Gale Prince is considered one of the industry’s top experts when it comes to food safety, regulatory requirements, food defense, quality control, safety of imports and product traceability. Formerly with the Kroger Co. as director of corporate regulatory affairs, Mr. Prince is now president of Sage Food Safety Consultants, Cincinnati, OH. Recently, Baking & Snack
asked Mr. Prince to provide his latest insights about traceability and its role in food safety. Baking & Snack: What is your perspective on traceability, and how much should be required to ensure food safety in the face of recalls? Gale Prince:
It is essential that food companies have in place a system to track their products from supplier into the marketplace, as well as the ingredients used in the manufacture of their products. In the food plant of today, this information does exist in some form. It may range from handwritten documents to elaborate electronic systems. It is important for a company to be able, on a moment's notice, to track the products one step forward, as well as their ingredients and packaging materials at least one step back.
Current documents such as bills of lading and invoices, along with production data and quality control records, can provide information on tracing the product. Too often, this information is not linked together in a document or in an electronic format that can assist in accomplishing a quick and thorough investigation when needed. In many smaller operations, many record-keeping systems involve lots of handwritten papers, making it difficult for efficient and timely traceback procedures.
There are many benefits of a strong traceability program other than just dealing with recalls. On the ingredients side, a good traceability program will certainly provide the ability to better manage your supply source by measuring the effectiveness of your supplier performance. Such a traceability program can also provide data to enhance controls in the production process and the documentation required to demonstrate the effective controls necessary in the production of a safe product. Data generated by a sound traceability program can be used to defend your product when there may be a foodborne illness outbreak associated with a similar product.
For example, a firm may be able to demonstrate a different distribution pattern, source of ingredients or production process. On the other hand, if a firm’s particular product has been identified as a vehicle in a foodborne illness outbreak, sound traceability information may be used in controlling the extent of the recall, resulting in minimizing negative economic impact. This will become more important in the next few years as we see greater advances in the field of epidemiology. The science applied to investigating multistate outbreaks will continue to develop with even greater expertise in identification of food contamination. Does traceability by a food processor need to go beyond the current approach of “one step backward and one step forward”?
The current regulatory requirement for traceability of one step back and one step forward does provide the opportunity for an effective traceback system. It requires a discipline within a food manufacturing operation to identify at the time of receiving the source from which ingredients were purchased and shipped. The current regulations also require the food manufacturer to track the ingredients that go into a product. Linking that information to the finished product during the production process and to the location to which product is shipped. Many of these records are made up of commercial paper required by various regulatory agencies — namely, the bills of lading and invoices.
A platform does exist for sharing the UPC bar code used to move finished products between manufacturers and retailers. The bar code on the retail package can be used to trace product movement. While the bar code does not contain the production lot code, many manufacturers include that information on the invoices, which allows identification of lot codes.
At retail, the system can work to identify the source, one step back to the manufacturer and the shipping location and dates. In the past, the electronic platform did not exist to exchange lot code data between companies, but that is changing with the produce traceability initiative targeted for 2012, when the bar code on the shipping case will include detailed information to allow a complete electronic trace from the field to the retail store. This will set an example for other industries to follow. This movement does not include lot code information on the retail package due to several limitations on the ability to place such information on the individual packages and the electronic limitations on its use at retail. Readable lot code information is normally already printed on the consumer package. Will this happen anytime soon?
An example of a model traceability program for produce will be seen in 2012. The produce industry has been diligently working on this voluntary program for the past three years.