When it comes to traceability for food companies, as the old saying goes: “Those who ignore history are doomed to repeat it.” In the case of Hudson Foods, the FDA not only identified issues with their products but also with compromised traceability of product.
As Hudson blended in remaining ground beef from one lot to the next, it made a limited recall of a few affected products impossible. Hudson Foods ended up recalling an order of approximately 25 million pounds of ground beef, and are no longer in business. Other examples of the importance of good traceability for food products include past recalls of black pepper in 2014 and 2015, and of peanut products from Peanut Corporation of America. Repercussions continued for months (and in some cases – years) after the initial recall was announced. In the case of the peanut products, months later they were still chasing down snack products in vending machines, and products in places like convenience stores.
Ultimately, implementing effective recall programs helps a food company to minimize the amount of product affected should an issue be identified; it can help identify risks upstream in your supply that may also affect other companies; and ideally should help you reduce the risk of having a recall in the first place. Our hope is that this article will help you identify parts of your traceability and recall programs that may need a little more polish.
Let’s start with the fundamental requirements and best practices which many readers will be familiar with.
Identification is the first step to traceability. Every product in your facility, whether raw material, work-in-progress, or finished goods needs to be issued a unique identifier (commonly called a lot code or something similar). The bins, cartons or crates should be labeled with this identifier at all times, so an employee can look at it and readily determine what it is and its status. This process can often entail using an electronic inventory tracking system, but can also be entirely paper-based.
The next step is traceability programs. Here are a few questions you should be asking yourself to determine the level of traceability your company has for its products. These are all expectations for a food manufacturer today:
- Can I do a “mass balance” to show where everything comes from, and where it goes, accounting for each pound?
- Can I randomly choose any lot of a raw material received, and through forward-trace, account for all the finished goods that it went into?
- Does my traceability system account for all rework, such that when I trace a lot of product, I also identify any later production lots which may have only a few pounds of this lot in them?
- Does the product-contact packaging that I receive have unique lot numbers, and can I trace exactly which finished goods that it was used for?
- If a customer were to contact us with a serious complaint which had food safety implications, would we be able to trace that product back to all its ingredients?
- Would I then be able to forward trace where the rest of those ingredients went?
- Could I do it in less than 4 hours?
Finally, food companies are responsible for testing their traceability programs. The questions noted above are serious ones and your company should be not only asking these questions, it should be testing each of those scenarios through traceability exercises – just think of it as a fire drill for your recall protocols.
The general expectation is a minimum of two times a year, and generally at least one of those times is done through a full “mock recall” exercise. Your exercises should provide evidence that your system is working; they should also identify “gaps” in your system that need to be updated. As a result, your team should be working to close those gaps through corrective actions and a good root cause analysis.
What’s New With FSMA
The scope of the requirements in the FSMA rules “Preventive Controls for Human Food” and “Foreign Supplier Verification Programs” are further-reaching than previous expectations. They assign food manufacturers some additional responsibilities for implementing robust controls both for their suppliers and their customers. When you review recalls over the past year, the reasons for this are clear. For instance, think about the recent recalls of imported cumin, which was used in a variety of products. This cumin had been ground with “filler” as spices sometimes are, but what was used were peanut shells – introducing a peanut allergen! This recall lasted about 6 months as FDA and the food industry continued to identify affected products. More robust upstream controls and better traceability may have minimized this issue.
Here are some things you should be looking at now:
- Do I have confidence in the integrity of what I’m receiving from my suppliers – is it:
- Wholesome and free of contamination? Can it be traced back to its original source to demonstrate this? Issues often arise with products that fetch a high dollar amount – such as dilution of olive oil with other oils.
- Not misbranded due to use of inferior products, or products actually originating somewhere else? We do see this in the food industry – particularly with examples like honey or inferior products from places like China.
- When I ship product, if not ready to eat, is it clearly identified as to any food safety hazards which may be present – such as “there is a potential for Salmonella, and this product has not yet received a validated pasteurization step”?
- Note: this is very similar to the way the almond industry requires the “unpasteurized” labeling
- Along the same line as the last question above, if I am selling any products which may bear a potential hazard that would require further processing (typically a pathogenic bacteria), there are two requirements:
- Labeling the product to identify this fact, as noted above;
- Obtaining a letter at least annually from my customers indicating that they will process this food to eliminate that hazard, or will follow these same requirements when shipping to their customer.
Ultimately, the end goal of your food safety program is better control, and minimizing risks to your company and your customers. The main focus in implementing traceability programs should be not only satisfying FDA or GFSI requirements, but also seamless functionality. Processors like you – who are working to implement the best programs they can – should seek the ability to take quick, comprehensive action at any time should the need to withdraw a product arise. And this is achieved by frequent practice and by continual improvement of programs.
DFA is always here to assist you in meeting your strategic food safety goals. Contact us today if you have questions or need help implementing one of your programs at (916) 561-5900 or email@example.com