Are food retailers and their suppliers sufficiently equipped to track down the source of contaminated food?
The outbreak of E. coli-contaminated spinach in September that made scores of people sick and caused at least one death underscored the need for retailers, distributors and other companies in the supply chain to quickly trace a tainted product back to its source. That crisis was followed by a salmonella outbreak associated with contaminated fresh tomatoes served in restaurants that sickened dozens of people in 21 states.
At a minimum, retailers are now required by the Bioterrorism Act of 2002 to be able to maintain records of a food's immediate previous source and immediate subsequent recipient, and produce them within 24 hours. In June, the deadline passed for businesses with 11-499 employees to comply with this record-keeping requirement; after Dec. 9, businesses with fewer than 11 employees must comply. Larger businesses have been expected to adhere to these requirements since last December.
Yet despite these high-profile contamination cases, and even the inducement of government regulation, some food industry observers, especially in the fresh food sector, believe that the food industry is not adequately prepared to track down and isolate the source of tainted products.
“Companies think they have track-and-trace systems in place,” said Gary Fleming, vice president, industry technology and standards, Produce Marketing Association, Newark, Del. “But the reality is that they might have decent internal programs, but when they go outside their four walls it breaks down.”
In the absence of sophisticated track-and-trace systems, recalled product is usually removed across a broad cross-section of stores rather than from a more narrowly defined group. “If you know a product is from a specific lot number, you can limit the amount of product you need to bring back,” said Greg Rowe, director, business development, GS1 US, Lawrenceville, N.J.
The PMA, in concert with the Canadian Produce Marketing Association, created a set of best practices for traceability based on a pilot conducted by the trade associations with retailers, distributors and grower/shippers. These guidelines have been available at www.pma.com (under “standards”) for more than a year.
“We have toolsets out there for the industry to use but the industry is not adopting these tools,” Fleming said. “That's why we get into trouble. Companies continue to think, ‘Oh, this won't happen to me.’”
In the spinach case, tracing the source of the contamination was simplified by the fact that the spinach came in packages with UPC bar codes, noted Kathy Means, vice president, government relations for the PMA. The packaging pointed to Natural Selection Foods, San Juan Bautista, Calif., the processor of the packaged product, and from there to specific farms.
But many other contamination incidents, such as the tomato salmonella outbreak, are far more challenging to trace, Means added. For those cases, retailers and distributors must at a minimum meet the record-keeping requirement of the Bioterrorism Act to go one step forward and back in the supply chain.
Yet, Means observed, some companies are failing to adhere to the record-keeping requirements. “There's a lot of work that needs to be done in terms of this ‘one-up, one-back’ rule,” she said. “Having these kinds of records and speeding a trace-back as fast as possible is what's going to minimize the damage to the industry.”
Other companies appear to be more proactive about using tracing technology. Bill Pool, manager, agricultural production and research, Wegmans Food Markets, Rochester, N.Y., said many of the chain's produce suppliers have systems in place that “trace product back to point of production.” Those suppliers are using a “field tag” generated at the time of harvest and containing information that follows product through processing and distribution.
Deborah White, vice president and associate general counsel, Food Marketing Institute, Washington, observed that FMI members “are cognizant of the [Bioterrorism Act's] requirements and are working hard to implement them.”
White said that much of the record-keeping data required by the FDA is captured by retailers in their electronic invoicing and electronic data interchange systems. “We asked our members if FMI should design a single standard for the food industry to address the requirements,” she said. “And the answer was that people had systems that could encompass most of what was required. So they could use what they had and modify it to accommodate the regs.”
The Food and Drug Administration keeps no formal gauge of whether companies are meeting its requirements, according to a spokesman. The Bioterrorism Act itself stipulates that the FDA can only demand access to records when food is found to be adulterated “and presents a serious threat of adverse health consequences or death to humans or other animals.” This has not yet been invoked anywhere, he said.
However, in the course of routine inspections the FDA may ask companies to voluntarily share records “so we can see that they're keeping them and so they can get feedback on the adequacy of their procedures,” the spokesman said.
Manhattan Associates, Atlanta, offers a system called Trading Partner Management that can help retailers trace products, especially from small suppliers.
The system, being employed by Sainsbury's in the U.K. and launched by Giant Eagle in the U.S., allows suppliers to access a retailer's purchase order as well as lot number and expiration date requirements via a Web portal. The data are then incorporated into bar-coded “license plates” that are printed and applied to cases or pallets. An advance shipping notice is sent electronically.
Giant Eagle, Pittsburgh, plans to pilot Manhattan Associate's TPM system at two warehouses in February, rolling it out to all of the chain's seven warehouses by next summer, said J.A. Hilzendeger, Giant Eagle's director, distribution systems and operations.
Giant Eagle will have suppliers that can send an ASN via electronic data interchange use that method to transmit license plate number information, including lot numbers and expiration dates, through TPM and into the chain's warehouse management system. Other vendors will send the data via the TPM Web portal. All vendors will incorporate the data on bar codes applied to pallets.
Hilzendeger sees TPM as a “scalable solution” that Giant Eagle will be able to “roll out with more vendors.” Currently some suppliers provide lot number data, but it has to be keyed into Giant Eagle's warehouse management system. The chain plans to work with more of them to provide this data via the TPM system.
By automating the transmission of lot numbers and associated data, Giant Eagle will be able to facilitate trace-backs, he noted. “We want to be able to track products for [country of origin labeling] and bioterrorism requirements.”