March/April 2021

Traceability plan can help ease fear of food recall
By Chuck Mead, guest columnist

Many good horror stories end with some version of “…and they disappeared without a trace.” Coincidentally, disappearing without a trace is a different kind of scary in the produce industry. That is because recalls in the U.S. are increasing at a rate of approximately 10% annually.

There is real danger in not having a plan for the traceability of ingredients, which will help foster an effective recall program, a crucial component of food safety. A plan can help keep consumers safe, strengthen customer relationships and maintain the reputation of the business.

Traceability is the ability to follow (trace) an ingredient, packaging material, processing aid or finished product from harvest or receiving, through production and to the first delivery point away from the facility. Recall is the ability to get that item or material back or put it on hold until it can be retrieved and or dispositioned. Having a traceability and recall plan is a necessity that supports the growing complexity of the supply chain, better detection of food safety issues, and more efficient mandated reporting by manufacturers and processors. It is also a regulatory requirement in a food safety plan and should include management’s strategy to take quick and effective action when experiencing a recall.

Importance of a traceability plan

Processors track their products through all stages of harvest, packaging of field-packed produce, production, processing, distribution and retail. They use recorded information to store and share information about specific fields, harvest crews, ingredients, packaging and other raw materials. Even though a facility or grower may have a traceability program in place, the difficulty is often in ensuring such a program is effective. Employees may not understand the reason for a traceability system, mistakenly believing the procedures are meticulous and burdensome, and that the information is needed only when a problem occurs.

An effective traceability plan should define the team’s actions through four stages:

  1. Identification: The ability to track and trace a product through the entire process and supply chain with a lot or ID number; 
  2. Recording: This number is recorded throughout the life of the product, including each time it is received, transferred, utilized as an ingredient and as a finished product;
  3. Establishing links: The lot numbers are the thread that ties the food material to all phases of its life, from seed to store, butcher to barbecue, plant to package; and,
  4. Communication: Food processors can then map the material through the supply chain and use that information to find it at any given point in the process.

Define the recall plan

It is also a requirement to have documented procedures and defined responsibilities for carrying out a recall due to the multi-faceted nature of the process.

As a first step, it is important to have an established HACCP, Food Safety, Recall or Crisis Management team that should include company management, outside consultants and legal representatives. It will be their decision whether to initiate either a market withdrawal or the recall process. Though this differs by country, in the U.S., the FDA shall be notified in accordance with the Reportable Food Registry program. The FDA can force a recall if they feel the processor is not acting in the best interest of the public.

Notification to all entities that may have product in their possession is key to performing a successful recall. Customer/contact lists must be continually updated, so the right personnel can be promptly notified.

Once quarantine of the product has been communicated, obtain the quantities of product in storage for each individual consignee. Arrangements for the return or verified destruction of product should be completed in a timely manner. The quantities of product will be verified once again for reporting to regulators, while also calculating effectiveness of the recall.

Depending on the type of hazard and class of recall, product may be dispositioned. If the product were contaminated with a pathogen or undeclared allergen, the likely disposition would be destruction. However, in some cases the product could be reprocessed if the hazard could be effectively removed and the product would be rendered safe to consume. All of this must be documented and completed by the Recall or Crisis Management team.

Evaluate the plans

Once traceability and recall plans are written, the team’s preparedness should also undergo an unbiased and comprehensive review. This process will assess traceability and recall exercises in practice, evaluating each aspect of the plans, while determining whether employees are challenging themselves and taking any necessary corrective actions. This allows for a real-time trace and recall exercise, providing a deep dive into the site’s performance and team-member expertise.

Throughout the process, the team’s ability to execute will be evaluated, including keeping track of the time it takes to perform the collection and communication of information at each step. This will confirm the effectiveness of the plan and team, while identifying gaps in their application and execution. Any resulting corrective actions will help support more effective future performance.

The success of these plans is largely dependent upon the knowledge and skills of those executing on it. For this reason, the selection and training of the traceability and recall team members is a critical activity in their development and execution. It may be best to first identify the activities that must be covered throughout the process before identifying team members, which may help dictate responsibilities for those activities. Further, education and ongoing training is paramount, ensuring the team’s preparation.

While detailed planning and execution is involved in each of the necessary steps, when the ingredients or finished products processors are responsible for are traceable and can be recalled, dangerous problems can be caught and quickly mitigated, possibly saving lives in the process.

Will these plans ever be needed? Hopefully, not. But when they are, it is a high-stakes situation with critical consequences. And by having written and tested traceability and recall plans, processors will be able to leave any surprises to books and movies.

— Chuck Mead is a food safety professional for AIB International. He has more than 40 years of experience in food processing and food safety auditing.

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