You, the consumer, are at the end of a long line of stops food makes before reaching your plate. Being able to trace this food back to its origins can be crucial to government and industry during a food-related recall or outbreak. But you may also want to know whether what you are about to consume is organic, whether it’s vegetarian, or maybe because of your beliefs you are looking for food that’s kosher or halal. So while food companies might benefit from traceability and government may eventually demand it, food chain traceability is in large part about building relationships with consumers and giving them what they really want – the ability to trust that they know what they are eating. Knowing what’s in your food and where it comes from sounds simple enough, but food chain traceability is a complex worldwide issue. It requires consistent standards and adequate technology in an ever changing world.
– The 2001 Bioterrorism Act: As of Dec. 11, 2006, food processors are required be able to identify the origin of all food received by lot, code or other identifier and provide the same information when releasing products. The Act applies to both foreign and domestic food, including all ingredients. Civil and criminal actions can be taken if information is not provided upon request to FDA within 24 hours.
– The 2011 Food Modernization and Safety Act: FSMA Empowers FDA to order mandatory recalls and establish a food product tracing system. The Act requires FDA to use pilot studies and stakeholder recommendations to develop the food product tracing system.
FDA has commissioned the Institute of Food Technologists (IFT) to do much of the traceability work called for in the FSMA. IFT has conducted two pilot projects, one on tomatoes and the other on processed foods including chicken, peanut butter and spices. The goal of the pilot project is to see how rapidly these foods can be traced to each prior step, and ultimately to their origins. IFT produced a 300-page document for comment in March that suggests FDA needs a technology platform that would allow “efficient aggregation and analysis” of data submitted to FDA upon request. Foods selected for the pilot project had been associated with outbreaks between 2005 and 2010. Key findings from IFT’s analysis of current product tracing practices indicate the following challenges associated with outbreak investigations:
• It can be tedious and difficult to sort through hundreds of pages of documents • Confusion can arise when data definition is lacking • Products often carry inconsistent item descriptions • Wrong or incomplete information causes delays • Companies operating under multiple names are difficult to identify as sources
IFT said that although FSMA limits FDA to enacting additional recordkeeping requirements to “high-risk foods,” outbreaks during the last several years reinforce the fact that foods previously considered “low-risk” can quickly find themselves on the “high-risk” list. Therefore, IFT suggested that FDA take the opportunity to advise the entire food industry on “best practices” for recordkeeping through the use of guidance documents. Additional IFT recommendations to the FDA include:
• Clearly identify the types of data that industry needs to provide during an outbreak investigation • Require each member of the food supply chain to develop, document and implement a product tracing plan • Pursue the adoption of a technology platform to allow the FDA to efficiently aggregate and analyze data reported in response to regulatory requests • Coordinate traceback investigations and develop response protocols between and among state and local health and regulatory agencies • Offer extensive outreach and education around future regulations and expectations
“IFT expects that these recommendations will not only help protect consumers, but also help develop a better framework for industry and government to focus on food system improvements in the coming years,” said IFT President John Ruff in a statement on the document. The FDA is soliciting input on the IFT report and will issue its own recommendations in a report to Congress. The new food safety law also directs FDA to make its own recommendations on traceability in a report to Congress. This is the first in a series of articles about traceability sponsored by Infor. Coming next week: A look at how food is traced from farm to fork.