The countdown is on for the Food and Drug Administration’s (FDA) final rule on enhancing food traceability. The rule, which the agency must submit to the Office of Federal Register by Nov. 7, 2022, will require maintaining records for foods on its Food Traceability List (FTL) to support more efficient and accurate traceability of potentially contaminated food.
The proposed rule, which has taken more than a decade to develop, is a required aspect of the Food Safety Modernization Act (FSMA), and it’s likely you’ve already begun preparations. If you have, FTL, key data elements (KDE) and critical tracking events (CTE) are already part of your life.
In case you need a refresher, the Food Traceability List includes the 16 foods that will have added tracking scrutiny attached to them. Any food that contains something from the FTL as an ingredient also falls under the rule. Check FDA’s site for the full list, but it includes many common items such as various types of produce, dairy items and some seafood. CTEs are events such as growing, receiving, transforming, creating and shipping any of the covered foods, while KDEs are the required data points collected depending on the CTE being performed.
We caught up with traceability experts to find out how to make your plan top notch, including tips, tricks and more.
Understand the Why
A good traceability plan helps you understand your supply chain even more deeply, something that Shamonique Schrick, food safety and quality assurance solutions architect at SafetyChain, said is important as the industry still struggles with supply chain issues and companies are scrambling to find new suppliers.
“[It lets you] really understand your supply chain so that if you do have an issue come up where you have to have a recall, you’re able to track your materials properly and you’re able to identify any sources of potential recalls,” she said.
Everything’s better when you’ve got backup, so get a traceability recall team together to make things more efficient, effective and accurate. Make sure each team member knows his or her role and is trained accordingly.
“The more efficient we are at tracing our finished products to the market, the more our consumers are informed and kept safe,” said Rod Martell, a food safety auditor at AIB International. “Being able to accurately record the lot numbers at the point of use for raw materials, food contact packaging materials, properly coded finished products and distribution to the customer is critical for an effective traceability program.”
But he said to also make sure you’ve got the right people on your team, which should include cross-functional members of the facility. Usually, they’ll also be part of the food safety team, but you need input from production and warehouse managers as well.
“And all those complementary functions can add to collecting all of that data, because the production manager might know exactly how something is produced,” Martell said.
Schrick said another first step, and one that is a potentially challenging choice, is deciding how you’ll code incoming materials. You can either use your suppliers’ codes or establish your own unique codes for those items.
There are positives and negatives to both, she said. If you use someone’s existing codes, chances are you won’t have to deal with a lot code being misread, and it’s one less step to take when tracing backwards. The advantage to a unique code is you could set up a barcode system, which allows for greater control and traceability throughout your process.
“But it’s also more costly,” Schrick said. “[You have to] weigh out if it’s worth the cost of a recall if you’re not able to potentially track something properly.”
“The more efficient we are at tracing our finished products to the market, the more our consumers are informed and kept safe.” – Rod Martell, a food safety auditor at AIB International
Like anything else, there could be stumbling blocks along the way. But being prepared, as they say, is half the battle. Obstacles include not recording or mis-recording data around raw materials, packaging materials and food contact packaging materials right at the point of use.
“Sometimes they forget to do that,” Martell said. “But if you don’t do that, you can’t trace it. You can’t trace the end product.”
Also, it’s really important to make sure your finished product is coded properly so the consumer can easily identify it and report that info back to you.
“One of the opportunities is a lot of facilities do not document the lot numbers for the packaging material that goes into that finished product,” Martell said.
Traceability is a key tool when it comes to recalls and limiting foodborne illness, but a robust plan can also help reduce food waste and save you money.
Since some companies might opt for a first-in, first-out method for keeping track of food contact packaging materials instead of lot codes, it’ll be harder to pinpoint the correct production run if there’s a recall due to the packaging itself.
“In the event of a recall, they would have to pull extra production dates from the market before and after the actual production to ensure they have pulled enough product,” Martell said.
If, instead, the company recorded the packaging lot codes from the beginning, they could have zeroed in on the specific dates the code was used.
“If a certain day was the issue, they pulled too much product from the marketplace,” Martell said. “You’re pulling product that your consumers want.”
Trace Raw Materials
Too often, Martell said, facilities will just trace their finished products during traceability exercises in an effort to find out where it went. But testing with raw materials is important too.
“Sometimes the raw material is the problem,” he said. “It would be beneficial to also test the raw material forward to see all the finished products that contained that raw material.”
For example, if you pick a raw material such ascorbic acid, one lot code could go into 15 different SKUs. Martell recommends testing traceability on raw materials at least once a year.
Schrick advised making your mock traceability exercises part of your overall mock recall program. With so many moving parts, you want to see how each of your groups involved in the recall will work together, since a recall involves so many parts of a facility.
“Review your mock recall exercise frequently, and then maybe do your mock traceability exercise more frequently than you would do an entire recall,” she said. “But at least be able to test the full recall annually and review that with all of the relevant teams so that they know their part.”