Traceability in the Modern Food Safety System

Recent FDA’s Recall, Market Withdrawals, & Safety Alerts, list undeclared allergens and Listeria monocytogenes contamination as the top two reasons for product recall. Food safety has become a growing concern among consumers and with foodborne outbreaks still occurring today, the ability for food companies to quickly withdraw or recall products identified as unsafe has become essential in protecting consumers from food borne illnesses. Traceability should be viewed as a risk-management tool which enables food companies and authorities to quickly respond in identifying and removing any unsafe food from the supply chain and is one of the foundations to any food safety program.

Traceability is the ability to identify the origin of food and ingredients and food sources, particularly when finished products are found to be unsafe.

Traceability is defined by the International Organization for Standards (ISO) as “the ability to follow the movement of feed or food through specific stage(s) of production, processing and distribution” and also referred to as the “one-step-back and one-step-forward principle.” Traceability is the ability to identify the origin of food and ingredients and food sources, particularly when finished products are found to be unsafe. A traceability system allows an organization to document and/or locate a product, creating visibility, through the stages and operations involved in the manufacture, processing, distribution and handling of food, from primary production to consumption. It can also, therefore facilitate the identification of the potential cause of nonconformities of a product, and improve the ability to withdraw or recall such product if necessary and prevent unsafe products from reaching consumers.

Due to the public health burden associated with these preventable outbreaks, great emphasis has been taken to ensure the safety in today’s food supply, such as the first set of Food Safety Modernization Act (FSMA) rules released by the FDA.

  • FDA is to respond effectively when problems emerge despite preventive controls through mandatory recall, expanded administrative detention, suspension of registration and enhanced food tracing abilities.
  • FDA is to establish a system that will enhance its ability to track and trace both domestic and imported foods. In addition, FDA is directed to establish pilot projects to explore and evaluate methods to rapidly and effectively identify recipients of food to prevent or control a foodborne illness outbreak.

Below is a list of some often-recognized benefits of an effective traceability system which includes:

  • Ability to determine the origin of a product, ingredient or component.
  • Simplifies problem-solving in event of defective or contaminated product, ingredient or component.
  • Allows issues to be more quickly identified, contained and resolved.
  • Limits losses and lowers costs.
  • Protects public health and safety.
  • Builds trust and confidence in affected products, businesses or systems.
  • Verifies that produce is locally grown.
  • Improves operating efficiencies for growers, packers and shippers.

A traceability system is effective when food products can be completely traced across the food supply chain.

A traceability system is effective when food products can be completely traced across the food supply chain. The information should be readily accessible in order to know what, how much and from where product(s) needs to be recalled in case of a food safety issue. The traceability process must be incorporated with the Product Recall Program and all GFSI Schemes requires an annual challenge to determine effectiveness using a mock scenario exercise.   The mock exercise should be capable of tracking raw materials, inputs, and packaging materials, backward and forward. The backward trace exercise should identify all affected finished products and tracked back to all raw materials, inputs and packaging materials component used; including any biological, chemical and physical measurement used during manufacturing. The forward trace exercise should identify specific lot(s) of raw materials, inputs and packaging material and tracked to the finished product and lot manufactured, and shipped using the affected components. Mock traceability exercises should document mass balance, using facility established tolerance limits (accounting for waste and moisture loss or gain), total exercise time (usually within 2-4 hours), and provide corrective actions to address any gaps found during the exercise.