Blog Archive

Friday, September 26, 2008

Traceability: Standards and legal requirements

There has always been a degree of traceability within the food processing industry, with individual companies able to identify both their suppliers and customers. In recent years however the role of traceability in the control and safety of food has been identified as requiring greater transparency and regulation. This has been achieved by the development of international standards, industry guidance and legislation.

The Codex Alimentarius Commission (CAC), was formed under the joint sponsorship of the United Nation’s World Health Organization (WHO) and Food & agriculture Organization (FAO) in 1962, to develop international standards for food safety. The main purpose of the CAC is to protect the health of the consumer and ensure fair trade practices by developing standards based on sound scientific evidence. The World Trade Organization (WTO) has designated CAC the organization with the responsibility for setting trade disputes relating to food, specially as they relate to the Codex standards of Application of Sanitary and phytosanitary measures (SPS) and the Agreement on Technical Barriers to Trade (TBT).

General Standard for Pre-packed Food (GSPPS)-

¨ The country of origin of the food shall be declared if its omission would mislead or
deceive the consumer.
¨ When a food undergoes processing in a second country which changes its nature, the
country in which the processing is performed shall be considered to be the country of
origin for the purpose of labeling.

The details of the product being certified should be clearly documented on the certificate which should at least contain the following information.

¨ Nature of the food
¨ Name of the product
¨ Quantity, in appropriate units
¨ Lot identifier or date coding
¨ Identity and, as appropriate the location of production establishment
¨ Name and contact details of importer or consignor
¨ Country of dispatch
¨ Country of destination


Demonstrating traceability through the records

In order to trace information relating to a specific product in a paper based traceability system it is necessary to firstly identify the “batch identity code” of the final product, which should be clearly indicated on the product label.

Using the batch identity code, individual processing records are then consulted to determine the process history. This can be time consuming since processing records are usually stored in date order and a particular product may have been within the factory for more than one day. There is, however, a problem in that processing records are used for other purposes besides traceability, e.g. HACCP, yields, equipment performance etc. where records are required to be ordered by time/date, meaning that the information needs to be ordered twice, therefore doubling the amount of time completing records within the factory.


Tracing the product through the supply chain

The supply or processing chain is defined as the entire sequence of events that occur from the moment raw material is obtained until the product is consumed. This is often termed “net to plate” approach. In order for traceability to be effective information gathered by an individual company within the supply chain must be shared with others also in the supply chain.The exchange of information operates in parallel with the product through the supply chain. The need for a parallel system of data transfer is because the nature and amount of information linked to a product far exceeds the capacity of either product labels or bar codes.

Verification of Traceability

From the product identification code, or alternatively a bar code on the retail label, it should be possible to trace back through the records of each company in the supply chain. At each link the source and (original) identity of all raw materials s well as the entire product processing/transport/storage history can be traced. In addition to validating its own traceability system (termed 1st party audit) the system may also be validated by external auditors. It is important that such verification of traceability is managed systematically and efficiently. There are many approaches that can be taken to verifying traceability and the following is one example based on “How to Audit”. The management of an audit is divided into the following steps-

¨ Planning and preparation
¨ Conducting the audit
¨ Analysing the results
¨ Agreeing Corrective Actions
¨ Verifying effective compeletion

Demonstrating the importance of traceability

In January, 2002 officials at the German Ministry of Agriculture and Consumer Protection were investigating a report from their Dutch counterparts that shrimp containing the banned antibiotic Chloramphenicol, had been mistakenly exported to a German animal feed manufacturer and had the potential to enter the human food chain.

Chloramohenicol is a powerful antibiotic which restricted use to combat serious infections such as typhoid and anthrax but it is banned from all food products because of a risk that it may cause a potentially lethal form of anaemia. In normal shrimp production, the use of antibiotics is common practice to ensure disease free maximal growth of shrimp at high stocking densities. However, before harvest there is normally a period (10-30 days) where antibiotics are not used. All traces of antibiotic residues are naturally eliminated from the shrimp by being metabolized to harmless products. Over the next few weeks using records that enabled traceability it was found that a Dutch company had imported 27.5 tons of shrimps containing the powerful antibiotic. They had been imoorted into the Netherlands from the Far East. This consignment was tested at the port of entry to the EU and found to contain Chloramphenicol. The normal procedures of either returning the product to the supplier (over 200 tons of frozen peeled shrimps were returned to China in 2001) or destruction and removal from the food chain by incineration were not followed. Due to procedural errors, the shrimp became part of a consignment of 188 tons of fish scraps shipped to a feed marker in the German state of Lower Saxony in November and early December 2001. The shrimp waste was then distributed to six animal feed producers in Germany and three other companies- one each in Denmark, Poland and Romania. The authorities in each of these countries were investigating the records of each to establish whether the contaminated material had been processed into animal feed and entered the human food chain.

Fortunately, recent food scares concerning bovine spongiform encephalopathy (BSE) in the cattle industry had resulted in the implementation of good standards of record keeping and traceability of both raw materials and final products being implemented throughout the EU. This enabled the rapid identification of how the contaminated shrimp had passed through the food chain. Apart from 4 tons of the potentially contaminated fishmeal that had been sold to Danish farmers and had probably been consumed before the problem was identified, the entire contaminated product was identified and prevented from entering the food chain.

This food scare was caused by an error in the procedures employed at the seafood processing company. Although it cost individual companies and Government time and money, it demonstrates how a traceability system can safeguard the consumer. The effects of this incident were widespread, with the EU placing a ban on all shrimp imports from China that resulted in much potential discussion that only just averted a wider scale trade dispute. The example also demonstrates how integrated the food industry has become with the waste of one sector becoming the raw material for another, which makes the supply chain even more complicated and the need for adequate traceability more important.