Traceability: Costs, Benefits, and the Future

From time to time the food industry and regulators seem to place great emphasis on the need to improve traceability. And yet, with focus in the U.S. on FDA’s proposed Food Safety Modernization Act (FSMA) rules, traceability seems to be taking a back burner. Still, there are pockets of activity, both in the U.S. and around the world, that direct some focus back to product tracing and traceability. Sometimes these are driven by public health and the inability to solve outbreak investigations, and sometimes they are driven by the economics of running a business.

While the term “traceability” is quite familiar, the range of concepts associated with traceability is broad. Many equate traceability with recall, as in “My company has great traceability. We successfully perform a mock recall every year/quarter/ etc.” Certainly being able to follow the flow of your products is important, but there’s more to traceability than simply knowing where you received product from and where you sent it.

Pinpointing Challenges

As an example, let’s look at the Cyclospora outbreak(s) of this past summer. This didn’t make headline news, despite the fact that over 300 people became ill. In an event like this, the first questions that are asked are “What is causing illness? Is it even a food product? Are these illnesses related to each other?” Epidemiologists, initially at the state and local level, play a critical role in developing answers to these questions and work hand-in-hand with the regulators who initiate tracebacks on suspect products. At this point, investigators are still trying to figure out the food(s) causing illness—don’t expect them to know the brand names, lot number, purchase order (PO) numbers, etc. yet! They are looking at the numerous “starting points” where people who became ill purchased or ate food, and following all of those pathways back to see if they intersect to determine if the ill patients have something in common.

And yet, when the food industry tests their internal traceability systems, they are often starting with the name of the product, lot numbers, PO numbers, etc. In the instance of the Cyclospora outbreak, the best the regulators could do was hypothesize that the cases in Texas were related to cilantro from Mexico, which was supported by the traceback investigations.

But as the investigation went on, the illnesses decreased until CDC declared the outbreak was over. We can’t definitively pinpoint the cause, and therefore, we’re far from being able to implement corrective or preventive actions to stop this from happening again.

Sometimes determining what two different foods eaten in two different locations have in common can be challenging. Real-life difficulties in traceability sometimes prompt regulatory change. Take, for example, ground beef produced at retail.

New—Recordkeeping in Retail

On July 16, USDA announced a new proposed rule, “Records to be Kept by Official Establishments and Retail Stores that Grind Raw Beef Products.” What prompted this? A 2011-2012 ground beef Salmonella Typhimurium outbreak impacting 20 people in seven states in which the actual source of contaminated beef could not be determined. Although the implicated meat was known to have been sold by Hannaford grocery stores, the investigation was unable to trace the meat back any further to determine the supplier because the retailer kept only limited records.

The rule, as proposed, would require retail outlets that make ground beef by mixing cuts of beef from various sources to keep clear records identifying the source, supplier, and names of all materials (including carryover) as well as their lot numbers/production dates used in the preparation of raw ground beef products. The proposed rule also requires records related to sanitation that help determine the “clean break” between lots of ground beef.