Recalls – Why Prevention Bests Management

With food safety again making headlines, I thought it was a good
time to discuss the ever increasing rate and impact of recalls on
the global food supply. While there are numerous challenges in
tracking and traceability systems solving food safety issues, there
are some fundamental issues that are critical for the industry to
address. Today I want to focus on how traceability systems
traditionally have focused on managing recalls and not on
prevention.

There’s been a relatively recent and elevated recognition
and concern for the role of food-borne illness, but even in the
early to mid 1990s, many sectors of the industry had established
complete and robust traceability initiatives well before the U.S.
Bioterrorism Act of 2002, which required tracing “one step
forward and one step back” throughout the supply chain.
Though most farms are exempt from this registration and mandatory
record-keeping requirements, several commodity groups and
individual businesses implemented rapid traceability and
trace-back/trace-forward capabilities that included coding
information back to a grower or even a ranch
harvest-block. 

Naturally, in any traceability system, once the labeled carton or
shipping unit is gone, the system may have great difficulty in
rapidly isolating the source of an issue to a particular region,
packer or farm. An additional concern, even with these and other
exemplary systems, is that the language of lot identification is
not uniform, and lot integrity may not be constant during
distribution. Carton re-use and re-sale is another recognized issue
that may interfere with effective traceability. 

Therefore, it is  important to take a prevention focused view
of food safety. The first priority of traceability is to protect
the consumer through faster and more precise identification of
implicated product. However, to proactively identify issues, detect
problems and prevent contamination in the food supply, traceability
needs to be integrated into lab testing, audits and quality
management systems along the entire supply chain.
Part of this challenge is automating highly manual-based quality
management standards, including SQF and ISO 22000. Traditionally,
auditors have to wade through stacks of paper to determine whether
companies are complying with standards. 

By linking traceability with audits, lab testing and quality
management systems, it is possible for manufacturers to track
trends in their food safety efforts, identify trouble spots and
protect themselves and their consumers by eliminating mistakes.
Traceability is the key to executing a proactive retrieval of lots
implicated in a suspected or confirmed event. A quiet (notification
not required) non-release or reverse-distribution of product that
remains under the control of a produce
shipper or handler is highly preferred, given the negative
consequences of a recall notification by buyers or public health
regulators. 

Though frequently referred to as a “market withdrawal,”
this term is not strictly accurate for most produce shipping
situations in the context of its FDA definition. Market
withdrawal occurs when a product has a minor violation that
would not be subject to FDA legal action, as would be the case in
knowingly shipping altered food. This situation has become more
common as pathogen testing has expanded. Newly enhanced
traceability capabilities have undoubtedly played a key role in the
rapid electronic notification and lot identification to prevent
suspect product from reaching retail shelves and consumers. All of
this is viewed as a positive and proactive approach.