ISO 22000 & Food Traceability
Part V
Critical Tracking Events – An Emerging Traceability Model
The identification of the origin of food
and feed ingredients and food sources is of prime importance for the protection
of consumers, particularly when products are found to be faulty. Traceability
facilitates and precisely targets the recall or withdrawal of foods when
necessary; enables consumers to be provided with targeted and accurate
information concerning implicated products; and is crucial to the investigation
of the causes of food poisoning and other contamination outbreaks. Thus
traceability is an indispensible feature of food safety. Long before there was
any attempt to legislate for traceability, responsible food manufacturers, in their
own enlightened self-interest, operated their own traceability schemes. These
were usually based on the concept widely known as “one-up, one-down,” (OUOD).
The impetus to develop legislation was public and governmental concern in many
countries over food poisoning and other contamination outbreaks (including
potential bio-terrorism), despite all the food safety legislation that existed.
Traceability necessitates that each lot of each food material is given a unique
identifier which accompanies it and is recorded at all stages of its progress
through its food chain.
Issues Prevailing in Product Traceability
Multi-ingredient foods may include
materials from a variety of food chains and countries, importers may have to
rely on the traceability systems (if any) of other countries up to the point of
import. This may be particularly difficult in the case of developing countries.
Obvious areas of difficulty are where a received or sold bulk supply is a
(sometimes heterogeneous) mixture of lots, or where a bulk supply (such as of
grain, coffee, olive oil, rice, and milk from multiple farms) is delivered into
bulk containers or silos, or where a received or sold pallet load of containers
includes a mixture of lots. However, the major problem areas are reliance on
all business operators to maintain adequate records and internal traceability;
and the frustrating slowness when utilizing traceability for outbreak
investigations. This has given rise to the search for a new food traceability
concept that emerged around 2008 and that has potential to revolutionize global
food traceability.
One-Up, One-Down Approach
The OUOD approach requires food supply
chain participants to be capable of identifying, through records maintained by
the company, the immediate supplier and customer of an identified food
material. Although even the smallest of food businesses (at least in developed countries)
typically use some form of accounting system, the normal processes and records related
to purchasing, receiving and shipping products are sometimes insufficient to
fulfill the OUOD requirement or may be unaccompanied by effective internal
traceability or maintenance of the onward integrity of the material identifier.
When investigating suspected food poisoning
or other contamination, investigations using the OUOD approach are tedious and
time consuming. Naturally, the process is serial, in such situations; investigators
must first review documents at the last known supply chain node in order to identify
the next node up the chain. Although regulations vary from country to country,
these usually permit investigators immediate access to records when on site.
Since legal consequences may ensue from any investigation, supply chain
participants are typically permitted 24 hours to respond to specific requests
for information. Assuming each supply chain participant uses the full 24 hours,
it may take days or weeks for investigators to work their way back through the
chain(s) to identify the source of contamination. Keeping in mind that investigators
are often unsure as to the source of contamination, and as multi-ingredient
food products contain materials received from several separate food chains many
such investigations must be done simultaneously. When the source of
contamination is identified, the process is then used in reverse to identify
product for recall. In addition to being tedious and time consuming for
investigators, investigations are often unnecessarily disruptive to many businesses
along each supply chain investigated and more consumers may be adversely affected
in the meantime.
Even if it is assumed that all necessary
data are present and error free, it is clear that this OUOD system is not
designed to point investigators quickly to likely sources of contamination. Adding
real-life complexities related to incomplete, missing or erroneous data simply
adds to the time and tediousness of food recall investigations.
Global Legislation, Impending Legislation
and Voluntary Schemes
A Codex document elaborates a set of
principles to assist competent authorities in utilizing traceability/product
tracing as a tool within their food inspection and certification system. This document
should be read in conjunction with all relevant Codex texts as well as those
adopted by the International Plant Protection Convention (IPPC) and the World
Organization for Animal Health (OIE) where appropriate. Recognizing the dual
mandate of the Codex Alimentarius, traceability/product tracing is a tool that
may be applied, when and as appropriate, within a food inspection and
certification system in order to contribute to the protection of consumers
against food-borne hazards and deceptive marketing practices and the
facilitation of trade on the basis of accurate product description (Codex
Alimentarius, 2006).
