Letters to the Editor

• Defining where traceability fits within a Food Event Cycle;
• Defining if a company is proactive or reactive in nature;
• Determining how data can be visualized to afford near real time product movement so to associate or dis-associate a company’s product with a food event;
• To explain to the government the pit falls of using products like the GS-1 as recommended by the PTI; and
• Cost.

How a company engages food safety and traceability is a dynamic entity. We can look at prevention measures, inspect them, conduct mock recalls, measure recall times, but when it comes to traceability, it’s about the how fast the response is once a contaminated product has been identified. The pilot traceability study discovered that if a company has a standard to operate from, it’s pretty easy to comply with a request. This where I have concerns with the report. It was discussed that KDEs CTEs and others similar to the PTI and GS-1 are deposited in a centralized database that traceability can be managed so to reduce the time needed in containment. This is very difficult process and I feel does not present a solution which is manageable. If you review the difference between food events that are short in duration against ones being long in duration, two factors come into play. First, the timed needed to go from the competition of the isolation component of a food event to the start of the containment side of a food event. Second, the association or disassociation of possible products and suppliers.

I strongly feel that the continued referring to the GS one and other standards is wrong. Industry companies have complex and proprietary inventory management systems, which they are not about to change. Nor does the current law require them to. If traceability is going to work industry has to come voluntarily. This means that traceability has to be managed in such a way that industry has no issue supporting the data requirements of a near real-time centralized database. Additionally, the government has to accept that there will never be a solution to all food outbreak problems without a complete overhaul of how we detect food outbreaks today. The only way solutions such as recommended by the PTI can ever be realized is that the entire food industry operates from a single standard. If the FDA was to evaluate the costs surrounding such a concept, they will come to the conclusion that it’s impossible and can never be achieved.

—John F Granich, President CEO, US FoodTRACK