WASHINGTON — A two-part study conducted by the Institute of Food Technologists (IFT) for the Food and Drug Administration over the past two years has uncovered a number of flaws in the tracing systems used in the food industry.
The study focused on produce and FDA-regulated food products and ingredients. More than 200 stakeholders were queried, including retailers, distributors, suppliers, trade associations and consumer groups. The study, now part of the FDA's public comment, is available at www.ift.org/traceability.
The study found that “the lack of common data elements in the supply chain may not provide complete product tracing,” said Jennifer McEntire, manager of science and technology projects for IFT, a scientific and professional society based here, in a presentation last month at the U Connect conference in San Antonio. “Data is captured but that doesn't equate to an ability to trace products. A lot of information is recorded but not linked.”
Among IFT's other findings:
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Paper recordkeeping is prevalent, slowing down traceback investigations. The FDA still prefers paper records.
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Paperwork generally lacks complete information.
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Within a facility, internal systems often differ and are not electronically linked.
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Some firms have the right information but not all in one place.
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The meaning of terms like “lot” is unclear, preventing traceability.
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Some firms won't engage in traceability unless it is required by regulation. “Unless they know their competitor is going to do it, they are not going to make that investment,” said McEntire.
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Suppliers don't routinely provide traceability data.
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There is uncertainty about traceability costs.
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There is concern about the difficulty of tracing bulk and commingled products.
The study also discovered a number of motivating factors, including fear of regulation, the opportunity to improve related processes like inventory control, improvement of consumer confidence, and a perception that traceability is a “cost of doing business.”
IFT made a number of recommendations in regard to traceability. Companies should:
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Identify critical tracking events such as when product is moved or transformed.
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Maintain records for each critical event in agreed-upon, standardized formats that link incoming and outgoing products.
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Provide key data elements in electronic form upon request by FDA within 24 hours.
In addition, IFT recommends that product tracing should be regulated and audited “to make sure that companies are doing what they are supposed to be doing.”