During an educational seminar at the 2015 Food Safety Summit in Baltimore, a room full of hands were raised high when asked if their company would greatly benefit from making improvements in its traceability measures.
But while many attendees claimed they would benefit from having a traceback program, lawyer Shawn Stevens of the Food Industry Counsel, LLC, said unfortunately the only time most companies truly care about food safety is when there’s a problem.
“After a nasty recall, your company’s in the news, there’s been a foodborne illness outbreak linked to your products and the FDA is breathing down your neck – that’s when most companies really start to care,” Stevens said. “We need to make [traceability] a topic that’s part of our daily intercourse.”
The “Achieving True Traceability Through Transparency” presentation looked at how food safety and traceability are interconnected, some of the main drivers behind traceability and the real life consequences of not caring.
Traceability can be best defined as the ability to trace and follow a food, feed, food-producing animal or substance intended/expected to be incorporated into a food or feed through all stages of production, processing and distribution. Directionality is not indicated, meaning the product should be able to be traced from farm to fork and fork to farm.
Learn more: Traceability: The Intersection of ROI and Compliance
Traceback vs. recall: what’s the difference?
A traceback is typically driven by the regulators throughout the entire supply chain. The scope of the issue is unknown and the goal is to try to find the common source, which is sometimes very hard to determine.
A recall though, is industry-driven, has a known issue and experts are working to locate the known product. When a food/food product is recalled, it works by using the 1 forward/1 back approach and is typically easy to test.
“Tracebacks can be laborious and can take up an awful lot of time,” Jennifer McEntire, Ph.D., VP Science Operations, Grocery Manufacturers Association, said.
The current state of the FDA’s traceability regulations is 1 up/1 down within 24 hours. But once an issue is identified (at any point in the supply chain), how long should it take to recall the affected product?
And whose responsibility really is it to ensure an effective traceability is in place for your supply chain? While some companies may put the responsibility on their food safety/quality personnel, inventory/warehouse management team, sales/procurement personnel or the Information Technology department, most attendees of the session agreed it should be all of the above.
What you can do now, before it’s too late
“Any platoon is only going to be as fast as their slowest runner,” Stevens said.
While you, as an employee at a food company, may find traceability important, if you don’t own your company it may not matter.
Stevens said if your owner/CEO doesn’t care, upper management doesn’t care, your suppliers don’t care and your customers don’t care --- it’s not going to get you too far.
So what can you do? Make a call for action.
- Articulate your role in traceability at your company.
- Understand your recordkeeping system, including any gaps like an employee store, donations, rework, etc.
- Understand your suppliers’ and customers’ recordkeeping systems.
- Be able to “sell” the value of improving traceability to your higher-ups.
Food safety and traceability
Food safety and traceability are like peanut butter and jelly –you simply can’t have one without the other.
While having a traceability program in place should be an everyday importance, when it really matters most is when people are getting sick and dying from a foodborne illness outbreak due to a contaminated product.
“Why would you buy a used car (without seeing it) from a car dealership over the phone? You wouldn’t because it’s stupid,” Stevens said.
Knowing exactly what you bought and who you bought it from --- that’s true traceability. It’s important for manufacturers to know their suppliers, but also exactly where their product is going after it leaves their facility. Stevens said if you can’t readily produce an answer, that’s a problem.
If there’s an illness outbreak and the FDA comes to your facility and says it’s you, you’re going to be required to go back and find the information.
“Is your system robust enough to immediately snap your finger and say ‘Aha! I got it figured out’?” Stevens asked.
Your company should be prepared to show the FDA the batch records of the product in question, so Stevens said it’s crucial that you know where to look.
And even if you know where to look (say, for example, you know you got the ingredient in question from Supplier A) but that supplier does not have very good records, your company better be prepared to recall all of your products with that ingredient, too.
Real life consequences
Stevens predicts that the food industry is going to see more and more products being pulled off store shelves in the future.
“When it does happen, you need to have programs in place so that the brand and company can survive,” Stevens said.
By not caring, your company is likely to face:
- Risk of brand(s)
- Financial impact from media/social media
- Sick consumers
- FDA regulatory issues
- Potential for criminal sanctions
- Lawsuits
What’s driving the need for traceability
In today’s world, consumers are much more vocal. More and more every day, customers are voicing their demand for rapid access to reliable and relevant information of their foods.
A simple nutrition label is no longer the answer for food advocates. Humans are a naturally curious race, but when it comes to food, consumers are increasingly wanting to know all the details.
Where did it come from? How was it made? With what ingredients? Can I trace it back to the exact farm? Is it organic? Fair-trade? Are there GMOs?
With consumers’ changes in food purchasing habits, the need for transparency in food is the next step in staying loyal to your customers and your company – all in the name of safety.
McEntire said some companies have already taken the step to include consumers in the journey from farm to fork in including a QR code on products. When a customer scans the code, it will bring them right back to the farm where it all began.
“Traceability can be expensive, but it’s probably not as expensive as the financial impacts of a recall would be,” McEntire concluded.