An overview of how traceability in the US food supply chain is being driven by the need to ensure product wholesomeness in food processing for protecting the nation’s health
by Gary Krause, SATO America
The news of late makes it clear that there is need for food processing traceability and a growing demand by the public and government to make this happen. Recent RFID industry symposiums reveal market focus being applied to solidifying the US food supply chain position as the best and most dependable in the world. As product wholesomeness significantly impacts the population’s health, the drive to full accounting through traceability grows within the industry.
The decision making of traceability solutions falls onto the individual corporation and the stakeholders they serve. Consumer markets and the US government demand accountability in the wholesomeness of product and there’s growing concern by state government for regulations on producers to validate their raw product processes using information technology, track and trace accountability. Years and years of paper trail detail produces an overwhelming amount of data for one producer to keep track of, yet alone the man hours associated with keeping the data captured organized and usable.
When coupled with the number of manufacturers who ’touch’ a single ingredient used to manufacturer the final product, the task of gathering this information is daunting to say the least. Each participant in the chain of manufacturing must come to the conclusion to invest in the automated process of trace/track accountability, as they are stakeholders in the overall process of finished product and will be accountable for their part in the products wholesomeness for human consumption. From seedling to processing, from farm to fork, track/trace systems provide visibility to any products processing and handling and supports the company’s validation of their procedures and protocols.
Track and trace
Some aspects of a track/trace solution would include: tracking import and export elements of raw materials; multi-ingredient food and additives tracking; integration with food safety and other processing systems; effectively track and trace products both internally and externally; document product history from manufacturing to the customer. Supportive systems would include barcode and/or RFID tagging solutions and provide a supported chain of custody for finished goods.
Accountability
Consumer markets and the US government demand accountability. This is borne out by the Food Safety and Inspection Service’s (FSIS), guidelines on what is required to achieve compliance. The FSIS is the public health agency in the U.S. Department of Agriculture responsible for ensuring that the nation’s commercial supply of meat, poultry, and egg products is safe, wholesome, and correctly labeled and packaged,
Efficiencies
Product efficiencies of track/trace solutions would include:
- an accurate accounting of raw material processes
- accurate traceability of processed products
- support for the drive in greater manufacturing controls for JIT (just in time) supply chain management
- lower costs of manufacturing by providing real time needs assessment data
- immediate and accurate raw material assessments during the manufacturing process
Logistics
Product logistic and warehousing support values would:
- support the labeling of processed products to industry standards
- electronically support the industry’s current standards, improving the overall processes and provide allowance for advancement in future process improvement
- support a first pick and process inventory management against lot numbers or user defined protocols
- provide a significant reduction in paper trace/ track processes
- assure the highest possible accounting of material or asset documentation
- allow for an implementation of location or date driven materials management offering asset optimization
- accurately track and trace the path lines of products that were recalled or were issued an isolation requirement
- drive quality assurance processes allowing the applicable FIFO and item rotation rules
- eliminate inaccurate manual track/trace processes in manufacturing
- dramatically reduce material handlers time on task to pull, move or account for product dispositions
- seamless integration of data elements to host legacy databases.
Value propositions applied to federal, state or local regulatory compliance means that it would support documentation on manufacturing and processes used for any track/trace protocol established by regulatory agencies and fulfill traceability requirements existing for on and off-farm programs. In addition integration guidelines as set by the industry or government regulatory standards would be supported as would a reporting of multi-ingredient traceability. Furthermore, incorporating the use of track/trace solutions will address the concerns presented during an assessment of product viability and wholesomeness and provide confidence in the data and processes in place by the processing company. From seedling to processing, from farm to fork, track/trace systems provide visibility to any products processing and handling.
Food Safety and Inspection Service
The following extract from FSIS policies and guidelines demonstrates the importance given to track and trace solutions, inspection and surveillance.
FSIS provides information to producers and agricultural businesses to help them maintain compliance with federally defined regulations for their establishments. According to the FSIS, in order to protect the food supply, FSIS must be aware of information pertaining to threats to the food supply and have the capability to monitor and detect acts of intentional contamination. FSIS continues to enhance its laboratory and other surveillance capabilities to detect intentional contamination of meat, poultry and egg products, including strengthening its relationships with the intelligence and law enforcement communities.
Surveillance capabilities
In order to help prevent an attack or to detect an attack if it were to occur, it is important that FSIS conduct surveillance activities. These include:
- FSIS has a representative assigned to Custom and Border Protection’s Import Safety Commercial Targeting Analysis Center (CTAC), which is devoted to supporting the development of strategic and operational plans to address health and safety risks. Other government agencies represented at the CTAC include the Consumer Product Safety Commission, the Food and Drug Administration, and the Environmental Protection Agency. The CTAC will develop special operations and national interventions in response to alleged or apparent import safety violations will be conducted by the CTAC.
- FSIS has hired 22 Import Surveillance Liaison Officers who are responsible for the agency’s oversight of food defense issues relating to imported food products at ports-of-entry, border entries, and in-commerce around the nation. In particular, they have expanded their liaison activities with DHS’ Customs and Border Protection.
- In order to better detect and respond to the intentional contamination, FSIS is developing a system using predictive models to assess its public health and inspection data.
- FSIS randomly tests processed products for threat agents that have been identified as concern.
- FSIS has also developed a system to rapidly identify, respond to and track significant incidents, such as intentional food contamination and other large scale food emergencies spanning multiple jurisdictions.
The FSIS utilizes the following surveillance systems currently in place:
- Consumer Complaint Monitoring System (CCMS): This system records, sorts, analyzes, and tracks consumer complaints received by the agency about FSIS-regulated products.
- FSIS’ Incident Management System (FIMS): A web-based common operating platform that allows program managers and users to rapidly identify, respond to and track the Agency’s response to significant incidents such as suspected tampering of products, threats to facilities, natural disasters, and Class I recalls with illness.
- Import Alerts Tracking System (IATS): Tracks illegal and ineligible shipments that may have entered the U.S. This automated data system operates under the FIMS platform and also tracks potential incidents of concern involving meat, poultry, and egg products.
- Agency field personnel conduct food defense verification tasks to ensure that potential vulnerabilities in establishments that could lead to or allow deliberate contamination are identified. This information is also analyzed to identify trends. Suggestions are made to facility management as to how they can be mitigated to the maximum extent possible.
Food defense
The department has also published a series of Food Defense Plans to help producers put measures in place to reduce the chances of someone intentionally contaminating the food supply in order to kill or hurt people, disrupt the economy, or ruin a business.
The FSIS states that by having a Food Defense Plan, you will contribute to a safer and more secure food supply. You will also protect public health, your employees, and your livelihood. A functional food defense plan may also recuce:
- the risk of unsafe product and economic loss
- theft
- the need for additional regulation on food defense
- company liability.
Measures
Some of the many FSIS recommended measures to protect product from intentional contamination throughout the production process are:
Physical security
- Plant boundaries are clear and secured to prevent unauthorized entry
- installed, no trespassing signs posted
- Entrances are secured
- Plant perimeter is periodically monitored for suspicious activity
- Outside lighting is present to deter unauthorized activities
- Other access points such as windows are secured
- Outside storage on the premises is protected from unauthorized access
Shipping/Receiving security
- Incoming shipments are examined for tampering
- Vehicles are examined for suspicious activity
- Loading and unloading activities are scheduled
- Loading dock access is controlled
- Incoming and outgoing shipments are secured with locks or seals
Storage security
- access to storage areas is restricted
- stock rotation (first in, first out) is practiced
- labels and packaging materials are controlled to prevent theft and misuse
- periodic examinations for tampering of materials.