ISO 22005:2007 provides a standard for
traceability in the feed and food chain – General principles and basic
requirements for system design and implementation (ISO 22005:2007). The
Agriculture and Rural Development Department (ARD) of the World Bank in
collaboration with infoDev (a global grant program managed by the World Bank to
promote innovative projects on the use of information and communication
technologies) embarked in an effort to explore and capture the expanding
knowledge and use of Information and Communication Technology (ICT) tools in
agrarian livelihoods. In November 2011, the World Bank released an electronic
Sourcebook (e-Sourcebook) to initiate further investment in this sector. Called
“ICT in Agriculture”, the e-Sourcebook provides practitioners within and
outside of the World Bank Group with lessons learned, guiding principles, and
hundreds of examples and case studies on applying information and communication
technologies in poor agriculture. It consists of standalone modules. Module 12
is “Improving Food Safety and Traceability” (ICT in Agriculture, 2011).
The Produce Traceability Initiative (PTI),
sponsored by Canadian Produce Marketing Association, GS1 US, Produce Marketing
Association and United Fresh Produce Association, is designed to help the
produce industry maximize the effectiveness of current trace-back procedures,
while developing a standardized industry approach to enhance the speed and efficiency
of traceability systems for the future (Porter et al., 2011). The PTI has a
bold vision which outlines a course of action to achieve supply chain-wide
adoption of electronic traceability of every case of produce by the year 2012.
The main thrust of PTI has been standardization of data structures and
presentation of data on cases and pallets of produce. PTI is described by the
produce industry as, “ … designed to help the industry maximize the
effectiveness of current trace back procedures, while developing a standardized
industry approach to enhance the speed and efficiency of traceability systems
for the future” (PTI, 2011).
PTI has made great strides in developing
data structure and presentation standards for the produce industry; however,
PTI remains rooted in the OUOD approach. Therefore, benefits from PTI are more
likely to be reduction in data errors and perhaps greater efficiency by supply chain
participants in collection and dissemination of traceability data. However,
since legal consequences of such investigations remain, it is possible that the
time saved may ultimately be consumed internally by company management and/or
legal counsel rather than contributing to any acceleration of investigations
and recalls. Additionally, it is questionable whether PTI can or will be more
widely adopted by other segments of the food industry.
The Global Traceability Standard (GTS) is
promulgated by GS1, an international not-for-profit association with member organizations
in over 100 countries. GTS makes traceability systems possible on a global
scale, all along the supply chain, no matter how many companies are involved or
how many borders are crossed, no matter what technologies are used.
Future of Food Traceability – Critical
Tracking Events
Efforts to improve food traceability
typically identify two major goals, namely speed and accuracy. Standardization
will likely improve accuracy, but will not do much to improve speed. Speed and
accuracy are both necessary to realize benefits from any food traceability
system in terms of illness, lives, waste and inventory control. The OUOD
approach, regardless of data standardization is simply not capable of providing
the speed that will be required by the industry or regulators.
The Critical Tracking Event (CTE) concept
is becoming widely accepted as the path to a next generation fast and effective
food traceability system (McEntire et al., 2010). The CTE approach is a
bottom-up approach that is inherently secure in terms of data ownership, data access
and proprietary information protection. The CTE approach recognizes that each operator
knows their own operations best and provides complete latitude as to how to
collect CTE traceability data. The CTE approach shifts focus from the food
product itself to the events that manipulate the product in the supply chain.
As each operator handles a food product (harvests, creates, receives, mingles,
aggregates, palletizes, depalletizes, relocates, ships, etc.) its actions are
viewed as events that occur at specific locations, dates and times. Some of these
events are critical to the ultimate traceability of the product. Therefore,
those events are deemed to be “critical tracking events.” Since a CTE is
essential to ultimately tracking the item in the supply chain, CTE traceability
requires a commitment from operators to collect, store and make retrievable,
CTE data from every CTE within their operation. The modern concepts and
technologies associated with relational distributed data provide confidence
that the CTE model will be much more effective in terms of speed and accuracy. Unlike
other approaches that are mired in exhaustive data field identification and standardization,
the CTE approach requires very little data, none of which need be descriptive
in any way of the product.
