FOOD SUPPLY CHAIN:SAFETY NORMSS

Background

Food safety has long been recognized as a mandatory requirement in the production and
marketing of foods. Traditional approaches to food safety management have relied upon end
product sampling and laboratory testing. Detailed procedures were developed to set
specifications for foods in regard to chemical and microbiological levels, and also levels of
physical contamination. Such specifications were originally derived from knowledge of Good
Manufacturing Practice (GMP) requirements and more recently from detailed risk assessments
which determined the likelihood of hazards presenting a risk to public health and safety. Food
product specifications and end product testing have traditionally formed the primary basis for
regulatory oversight of food safety. In some areas this is still the case today. A major
change in approach arose when it was demonstrated that hazard identification and control
could be used to manage food safety across the entire agri-food supply chain, rather than at
some endpoint. This approach led to the adoption of the now well accepted Hazard Analysis
and Critical Control Point (HACCP) system which emphasized preventative approaches.
Whereas the initial research relating to food product hazard control was undertaken several
decades ago, the impetus for its adoption in the food sector became very significant in the 1990s.
A second area of development is the concept of “hurdle technology” where a series of food
safety measures are used, sometimes in steps, to gain synergy in the interaction and
effectiveness of several food safety measures. The correct application of a series of hurdles can
achieve the same product safety as a single food safety measure such as a kill step. Continuing
research underpinning food safety management has provided a number of new approaches,
and tools, which have strengthened risk assessment capability, and allowed a clearer delineation
between risk assessment and risk management. This has enabled a transition from end product
specification and testing to a focus on establishing new measures of food safety such as Food
Safety Objectives and associated metrics (ICMSF 2002). This allows the food industry greater
flexibility when examining approaches to food safety management.

Keeping food safe: A growing global challenge

Keeping food safe as it moves through the supply chain is a significant challenge. Perishables
such as produce, meat, fish, milk and more can change hands ten to twenty times before reaching
the consumer. This fact alone presents many opportunities along the supply chain for accidental
or malicious mishandling that can lead to contamination or spoilage. And a host of new issues
and trends, from the globalization of the supply chain to the type of foods that are imported,
takes the challenge of protecting the safety of the food in the supply chain to new heights.
Changes in consumption trends

Today’s busy consumers often rank convenience over price — a trend that can translate into
increased opportunities for food contamination. For example, many consumers today would
prefer to purchase a bag of prepared ready-to-eat lettuce instead of a head of lettuce that must be
prepared. As a result, bacteria in a tainted head of lettuce that may have only affected one family
in the past might now end up in multiple of bags of lettuce, potentially causing foodborne illness
in hundreds of people.

Another challenge in the food chain: increased government regulations

In response to growing food safety issues, new government regulations have been developed to
help protect food as it travels through the supply chain. While these regulations do improve
consumer safety, they also translate into a substantial increase in recordkeeping requirements for
companies throughout the food supply chain. For example, federal regulations in the U.S such as
The Federal Public health security and bioterrorism Preparedness and Response act of 2002
(enacted after September 11, 2001) and the U.S. FDA Good

Manufacturing Practice Regulations as well as the EU food laws defined by the European
commission (EC) now require the collection and maintenance of detailed specific information as
food moves through the supply chain. In order to remain profitable, enterprises in the food
industry need to accurately and cost-effectively collect, filter and react to this massive amount of
information — a task at which RFID excels.

RFID — A critical new link in the food supply chain

RFID can help improve the efficiency and safety of the food supply chain by enabling the
collection of the vast amount of data required to ensure the safety of food as it moves through
either the national or international food supply chain. Passive RFID tags provide cost-effective
tracking and traceability as food moves through the supply chain, while temperature-sensing and
data logging RFID tags capture information about the conditions the food is subjected to on the
journey from field to fork.

“With RFID, food is tracked from the moment it is picked in the field. RFID tags are applied to
collection bins, and when a bin is full, an RFID-enabled mobile computer is utilized to read the
tag. The unique identifier associated with the bin is captured the date and time are automatically
recorded, and any other additional information needed to enable full traceability back to the
origin of the product is entered, such as the picker’s name and the picking location. The
automation of the data collection process protects the integrity of the data set, and encourages
the capture of a richer set of information due to the simplicity of data input. And when combined
with a locationing technology such as GPS, RFID can automatically record the exact location in
the field where the produce was picked, allowing growers to pinpoint the source of contaminated
produce quickly and more cost-effectively — protecting the health of consumers as well as the
business.”

The RFID advantage: improving food safety and supply chain efficiency

In the food supply chain, consumer safety and enterprise profitability are both dependent upon
how rapidly product can move from the field, pasture and sea to the grocer’s shelves — as well
as visibility into how the product was handled along the way. RFID improves both.

 Food safety improvements

Superior visibility into the movement of products through the supply chain provides the real time
granular data required to make better business decisions that increase the safety of the food
supply at every junction in the supply chain:

 Visibility into harvest times and product temperature condition enables FeFo (First to
expire, First out) inventory management’, helping product move more rapidly from field
to fork as well as reducing the opportunity for spoilage, foodborne illness and loss of
product.

