the affected firms could have been mitigated. Another oft-reported tangible
benefit from improvements in tracing
comes from tighter controls on inventory and being able to link product quality with supplier information. Again, the
extent of these benefits is firm-specific
and depends on the difference between
what is occurring today and what the
firm might do in the future.
tributors to a given silo. For other products, complete emptying is done rarely, if ever.
However, this does not excuse the firm handling the product from keeping appropriate records. In this instance, although the records may show that the pool of constituents is in the hundreds, thousands or more, engineers who understand the way
the specific product flows through the silo can provide estimates of the amount of
Cost aside, there are other challenges
that various members of the food supply
chain will face and need to overcome to
improve product tracing. Some are firm-specific and relate to changes in the flow
of product that may result from the need
to add identifiers to products. Many
food processing environments are not
amenable to things like labels: dust and
water are two commonly encountered
obstacles that complicate the ability to
attach a label to a box. Within the food
manufacturing environment, processes
have been developed to be highly efficient, and the addition of “another step”
specifically for traceability may be a challenge in some operations. Warehouse
and distribution operations also deal
with high throughput, and the procedures for “picking” products may require
some adjustment in order to capture the
information needed for product tracing.
Even if the recommendations made
by IFT are fully implemented, there will
still be some products that are more difficult to trace than others because of
their production processes. It is impractical to expect a wheat farmer to mill his
own flour or for tomatoes to ripen at exactly the same time. The extent to which
facilitating product tracing may compromise efficiency needs to be discussed.
already use electronic systems that can be
tweaked to enable the capture of data
needed to trace products...”
constituent that might reasonably be expected to remain in the system. Obviously, the
more time has elapsed since the addition of a specific input, the less of that input
would be expected to be in the silo. Dilution is not always a good solution, but having
a sense of the relative amount of inputs in a silo or other bulk container could prove
very useful when tracking products.
Tomatoes have served as the poster child for complex product tracing, somewhat
unfairly. Conceptually, commingling and repacking are no different than producing
multi-ingredient food products. It’s just that in the case of commingling, the ingredients happen to be the same. Therefore, tracking commingled product should not be
viewed as an exceptional circumstance. Like other multi-ingredient products, the information needed to track incoming ingredients (e.g., multiple lots of tomatoes), such
as lot numbers or other identifiers, needs to be recorded and linked to the outgoing
product (e.g., a box of tomatoes consisting of multiple sources). The same can be said
for rework, which, according to many firms IFT spoke to, is already tracked as an ingredient. Clearly, possible sources and routes of a problem increase in the case of rework, but this is not an excuse to not maintain adequate records.
Recommended Next Steps
Whether or not the House or Senate versions of a food safety bill pass, change is
coming. For some, the change could be small. For others, the changes might put them
out of business.
For now, IFT hopes firms will consider the recommendations it made to the FDA
with respect to the concepts of Critical Tracking Events and Key Data Elements. We
believe that identifying the right points at which to capture information (the Critical
Tracking Events) and generating or capturing the data needed to trace products (the
Key Data Elements—such as lot number, production date, shipper, etc.) will provide a
solid foundation for whatever Congress may mandate and the FDA (or the Food
Safety and Inspection Service) might implement. n
Bulk Product Tracing
The difficulties associated with tracing bulk product have been voiced in
many forums. Tracing bulk ingredients
such as wheat, sugar, oil, etc. is not impossible, but it’s certainly complicated.
Some product-storage silos need to be
emptied and cleaned regularly. These
“break points” enable one to determine
the finite (even if high) number of con-
McEntire, J., et al. 2010. Product tracing in food systems: An IFT report submitted to the FDA, Volume 1: Technical aspects and recommendations. Comp Rev Food Sci Food Safety 9(1):92-158.
Mejia C., et al. 2010. Product tracing in food systems: An IFT report submitted to the FDA, Volume
2: Cost considerations and implications. Comp Rev Food Sci Food Safety 9(1):159-175.