Since the goal of the food traceability
system is to connect investigators with the source of contamination as quickly
as possible, there is little value in collecting large amounts of even standardized
data from every node in the supply chain when only a few or even none of the nodes
may be of actual interest to the investigation. Rather, it would be preferable
to skip nodes that are not interesting to the investigation, saving precious
time for investigators as well as time and angst for many food businesses. This
ability of the CTE approach to quickly and effortlessly elucidate the actual
supply chain through CTEs is the major benefit over OUOD based approaches
regardless of data standardization. Additionally, once the source of contamination
is identified, the CTE based food traceability system is just as capable of
trace forward as trace back, which means that rapid, targeted and accurate food
product recalls will be possible. The IFT’s current working definition of a
critical tracking event is A CTE is any occurrence involving an item at a
specific location and time associated with collection and storage of data
useful for associating the item (or related items) to the specific occurrence
at a later time and is determined to be necessary for identifying the actual
path of an item through the supply chain.
When applying this definition, it is easy
to see that the many important and often proprietary business process data are
not necessary to achieve traceability with CTEs. Basic handling/transfer CTEs requires
the minimum amount of data, which includes a code to identify the item, a code
to identify the particular CTE (e.g. “received at ABC Co. at door #2”) and a
date and time stamp. Transformative CTEs (mixing, repacking, etc.) require
additional information to link the inbound and outbound product-codes.
Under the CTE approach, each operator would
determine how best to collect and store data. Some might be able to maintain a
CTE Server on-site. Smaller businesses might choose to house CTE data at a
third-party (cloud) based service provider. Regardless, CTE data remain the
property of and under the direct control of the business generating CTE data.
When an outbreak occurs, investigators
would be able to query the CTE traceability system by asking, “who has seen
item code XYZ?” CTE servers might first alert a company that an appropriate
authority has made a formal request. The company could then review the request and
authorize a response. The initial response could be minimal in terms of “no”
(the item was never seen by our CTEs), or “yes” (the item was seen at these
locations at these dates and times). Transformative CTEs would provide the link
between products and ingredients. At this point, investigators would be able to
clearly visualize the supply chain for the item in terms of locations, dates
and times. Assuming other investigations are on-going, there may be nodes that
are common to separate investigations (e.g., sprouts from a deli sandwich and
sprouts from a restaurant salad bar). In such cases, investigators would be
drawn directly to the point of convergence rather than working their way
backwards through a cumbersome OUOD system.
Companies may choose to use or not use
existing product codes or coding schemes. The CTE traceability approach simply
requires product codes that are globally unique (Welt, 2008). Since many
current industries coding schemes use qualitative information as part of the
code (e.g., PTI combines UPC/GTIN with lot numbers) and since proprietary
information may be gleaned from codes with meaningful business data, it is
recommended that codes expose no valuable information themselves, but rather
point to relevant data for retrieval by properly authorized personnel. For the
case of PTI codes with exposed lot number information, someone might be able to
glean competitor production rate and/or volume by analyzing rates of changes of
lot numbers in product codes. This can be avoided by associating the CTE
traceability code to appropriate lot numbers within the enterprise database.
Identifying the lot associated with a particular item would be a matter of a
simple database query and can be done by appropriately authorized personnel.
Implementation of CTE traceability does not
interfere with any existing business processes. However, CTEs require a
commitment by operators to collect, store and make available for retrieval a
minimal set of data that is inherently secure through abstraction, separation
and restricted accessibility. Operators can choose the most appropriate manner
to collect data from manual entry to sophisticated automated scanners. Once CTE
data are captured and available for query, investigators will no longer need to
stop at each node in the supply chain in order to learn where to go next. CTE
based traceability promises to greatly accelerate the rate of trace back
investigations as well as the precision and speed of recalls.
Document Courtesy: IUFoST Scientific Information Bulletin (SIB),
March 2012, Food Traceability
http://www.iufost.org/iufost-scientific-information-bulletins-sib
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