IFT’s Traceability Pilot Projects: Should All Food Be Treated Equally?

The Institute of Food Technologists’ (IFT) “Pilot Projects for Improving Tracing Along the Food Supply System—Final Report” covers two food tracing projects sponsored by the FDA. In its report, the IFT recommends that the agency establish a uniform set of recordkeeping requirements for all FDA-regulated foods and not allow exemptions based on risk categories or the size of the firm involved.

In addition, the IFT recommends every company involved in the food supply chain should be required to develop, document, and exercise its own product tracing plan and to identify and maintain records of so-called key data elements (KDEs), such as lot or batch numbers, to make product tracking more efficient.

“We think these recommendations are sufficient and directly on point,” says Angela Fernandez, vice president of retail and grocery for GS1 US, a member of the GS1 international supply-chain information standards organization. “The pilots validated the reality of what’s happening inside of the food supply chain today. The recommendations address all of the challenges that companies are facing.”

The FDA is currently accepting public comments on the 334-page report through July 3, 2013, after which it will submit its own recommendations on food traceability requirements to Congress and then prepare proposed regulations—steps required by Section 204 of the Food Safety Modernization Act (FSMA). While the law requires the FDA to establish recordkeeping requirements only for “high-risk” foods, the IFT recommends that this should be extended to all food categories because “low-risk” products can quickly become “high-risk” when an unexpected outbreak occurs.

Tomatoes, Kung Pao Dishes, and Peanut Butter

In September 2011, the FDA tasked IFT with conducting two traceability pilots, one involving produce and the other processed foods. FDA selected tomatoes for the produce test because they’ve been implicated in a number of significant outbreaks from 2005 to 2010 and their supply chain can be complex. The agency chose frozen Kung Pao-style dishes containing peanut products, red pepper spice, and chicken for the processed food test because they contain multiple ingredients implicated in outbreaks and they too move through a variety of supply channels. Finally, jarred peanut butter and dry, packaged peanut/spices were included “to enhance the complexity of the pilots,” according to IFT.

IFT convened a group of federal, state, and local traceback investigators to establish an historical “baseline” of the time and effort involved in various investigations. In all, 45 food industry participants voluntarily submitted data to be analyzed in the pilots. IFT also selected 10 technology vendors from companies that had volunteered to showcase their capabilities using blinded pilot data. Deloitte Consulting and Auburn University helped conduct cost-benefit analyses. “This was not a laboratory experiment,” recalled Jennifer McEntire, PhD, a senior director at Leavitt Partners’ food safety practice who worked with IFT on the pilots and coauthored the final report. “We simply didn’t have the time to ask people to implement hardware, software, or procedural changes within their facilities. We assembled a diverse group of about 45 industry members and worked with the records they had, and examined the systems they used for recordkeeping,” Dr. McEntire wrote in a March 7, 2013 blog posting.

Using current technologies to analyze company-supplied data, IFT found that it was “tedious and difficult” to sort through hundreds of pages of documents. IFT also found that confusion arose when data definitions were lacking; delays occurred when item descriptions were inconsistent or wrong or when information was incomplete; and sources were hard to identify because companies often went by different names. The pilots highlighted many areas for improvements and in its final report, submitted to the FDA in August 2012, the IFT made 10 recommendations. They include the following.