Developing Traceability to Prevent Recalls

With recent Salmonella outbreaks involving peanuts and pistachios dominating the headlines, an inordinate number of recalls have occurred across the food industry. The recall notices for these nut products, which are used as ingredients in many types of foods, include phrases such as “may have been contaminated” and “potentially may be contaminated with Salmonella because of the inclusion of the suspect peanuts/pistachios.” This language suggests a lack of traceability of ingredients going into many finished products.

So how can a company build traceability into its products? A verifiable system of tracking ingredients from supplier through distribution can mitigate the scope of a recall or even negate the necessity of a recall altogether. While this article will focus on the food manufacturer, the principles included are applicable to each point on the food chain from ingredient supplier through manufacturing to distribution through retail or food service outlet.

Food facilities generally have an operational flow of:

• raw material receiving;
• raw material storage;
• production;
• finished product storage; and
• shipping.

A good traceability model is concentrated in the areas of raw material receipt, warehousing, production, and quality control (QC). This model should emphasize a system of documenting redundant references to product and material codes throughout the supply chain.

The Traceability Train

For all companies, traceability begins at the receiving dock. All suppliers should be required to go through a qualification process that includes a quality systems audit. Part of that audit should document that the materials supplied by the vendor are traceable to their source as well as through their unit operation. All material should be coded with appropriate lot numbers that appear on the product containers delivered to a company’s back door. At the time of delivery, receiving personnel should check that the lot numbers correspond to the product received. QC, as part of the raw material qualification process, should verify the shipment as well.

Proper warehouse practices are necessary to maintain the traceability of raw materials as well as finished product after manufacture. It is the responsibility of the warehouse to link the lot numbers of the raw materials to their receive dates and any in-house material codes. To ensure proper product flow, “First In First Out” inventory methods are required for the handling of both raw and finished goods. While this may be done manually, there are many forms of software available to assist with this function.

When shipping finished products to distribution, the warehouse should document on all bills of lading the production codes and amounts of good shipped. Records of all shipments must be kept on file in order to reconcile and recover product in the event of a recall. To facilitate this process, companies should keep a list of key contacts on file for quick access.

Production is primarily responsible for building traceability into its finished food products. At the time of batching, production personnel must ensure that the proper materials have been withdrawn from the warehouse. They must check to see that all materials have appropriate lot numbers and reject any that do not. During the batching process, production personnel must document on the batch record the lot numbers of the raw materials and the amount of each material used.

As manufacturing proceeds, other traceability concerns arise. One involves the issue of rework. One of the biggest causes for recall is the inclusion of undeclared allergens in a product, and one way undeclared allergens may enter into a food is through rework. If a manufacturer’s process involves rework, it is vitally important to understand what is going into the finished food. Batch documentation, including lot numbers and ingredients of any rework, must be attached to the batch record of the finished good. Think of the rework as another raw material check to make sure that the ingredients in the rework, including allergens, are included in the ingredient declaration on the finished product package. This point cannot be emphasized enough.