If you subscribe to the U.S. Food & Drug Administration’s (FDA) Recalls, Market Withdrawals and Safety Alerts, you’re well aware that food recalls occur almost daily. Few of these product issues receive nationwide publicity like this summer’s recall of 380 million infected eggs or last year’s Salmonella-tainted peanut butter.
But even small and localized recalls, such as mislabeled products containing dairy or nuts, have a large impact on consumers and manufacturers. The safety regulations a local supplier must follow are the same for national suppliers, whose product recalls become ingrained in the minds of American consumers. In fact, safety has become such a major issue for consumers that the FDA has supplemented its e-mail recall alerts with a mobile phone application that allows shoppers to download current recalls for any product.
Following this year’s midterm elections in November, politicians approved the FDA Food Safety Modernization Act. The bill, if signed into law, would provide:
- increased inspection of food manufacturing facilities, including annual inspections of high-risk facilities;
- expanded FDA authority to order recalls; and
- new standards similar to those set by the Global Food Safety Initiative (GFSI) and hazard analysis and critical control point (HACCP) systems.
There’s no question that the Food Safety & Modernization Act creates more stringent standards for food manufacturers, closer oversight of individual suppliers, and higher penalties. The Senate approved the bill November 30, and it will be sent to the House for action.
One thing the bill will not give anyone is a full-fledged commitment to tracking and tracing technology. The bill only calls for a pilot project to explore and evaluate methods to rapidly track and trace foods in order to identify the source of an outbreak and the recipients of the contaminated food. This pilot project includes methods that are applicable and appropriate for small businesses and technologies, including existing technologies that enhance trace-back and trace-forward. No later than 18 months following the end of the project, the Secretary of Health and Human Services is to report the results to Congress and must publish a notice of proposed rule making establishing standards for rapidly tracking and tracing a foodborne illness outbreak within three years of the bill’s enactment.
As technology professionals, my colleagues and I know that any technology viable today will most likely be obsolete in three years. And as consumers, we’re all concerned about potential future outbreaks that might occur in the three-year period prior to a notice of proposed standards, plus the additional time for the enactment of the proposal as law.
While the act itself may have good intentions, best practices call for companies to move forward today with track-and-trace methods and technology that gives them the power to track products back to the ingredients and sources and forward to their customers.
For instance, the FDA maintains certain rules about chicken processing but rarely, if ever, addresses the role technology can play in decreasing the likelihood of contamination. Consequently, while companies employing those technologies are not necessarily more compliant, they do leverage the investment in their marketing to take market share from competitors.
Some of the latest technologies helpful to producers and processors are software solutions that provide a visual “traceability map” that gets away from the conference room table approach of manual documents or spreadsheets. A traceability map doesn’t require time-consuming, deep analysis to figure out the source of ingredients and the destinations or recipients of lots containing these ingredients.
This speeds any potential recall process and reduces the time required to trace an ingredient from hours or days to minutes. This type of technology will become increasingly important as more retailers demand that their suppliers conduct mock recalls to prove that the organization can react quickly to a recall if necessary and can pinpoint recalls to only contaminated lots, minimizing exposure and protecting brand perception.
Increased Inspections on the Horizon
While pending legislation isn’t keeping up with consumer demand for track-and-trace methods and technology, it does contain language that will fund more government inspections. Many of us watched the attention the fishing industry received when the Gulf of Mexico was reopened to fishing and shrimping after the largest oil spill in U.S. history. The National Oceanic and Atmospheric Administration teamed up with the FDA to conduct tests and declare the seafood safe to eat.
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