On March 4, the FDA released its report on two product traceability pilot projects launched in 2011 as part of the implementation of the Food Safety Modernization Act.
The two pilots, carried out by the Institute of Food Technologists (IFT), focused on foods recently linked to foodborne illness outbreaks—tomatoes in one pilot and chicken, peanuts, and spices in processed foods in the other. The goal: To identify potential methods of improving product tracing of foods in the supply chain and of identifying the final recipient of a contaminated food in order to address threats of serious adverse health consequences.
In all, IFT was able to conduct 14 mock tracebacks or trace forwards. “The process of conducting a stepwise product tracing investigation was complicated and often times confusing,” the report noted. “Inconsistencies in the terminology, numbering systems, formatting, legibility, and occasionally the language sometimes required IFT to contact the submitting firm to gain clarity…However, the pilot participants appeared to have many of the tools and processes in place which are required to allow the capture and communication of critical trace and track information.”
The report includes 10 recommendations, including calling for the FDA to establish a uniform set of recordkeeping requirements for all FDA-regulated foods with no exceptions based on risk classification and to require each member of the food supply chain to develop and implement a product tracing plan.
“The report really validates many of the assumptions that we’ve had—that food traceability is not where it should be and that there’s a difference between internal and external traceability,” says Angela Fernandez, vice president of retail and grocery for GS1 US, a member of the Product Traceability Initiative. “We’ve been hearing a lot from industry that this confirms what we thought were the opportunities to do traceability better. They know that the recommendations that came out of the IFT report will drive the traceability rules coming from the FDA, although no one is sure when that will be issued. But in the meantime, industry can continue to work on where they’re headed, such as working to define what we consider a critical event and some of the key data elements involved.”
Fernandez praises the recommendation to consider all FDA-regulated foods as one in terms of traceability. “The mindset of food companies today is that you’re only a non-high-risk product until your first recall. There’s a strong sense within industry today that to protect the consumer, we need to treat all food products the same way.”