Just because you have a great recall plan does not mean that you have great traceability.
Just because, when given a lot number (whether of an ingredient you used in production, or of a finished product released to a customer), you are able to determine where it went in less than 4 hours, or 2 hours, or 2 minutes—it does not mean that there are no traceability issues.
I have distinguished traceability from recall hundreds of times as I have talked about these topics, and it’s only when people are confronted with the plight of the regulator that they begin to understand that traceability is not defined by what happens within the four walls of a facility. Traceability is something that is needed system-wide.
Let’s walk through an example: someone get salmonellosis in Milwaukee. A couple gets salmonellosis in San Antonio, and a family falls ill from salmonellosis in Long Island. The science shows that they are all sick from the exact same strain of Salmonella. Public health officials in each location suspect that it’s from the same source, but how can they get to the root of this outbreak? The answer is: traceability. And yet this type of scenario is never one that food companies think of when doing the traceability tests required to satisfy audits.
In the example above, health officials begin with absolutely no information about the specific food that caused illness, let alone the lot number. It is through asking a series of questions (and maybe looking at shopper cards and credit card receipts) that they begin to narrow the realm of possible food items to a few sources.
At this stage it would be lucky if a particular “brand” popped up as being in common between the three populations. Once health officials have a good sense of possible foods and the locations and rough dates (or date ranges) when they were purchased, this is when record-keeping comes into play. Regulators in each state ask for records and keep moving back in the supply chain, hoping to find some common point. When products change names, when a whole truckload of product is assigned a single license plate number, when there is some fuzziness in exactly which lot of ingredient went into a specific batch of finished product—all of these things hinder the investigation that is attempting to get to that singular point in time and location where something went wrong.
Once the traceback can determine what happened, then a recall can ensue. If its an ingredient that has been distributed to several manufacturers, then tracking the use of that ingredient (and any rework containing that ingredient) can be challenging, not only for the manufacturer, but for a whole supply chain when the ingredient may have passed through brokers and distributors before being used.
So what does this mean to a single company, or a single facility? A company can only manage products (and ingredients) during the part of the journey that the company is responsible for. A company can’t be expected to know the capabilities or deficiencies throughout the supply chain (and in fact, most companies have no idea who all is in their supply chains). But in fact, companies can use the principle of the one up/one down approach discussed in previous posts to determine if their immediate supply chain partners have adequate internal traceability systems, and also (and critically) if the “handshake” between a supplier and a customer provides the 1:1 relationship between what was shipped and what was received. This can be done by matching up lot numbers (my first preference), or, if that is impractical, bill of lading numbers (my second choice), or as a third choice, purchase order numbers (POs can be split across shipments, and POs are much less likely than bills of lading to contain discriminating information such as lot numbers which is why it is lower on my list). Invoices typically don’t contain useful information related to traceability.
As you consider your company’s traceability processes and systems, put yourself in the shoes of a regulator looking to get to the bottom of an outbreak investigation. If you’re asked to provide records for a range of dates, or for a set of POs or BOLs, how quickly could you provide this information and provide any interpretation needed (e.g, the first three numbers of the LPN are the Julian date)? Expand your definition of a “mock recall”—and evaluate the risks in your supply chain to minimize the chance that you’ll be involved in an outbreak investigation!
Learn more about the role technology plays in effective traceability in today’s food processing business – join a panel of experts for Blytheco’s upcoming webinars:
- The Role of Technology in Food Safety and Recalls – July 16, 1pm ET. Register here.
- The Role of Technology in Food Processing Compliance and Traceability – September 25, 2pm ET. Register here.
Jennifer McEntire, Ph.D., Vice President and Chief Science Officer for The Acheson Group, former Senior Staff Scientist and Director of Science & Technology Projects at the Institute of Food Technologists.