Keys to Fitting Traceability into Produce Safety

The first step on the road to preventing the next multistate foodborne illness outbreak is honesty and openness throughout the supply chain, and broader adoption and participation in existing and emerging supply chain traceability tools is an important part of this. The hard work ahead to advance public health protection is much more than instantaneous lot tracking based on distributed ledger technologies (now often and more generically referred to as blockchain) or alternative open-participation traceability platforms. Clearly this is an important investigative tool needed to serve the food industry by assisting public health agencies during an emerging outbreak.

However, it is also a largely retrospective tool as far as illness prevention is concerned. It is activated several steps after an outbreak is recognized and the hypothesis generation and epidemiological process has begun to focus in on a common, implicated food vehicle.

Having an unbroken and timely traceability chain may prevent further exposure and illnesses by removing contaminated product from distribution, inventory, food establishments, and consumer kitchens, refrigerators, and freezers. Significant enhancements in training and foundational advancements in produce safety systems are needed to provide the unseen but accessible data and documentation layers behind the lot coding transaction ledgers.

Why Trace?

Traceability is a key component in any modern food safety program and can be an important companion tool in quality management and improvement efforts. Adopting a sound- and scale-appropriate traceability system isn’t just good business practice—your operation may be covered by federal regulations under the Food Safety Modernization Act (FSMA). These regulations require a recall program, which minimally dictates having a rudimentary track and trace system in place. The basic requirement is to be able to determine one step back and one step forward in all aspects of product handling and distribution to the end-consumer. This necessitates the ability to determine what product was received, who it came from, and what was done with it. For raw agricultural commodities, current market standards may require product receivers and handlers to have in place a routinely tested and verifiable traceability system to rapidly get back to a harvest date, a harvest crew, a mobile or mechanized harvesting unit, and even a field location.

Businesses meeting the current definition of a farm that are growing, harvesting, handling, or holding covered crops subject to the FSMA Standards for the Growing, Harvesting, Packing, and Holding of Produce for Human Consumption (Produce Safety Standards, or PSS) are not required to have a formal food safety plan or traceability system. Regardless, many handlers, market-standards, and “approved-supplier” audit requirements from buyers mandate at least the one-step-back-one-step-forward tracking capability, including clear and defensible lot coding practices. Sprout growers are similarly covered under the PSS but have additional testing, recordkeeping, and recall-motivated tracking requirement expectations.

Traceability and recall programs are mandated for registered facility businesses that are subject to the FSMA Current Good Manufacturing Practice, Hazard Analysis, and Risk-Based Preventive Controls for Human Food. They must encompass the potential need, based on the hazard analysis, for supply chain controls and oversight management related to the FSMA Foreign Supplier Verification Program.

The ability to trace product into and out of an organization is like taking out an insurance policy: Most times it is not needed, but when it is, it proves highly beneficial. A well-designed and managed track-and-trace program will prove its value in times of crisis and in preserving your organization’s credibility. Recent experiences during the 2018 romaine lettuce outbreaks have, once again, graphically underscored the high potential for substantial collective economic losses and erosion of consumer confidence resulting from lapses and gaps in step-wise, handoff-to-handoff supply chain traceability.