Making traceability work
It can be a long way from farm to table. And a lot of things can happen along the journey.
With the Food Safety Modernization Act (FSMA) calling for an effective protocol to track and trace foods in the entire supply chain, traceability is the word of the hour.
Label on every case
Even as the FDA has initiated pilot programs to examine the practices, processes and types of technology that might be available to help better trace foods in the event of a foodborne illness outbreak, the industry’s Produce Traceability Initiative (PTI) is trying to stay the path to achieve supply chain-wide adoption of electronic traceability for every case of produce by Dec. 31.
“The end game, I think, is that we’ve got the ability to, number one, track a case of produce wherever it went through the supply chain,” said Ray Connelly, president of Salinas, Calif.-based TRUETRAC and a member of PTI’s technology committee. “Number two, that label on that case is a license plate to additional information about that product – things like food safety, the production practices, things like that.
“The goal right now is to provide a label on every case of produce that goes into commerce in North America. That’s what the Produce Traceability study is.”
A voluntary effort, PTI is a collaboration of the Produce Marketing Association, United Fresh Produce Association, Canadian Produce Marketing Association and GS1 US. The group’s latest undertaking was a survey to assess the extent of the industry’s adoption of traceability standards, with results to be completed soon.
In the meantime, the FDA is conducting a traceability pilot that focuses on fresh tomatoes as it aims for full implementation of the FSMA, signed into law in January 2011. Connelly said the FDA is working in a three-year window to come up with final rules.
“The Food Safety ModernizationActgave the FDA the clout to redefine a safe food supply,” said Connelly, adding that if PTI’s traceability protocol proves functional, it is likely to be welcomed by FDA.
The FDA’s standard for traceability calls for each player in the supply chain to be able to trace the product one step back and one step forward. That means everyone – from grower to retail store or foodservice provider and all stops between – should have an in-house traceability plan.
The PTI has developed an action plan posted at www.producetraceability.org that spells out a process relying on bar codes to identify individual companies (GS 1 company prefix) and a 14-digit GTIN number that contains all of the traceability data for each product. The numbers are to beprovidedtobuyersandare also supposed to be displayed and readable on each case. Anyone receiving the cases should be able to read and store information on each one based on the data provided.
Whose name the identification is tied to depends on how the product is being sold.
“If Farmer Ed is selling his product under Ed’s product brand, then yes, he’s a brand owner and brand owners need to get a GS1 company number and assign a GTIN to every different case they have,” said Angela Fernandez, GS1 senior director of industry engagement, during a recent PTI-sponsored webinar. “If they’re packing and shipping under somebody else’s brand – for example, if they’re shipping for a private label and that’s all they do, they don’t sell under their own brand, they are not required to get their own GTIN and GS1 number. That will be provided by the label owner.”
Packers
Even though each player has responsibility for internal traceability, there are some pivotal points in the supply chain. Connelly said one of them is at the packer level.
“The brand owners, which are largely the packers – they are the key because they are the ones that effectively create that carton of produce and insert it into commerce,” Connelly said. “They sell it, so it becomes a transaction that comes to another company.”
It is during packing that PTI calls for barcodes to be affixed to each case of produce.
During PTI’S traceability webinar, Ed Treacy, vice president of supply chain efficiencies for the Produce Marketing Association, warned that it’s important to include all materials in traceability accountability – not just the food.
“If there is a problem with the product discovered somewhere down in the supply chain, you want to find out all the inputs that went in to create that product,” Treacy said. “It may be you’ve got a bad batch of cardboard – actually the shipping container you’ve shipped it in is causing issues with the product. That’s why it’s best practice to record all inputs – packaging, labels and everything you used.”
Fresh cut
Those processing products for the fresh-cut value- added markets must overcome issues of their own.
“It’s a big challenge,” Connelly said. “You’re at one end of the line, dumping carrots, radishes and lettuce in a continuous stream, and at the other end, you have bags, boxes and you’re making pallets.
“You’re going to say, ‘Shoot, I’ve got a different batch of carrots coming in from a different grower in a different part of the world.’ Do you shut everything down now because the traceability is different? It’s very tricky how you manage that on a packing and production line.”
The term for it is commingling, and in traceability terms, it means taking multiple GTINs and lots and combining it into one traceable label, said Steve Roohsdal, director of supply chain, operations and quality control at The Oppenheimer Group.
Keeping accurate records on where it all came from and where it went can be done, but takes planning and a process. The FDA now requires that records be available within 24 hours. Having a system that is consistent and functional expedites tracking, which is better for public health, eliminates unnecessary removal of product and minimizes bad publicity, Connelly said.
“I’ve coached a lot of companies specific to how they ought to be doing it or could be doing it internally, and some just can’t – they don’t have the technology, they don’t have the ways or means to handle it,” he said. “It might be ‘I only know what I used today and produced today, so today is the batch. But I might have had five different producers who all got blended in today.
“The downside (of that) is if there’s a recall, you would have to get five growers involved in this recall as opposed to if it’s just one. The lack of precision or lack of ability to have precision just broadens the scope of a recall you might have to do.”
–Kathy Gibbons, editorial director
Photo: Running and affixing labels in the field. Courtesy of TRUETRAC
