records each pallet against a customer as well as a location. A pallet dropped into the wrong zone during a quick transfer can show up as one customer’s shortage and another customer’s overage at the same time, and both customers will want an explanation before the next storage invoice goes out. Blast freezing creates its own gap, because product sits in a blast cell through its freezing cycle before moving to long-term storage, and a handoff that crosses a shift change is easy to lose entirely.
A count that sweeps every zone, including blast cells and staging lanes that don’t appear on the location master, catches the pallets those quick moves left behind. Datascan’s warehouse software includes bin location tracking and reconciliation to match what counters find against where the records say it should be, and its Enhanced Data Analytics views inventory accuracy from multiple perspectives, which helps an operator separate misplaced pallets from true loss before either customer starts asking questions.
8. Receiving Rushed to Protect the Cold Chain
Every minute a dock door stays open and a refrigerated trailer sits unloaded costs temperature, and receivers under that pressure confirm quantities against the advance ship notice without counting the freight. Short shipments and substituted lots enter the system as received and surface weeks later as unexplained shortages. Datascan’s receiving verification checks incoming quantities against what physically arrived and flags discrepancies before the product reaches a storage location.
9. Records That Won’t Survive a 24-Hour Request
The Food Traceability Rule requires covered businesses to produce records within 24 hours of an FDA request, and a warehouse whose counts live in spreadsheets, handwritten tally sheets and a separate lot log will struggle to meet that window whenever enforcement begins. Upshop’s Mike Weber put the industry’s choice plainly when he said the extension isn’t permission to delay preparation, and the facilities that use the extra time to clean up their inventory records will have the least scrambling to do in 2028.
A full-service inventory count builds that foundation with documented, reconciled results, real-time visibility through Datascan’s software and post-count analysis that identifies patterns in discrepancies. Datascan’s SOC 1 compliance adds an outside layer of assurance around the controls that govern the inventory data an auditor or regulator will eventually review.
Reducing Cold Storage Inventory Errors With RFID, Supplemental Staff and Full-Service Counts
The FDA delay gave cold storage operators 30 more months, and critics and supporters alike agree on how that time should be spent. RFID addresses the label failures and unlogged transfers that barcodes can’t handle in frozen environments, supplemental staff keep counts and cycle programs reaching every rack position despite turnover that runs far above other industries and a full-service team brings the planning, lot-level verification and documentation that a traceability audit will demand. A consultation with Datascan can identify which of these nine causes are producing the recurring variances in a specific facility and build a counting plan around them.
