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Public demands what feds suggest: Traceability via food labels

While the Food Safety Modernization Act doesn’t require transparency, it encourages it, but equally important for food manufacturers, consumers are increasingly demanding traceability.

“Companies are under pressure from consumers, as trust is the lowest it’s ever been,” said John Keogh, president and principal advisor, Shantalla Inc., Ho Chi Minh City, Vietnam. “Trust can be lost at the click of a mouse due to online conversations.”

In the age of social media, food manufacturers have to be doubly cognizant of how their brands are perceived by consumers. Because today’s ground meat filler is tomorrow’s pink slime.


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“Consumers want transparency on labels more than anything else,” said Dr. David Acheson, former chief medical officer for both the USDA’s Food Safety and Inspection Service and the FDA’s Center for Food Safety and Applied Nutrition (CFSAN).

“What are they eating; where are these ingredients coming from? In the future, consumers may want insight into the manufacturing process, as well.”

Acheson, who is in the private sector now as CEO of the consulting firm The Acheson Group, had an agency-wide leadership role at the Food and Drug Administration when the 2007 Food Protection Plan was in development. He served as assistant and associate FDA commissioner for foods during that time, with the 2007 plan later serving as the basis for many of the authorities granted to FDA by the Food Safety Modernization Act (FSMA).

“Effectively, FSMA is encouraging manufacturers to get insight into their supply chain risks, and whether or not they are being controlled,” Acheson said recently. “An on site, third party needs to be reviewing and testing these programs.”

The equation is complicated enough for single-ingredient, non-processed foods such as fresh produce commodities. When multiple ingredients from multiple processing plants are added, meeting consumer demands for transparency and FSMA requirements for documentation of preventive controls are dramatically more complex.

Software solutions are emerging to facilitate more trust amongst all members of the supply chain, from consumers to retailers to suppliers, while helping manufacturers meet new requirements under FSMA.

Managing data

Certainly, one of the biggest challenges for food companies is managing data, Acheson said.


David Acheson

“The expectation with FSMA is for companies to gather more data and act on it,” he said. “Whether a company uses 10 or 1,000 suppliers, it has a constant stream of information coming in that needs to be analyzed.”

This information is useful for the environmental analysis required by FSMA, for example. Plant equipment can collect times, temperatures, speeds, etc., that will bring to attention if a food safety problem is occurring, said Acheson.

“Testing has a faster detection rate today, as well,” he said. “Results for pathogens can come back in six hours, instead of 48 hours, which increases the company’s ability to stay in front of risks.”

Solving problems

Consumers, for one, expect the food industry to conduct effective recalls today, said Keogh, which generally cost $10 million — let alone the untold impact on consumer trust.

In 2007, the Food Marketing Institute, Grocery Manufacturers Association and GS1 (Global Standards One) organization began working together on developing a standard protocol for product recall information between businesses, so there would be a standard method for issuing and communicating recalls.

John Keogh

John Keogh

“Ninety percent of food is now managed through GS1, which has a rapid business-to-business automated recall on its platform,” said Keogh.

The last few years have also seen improvements in cloud-based traceability applications, which can gather information from farm to fork, he said.

Information can now be gathered on each ingredient, supplier, protocol, data format and coding structure involved in a processed food. This data can then be transformed into a common format and put into appropriate processing applications.

There is a drawback. Companies may not want to disclose the information because of concerns about security and competitive advantages.

“I think when CEOs look at transparency it raises questions over the right to know over duty to disclose,” Keogh said.

To enable consumers to more easily stay informed, GMA initiated the Consumer Information Transparency Initiative (CITI), which features the SmartLabel program, Keogh said.

This initiative allows consumers to learn more about a product by scanning a bar code or reaching a landing page online with information on ingredients, nutrition, allergens, advisories and brand information.

“As technology matures, the next phase will focus on providing one interface so a variety of information can converge, like SmartLabel,” he said.

Mapping the supply chain

In order to enable accuracy, brand owners need to unravel their supply chain with supply chain mapping, said Keogh.

It allows retailers to see that when suppliers’ safety verifications will be expiring so they can contact them to make sure they are on track to secure renewals.

GS1’s EPCIS is another open standard that allows businesses to capture and share information about the movement and status of products, logistics units and other assets in the supply chain. Trading partners use Core Business Vocabulary (CBV) to ensure that all members of the supply chain are using the same vocabulary.

Transparency is also critical for supplier verification, said Keogh.

“If a U.S. importer accepts third-party verification from a foreign county, it will need documentation or a guarantee that the supplier records are correct,” he said.

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