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.

Such a system can also be used defensively or offensively in a product quality claim or dispute, in conjunction with an internally or externally activated stock recovery, market withdrawal, recall, or related to an outbreak investigation. One of the key benefits of a good traceability system is that it expedites removing your company from the implicated pool of suppliers in the event of a recall or outbreak. Another benefit is that it can rapidly and efficiently provide implicated lot information for public health investigators as they conduct a traceback effort based on epidemiological evidence. Equally, rapid and definitive tracking allows you to communicate clearly and in a timely manner with your customers and, ultimately, your customer’s customers along the supply chain.

The Required Elements

The requirements of a good traceability system are capturing and recording the key data elements at the critical tracking events.

Critical tracking events are those instances where product is moved between premises, is transformed, or any instance that is determined to be a point where data capture is necessary for effective tracing. Specifically, the critical tracking events are:

1. Transformation input (used to create another product or item);
2. Transformation output (product creation or manipulation);
3. Shipment;
4. Receipt;
5. Disposal; and
6. Consumption.

The ability to query and extract key data elements in a seamless manner is critical. The key data elements that should be digitally captured, stored, and electronically retrievable are:

• Item number or Global Trade Item Number (GTIN) and uniquely identifiable product description*;
• Quantity on hand;
• Physical location at which the product was last handled, whether at the packer, processor, or another location;
• Incoming lot number(s) of product received;
• Amount of product created, packed, shipped, consumed, or eliminated from lot association;
• Continuity of an incoming lot or record of lots included—for example, following comingling or repacking to create a new lot code;
• All physical locations to which cases were shipped;
• Lot number(s) shipped to each location;
• Date(s) and time(s) product was received and/or shipped to all locations;
• Date(s) and time(s) each lot was packed, processed, or harvested; and
• If applicable, all ingredients used in product, with lot numbers, facility at which they were manufactured, and date(s) and time(s) they were received.

There are many system applications that record the key data elements at all critical tracking events in use in the fresh produce industry today. Some of these applications are utilizing the blockchain data sharing protocol while others run on proprietary databases. These applications are designed to provide supply chain transparency while also providing traceability. The value of these visibility platforms is to gain a supply chain-wide view of the products from harvest through to point of sale to the consumer to identify when there are delays, unnecessary steps, or less-than-ideal conditions. It is reasonable to anticipate that transparency in time temperature controls for food safety, alluded to briefly below, would also be captured and visible in modern traceability systems.

Complete “mass balance” of each lot is an attainable goal of sound traceability systems. Ability to account for 100 percent of product received or created is a must. It is equally as imperative for lot number and manufacturing facility to appear on each case of product, and lot number(s), quantity, and shipping location to appear on invoices and bills of lading as well.

A fresh produce industry best practice capable of executing case-level tracking is the Produce Traceability Initiative (PTI) label, which is foundational in functioning as the bridge between the physical goods and any of the tracked information that would be contained within blockchain’s virtual ledger—composed of blocks of linked and sequential data. All traceability systems should be regularly audited, and effectiveness of recall implementation tested to ensure the procedures and training are current and effective.

One of the mandates of FSMA is that FDA work with industry and both assess and conduct pilot traceability programs to improve public health protection. PTI is currently working in conjunction with FDA for evaluating the fidelity and sufficiency of traceback data for these audits and tests, as well as functionality, as in the event of a product recall.

Standardized and Interchangeable Platforms

Data tracking and collection will be imperative in the coming years. Data stand to become the next most used natural resource. Of the 2.5 quintillion bytes of data created each day across all industries, only 1 percent is collected, analyzed, and used. There is a large opportunity for blockchain and other technologies to collect data and turn the resultant data mining and analysis into insights and quick actions. This capability will benefit traceability as well as other key aspects including the design, implementation, and oversight of produce safety systems.

Clearly, these digital platforms will be helpful in that they do allow investigators to trace data digitally all the way back to harvest, and beyond into crop management inputs, upon request. This is a significant advancement over the basic requirement of bi-directional one-step increments already in place within many traceability programs, and not just among the larger producers. A diversity of data capture and software solutions are available, but, unfortunately, not all inter-compatible.

It is predicted that these digital platforms will be able to link a valid food safety audit to each transaction. This will validate that there is a credible, basic snapshot verification of practices and all supporting required and additional documentation and records are in place from each participant in the supply chain.

Produce Marketing Association (PMA) recently led an effort to enable this process by developing the Trellis Data Framework for digitally sharing audit data. There are also alerts that can and are being set up to flag when there is a discrepancy or violation of time, temperature, humidity, etc. that will complement supply chain visibility applications/platforms in using blockchain technology to supplement food safety systems.

There are many examples of where blockchain technology is being used with PTI and the Trellis framework to record and share relevant audit data across the supply chain. Perhaps the most well-known of these examples is Walmart’s use of IBM’s blockchain technology to monitor and track the data of its fresh produce supply and distribution. Other instances include the Dole Food Co. working with Centricity, a grower-owned partner, to leverage the Trellis framework to connect audit data to the blockchain. These types of pilot programs and collaborative efforts help provide the produce industry with mechanisms to standardize data sharing for more efficient and timelier traceback.

As it stands, the too-common experience is that the “last mile” to the point of purchase or point of consumption is the weakest link in the currently complex and too often gap-plagued supply chain trace-forward-trace-back sequence. This means that the lack of lot numbers and clearly identifiable product information being recorded by buyers or distributors/wholesalers creates a broken link and barrier to establishing clear supply chain convergence in traceback investigations. This invariably slows down or stalls the investigation, limits uncovering the full scope of implicated product distribution, or results in failure to identify a minor, but widely distributed and consumed commodity or ingredient.

While blockchain technologies and traceability systems will help close this gap, traceability itself is unequivocally incapable to fundamentally improve the foundation of food safety programs, and the prevention and mitigation of contamination. Traceability programs, in reality, are the insurance coverage activated only for recalls and foodborne illness outbreaks.

People have a deep, emotional connection with their food. When they hear that there is a problem, they want to know what it is and that the information they are getting about their food is accurate. We often speak about the “race to disclosure.” Speed matters; the faster we can get accurate information to the consumers, the better the outcome for all parties. Traceability can help create strong food safety programs and help build consumer confidence. We as an industry need all participants in the supply chain to do their part in order to have effective whole-chain traceability.

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Dr. Suslow is vice president of produce safety for PMA. Reach him at [email protected]. Treacy is vice president, supply chain and sustainability, at PMA. Hepner is director, technology, at PMA. Reach her at [email protected]. And Estes is PMA’s vice president of technology.

* For specialty crops, a uniquely identifiable product description should provide more detail than a category, such as sweet cherry, and should provide a recognized varietal name. Variety differences have proved to be important in projections of defining shelf-life expectations during outbreak investigations and in developing public advisory notifications.