Tactics for Improving Food Traceability (Online Exclusive) November 1, 2009

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Whenever ingredients and products are moved between premises, transformed, or determined to be a point of data capture, it constitutes a CTE. To facilitate identifying CTEs and implementing an effective product traceability program, IFT makes the following recommendations:

    • Recordkeeping. Every facility that handles a food product must maintain key data elements for each CTE. Therefore, maintaining accurate internal traceability for processed products is imperative. For products that do not undergo additional processing or transformation (e.g., a case remains unopened), a one-to-one relationship between incoming and outgoing lots must be sustained—even when repacking occurs. Upon FDA request, each entity should provide this information in electronic format within 24 hours. IFT does not recommend specifically prescribing a method for each firm to capture data.

      • Key Data Elements. Key data elements provide for the flow of ingredients and movement of finished products, which facilitate rapid identification of the source of contamination. Each key data element should be in a standardized format so that communication from company to agency is smooth and efficient. Gathering and maintaining the following key data throughout the supply chain is imperative:
    • Physical location that last handled the product (manufacturer or distributor);
    • Incoming lot numbers of products;
    • Amount of product received, manufactured, or shipped;
    • Each physical location of shipped cases;
    • Lot number(s) for products shipped to each location;
    • Date and time of product receipt and/or shipment;
    • Date and time of the manufacturing or harvesting of each lot;
    • Lot numbers and sources of all ingredients used to manufacture a product, name of the facility that manufactured the products, and the date and time of receipt;
    • Lot number and name of manufacturing facility on each case of product;
    • Lot number(s), quantity, and shipping location on invoices or packing slips.
    • IFT also recommends that all operations maintain data electronically. Electronic formats allow timely access to information, especially when requests need to be fulfilled within 24 hours. Operations using paper-based systems should implement a conversion of all data to an electronic format. Data conversions may be done through third parties but must be done regularly to be kept current.
    • • Required Company Audits and Staff Training. IFT recommends that traceability be part of standard company and third-party audits. In particular, appropriate identification of CTEs, adherence to internal traceability, and correct capture of key data elements should be included as part of the audit procedures. Furthermore, guidance should be developed that details how CTEs should be identified, and definitions for critical terms such as “lot” should be determined. Educational product tracing compliance modules should be developed and all segments of the food industry and regulatory community should be trained in their use.

Economic I mplications
Although implementing IFT’s recommendations would come at an added cost to the industry, several benefits outweigh the cost. Improved supply chain management and inventory control, increased access to contracts and markets, and more targeted recalls with lower costs to recall are a few prominent advantages. Other potential benefits are brand name protection, decreased risk of counterfeiting, and reduced possibility for liability claims. In fact, effective product tracing could facilitate a firm’s exclusion from a lengthy and perhaps costly investigative process.

As with other technologies and services, the cost of product tracing software and services will likely decrease with increased use of traceability systems. Also, some systems that are currently used to serve other business functions (e.g., accounting, inventory control, etc.) may be capable of recording traceability information at minimal expense.

Bottom Line
The United States needs an effective way to trace food products throughout the food supply chain. Setting clear, well-defined objectives for those in the food supply chain and allowing the industry to determine how to reach those objectives constitute an appropriate approach to product tracing. Company audits and staff training can help reinforce traceability objectives. Moreover, a traceability system should be simple, user-friendly, and globally accepted. The system should have the ability to leverage existing industry technologies and systems, but most importantly, it should protect public health and foster consumer confidence in the U.S. food supply.

IFT thanks the following expert panel members for their time and expertise: Steve Arens, MBA; Frank Busta, Ph.D.; Martin Cole, Ph.D.; Arthur Davis, Ph.D.; Helen Jensen, Ph.D.; Brenda Lloyd; Benjamin Miller, MPH, RS; and Gale Prince.

For additional information, contact Jennifer McEntire, Ph.D., at 202.330.4984 or jcmcentire@ift.org . To view the report in its entirety, click www.ift.org/traceability.

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