What is Traceability and How is it Implemented in the US?
Prior to determining the processes for developing traceability for food supply systems, a clear perception about the definition of traceability will guide us in understanding the significance of this concept.
Traceability is a record keeping system that allows the tracking down not only of the food source but also of its history, the application processes used and the methods of delivery, from the retailer back to the farm, or a specific key point where the food being retailed was processed, grown or produced.
However, the systems developed by food producers vary and no particular standards are being observed, especially for products that were grown in large geographical areas. Nonetheless, traceability is a system that allows consumers to gain more confidence in the quality and safety of the food being bought for consumption, that is often lacking due to the rising concerns about unlabeled genetically modified foods and threats of bioterrorism.
Brief Overview of the Traceability System
New technologies are making it possible to allow the integration of specific data into a bar code. Hence, an apple bought from the grocery store can be traced back to the box, the pallet, the delivery truck and back to the supplier where the apple was produced.
In very much the same way, a package of ground beef is appended with bar codes that carry not only its price but also the packinghouse that received the beef from the slaughterhouse. The packinghouse will now refer to its record of slaughterhouse boxes from where the beef was retrieved for grinding and packing processes. Once the slaughterhouse is identified, the name of the livestock supplier who delivered and claimed the contents of the particular meat box from the slaughter unit, can be established by checking their records. The supplier’s identity now embodies all other attributes of the product, i.e. geographic location of the farm and the farming methods used, whether organic or inorganic.
The system is not yet mandated for implementation by the federal government, but the widespread voluntary initiatives among food producers are slowly creating some confusion through their use of different approaches and information.
Governmental Regulations about the Systems for Traceability
There are two agencies largely involved in overseeing food supply: the US Department of Agriculture (USDA) and the US Food and Drug Administration (FDA).
The USDA is still hesitant when imposing mandatory regulations regarding the implementation of standards for developing traceability. The concern of this department is that in cases where an efficient system is already existing, it may be rendered inefficient by confining the trace system to a non-flexible standard.
The FDA on the other hand employed the services of the Institute of Food Technologies (IFT) to come up with its recommendations for a standard system of implementing traceability for the food supply chain.
How is Traceability Developed for the Food Supply System?
In developing traceability for the food supply system, IFT recommends the recognition of checkpoints known as Critical Tracking Events (CTE), for which links between outgoing and incoming and vice versa, will be recorded and checked.
Based on the studies conducted by the IFT, the following are the recommended standards in setting up a system for tracing food products and its entire attributes. The following elements and guidelines are aimed to create a standard by which information should be integrated as references for food traceability.
(1) All the following data about the product shall be made available to the FDA and the consumers.
- The farm and its farmer
- The processor
- The packager
- The retailer
- The food outlet
- The required key data for inclusion as traceability attribute.
(2) Every product received and delivered at each point should be identified by its assigned lot number. All products should be broken down into units to which a “lot” would be the smallest unit used as a reference point. However, in cases where a lot number has to be changed, the original number and the new number will still be recorded in all identifying labels connected to the processing, packing, transport and selling of the product.
(3) Every product received and delivered must carry the date, location from where it was received and to where it will be shipped.
(4) Every manufacturer, processor and re-packer/packager should indicate the date when each lot was manufactured, produced, processed or packed.
Traceability Information (continuation)
(5) Manufacturers or food processors should include all ingredients and raw materials used in manufacturing the food by using item codes and their corresponding lot numbers. Information about the sources from where these ingredients and supplies came should also be included.
(6) All packers/packagers should indicate the types of materials used for packing each lot
(7) The best practice to be observed by any traceability system should also provide trace numbers for the larger units to which the lots packed will be linked, along with the item code, the lot numbers contained and the name of the manufacturer. Larger units may refer to boxes, crates or pallets. The rule is, to provide a link from the smallest unit to its largest container by indicating all reference codes.
Standardized Format of References
- The IFT recommends that a standard format of inputs used for reference should be implemented. As an example, there should be an agreement on how dates should be indicated, either as a numeric reference using MM/DD/YY as the format or nomenclature using January, 01, 2011.
- There should also be a specific standard for units of measurement to indicate quantity and a clear identification of numeric data to indicate whether it refers to Lot No. or Manufacture Date, or Location-Port Area No.
Record Management of Information
- Each participant working with a food chain and its corresponding facility must keep a specific transaction record for all products and all transaction events.
- It is important that records are taken at every CTE point of handling, otherwise, failure to do so will break the traceability chain. Again, every reference code changed should contain both the old and the new number references and should likewise be placed in all other packaging units used for the affected lot.
- The written records shall be maintained for two years at the least or the shelf-life of the food product, whichever is longer.
- All information required and requested by the FDA should be transmitted to the said office within 24 hours via electronic transmissions.
- All invoices, delivery receipts, purchase orders, bills of lading and the like, should also contain information identifying the lot number involved in the transaction event.
- In cases where the lots are minimally repacked, the same identifying marks that will link the minimally repacked goods to the lot item from which it was extracted. However, if repacking results in some percentage of loss or spoilage, this should also be indicated in order to account for the reduction in weight or ratio.
- Internal tracing should likewise be maintained in cases where raw materials received are transformed and transferred to different locations within the manufacturer’s vicinity. This denotes from point of release from the warehouse to the production section and to different sections of the manufacturing process through its transformation into finished goods ready for storage inside the warehouse.
- For best practices in record-keeping, electronic formats should be used to ensure clarity and compatibility for comparing data inputs.
- Audit should be maintained and be observed as a best practice to ensure that the connection of traceability links are intact.
The GS 1 US Standards for Bar Codes
Global Trade Item Number (GTIN)– This is the standard numeric item code which the brand-owner of a particular meat product will use in order to identify his products. The brand-owner will take the initiative to apply for the GS1 company prefix, as a bonafide member of the GS1 Member Organization. The company’s traceability system will now use this company prefix in addition to the item number used as reference codes for identifying all the different products under the owner’s registered brand name.
The product bar codes and the product hierarchy should follow the UPC-type 2 bar code recommended by the Global Standards 1 US. Examples and guidelines for said bar codes are available at the GS1 US.Org website found in the reference section.
These are the current standards recommended by the IFT to the FDA, which all participants regarding the food chain should observe in developing traceability for food supply systems.
Reference Materials and Image Credits
- Traceability Across the Supply Chain -https://www.ers.usda.gov/publications/aer830/aer830.pdf
- Standard Bar Codes – https://www.gs1us.org/standards/barcodes