 Distributors and grocers now have visibility into the length of time a product has been
traveling through the supply chain, condition during transit and remaining shelf life.
More volatile perishables can be processed first, accuracy of “best by” date stamps is
increased; and distributors and grocers can recognize and refuse any product where
quality may have been compromised s— again improving food safety and quality.

 Visibility into the whereabouts of contaminated product enables manufacturers,

distributors and local grocers to issue more narrow recalls — recalls that are focused on
the specific lots that are potentially tainted rather than a broad recall of a specific class of
item. as a result, tainted food can be quickly identified and removed regardless of where
it may be in the supply chain, reducing the opportunity for inadvertent consumption and
the resulting food-related illnesses — and improving the success rate of recalls.
  More reliable data — The ability to automatically collect data by reading an RFID tag
helps to error proof data collection. And the improved accuracy of the data in your
system helps increase product safety.

 brand protection — RFID can help enterprises in the food supply chain prevent brand
damage by providing the information needed to instantly spot and contain incidents
before they can impact sales and brand value. The impact of outbreaks and the effect on
the food industry as a whole cannot be underestimated. In response to recent recalls, 38
percent of consumers stopped buying certain food products in 2007 — a 400 percent
increase over the 9 percent in 2006. of the 38 percent: 71 percent avoided spinach, 16
percent avoided lettuce, 9 percent avoided bagged salads and 8 percent avoided beef. FID
can help enterprises prevent and mitigate incidents, reducing the potential negative
impact on brand equity and sales.

 Reduction in liability — The ability to rapidly identify and remove potentially tainted
food items from the supply chain minimizes the opportunity for foodborne illness — and
the associated liabilities.

 Supply chain efficiency improvements

The same information that helps protect food as it moves through the supply chain also increases
the efficiency of the supply chain, protecting profitability through:

 Loss protection — The ability to move perishables through the supply chain as quickly as
possible helps maximize product shelf life – and prevent shrink due to spoilage.

 Productivity improvements — The automated data capture eliminates the need for
workers to capture information on paper forms, which in turn increases throughput —
existing staff can now process more product per day.
  Substantial reduction in the cost of recalls — Real-time visibility into the exact
whereabouts of any contaminated product enables a targeted recall effort that can be
executed at a fraction of the time and cost associated with a traditional widespread recall.

 Cost-effective regulatory compliance — complying with new government regulations can

be a costly endeavor. Through automated collection of regulatory data and more, RFID
enables businesses to easily comply with new regulations without a substantial impact on
margins.

DEVELOPMENT OF NEW APPROACHES TO SUPPLY CHAIN MANAGEMENT

Examples of recent developments in food preservation technology are

 High pressure processing,

 Food irradiation,

 Pulsed electric fields and pulsed light.

These new technologies enable manufacturers to provide innovative products as well as meet
food safety objectives.

High Pressure Processing: refers to high pressure used for food preservation. "Pressed inside
a vessel exerting 70,000 pounds per square inch or more, food can be processed so that it retains
its fresh appearance, flavor, texture and nutrients while slowing spoilage by killing E.
coli, Salmonella and Listeria pathogens (but not Clostridium botulinum). "Using hydrostatic
pressure, water is pumped into a sturdy closeable steel vessel. Foods of any shape or size are
equally squeezed around its surface area without crushing the food particles. It's effective on
most moist foods, such as fruits, vegetables, sauces and ready-to-eat meats. It can even shell
whole uncooked lobster.The high pressure cycle takes no longer than six minutes, compared to
traditional high-temperature processing that takes an hour or longer, without causing chemical
changes that degrade food quality."It is successful in improving flavor retention and sensory
quality in a range of foods, for example fruit juices, fruit and vegetable purees, processed meat
products, and seafood. The technology is successful also in controlling microbial levels in
many situations, and it provides a good example of “equivalence” to traditional high temperature
heat treatment.

Food Irradiation is the process of exposing food to ionizing radiation to

destroy microorganisms, bacteria, viruses, or insects that might be present in the food. Further
applications include sprout inhibition, delay of ripening, increase of juice yield, and
improvement of re-hydration. Irradiation is a more general term of deliberate exposure of
materials to radiation to achieve a technical goal (in this context "ionizing radiation" is implied).
As such it is also used on non-food items, such as medical hardware, plastics, tubes for gas-
pipelines, hoses for floor-heating, shrink-foils for food packaging, automobile parts, wires and
cables (isolation), tires, and even gemstones. Compared to the amount of food irradiated, the
volume of those every-day applications is huge but not noticed by the consume .It shas the
capacity to play an important role in food safety management, but consumer acceptance has been
until recently quite low in some countries.

 Gamma Irradiator for food processing

 Electron Beam Irradiator for food processing

Application

On the basis of the dose of radiation the application is generally divided into three main
categories as detailed under:

Low Dose Applications (up to 1 kGy)

 Sprout inhibition in bulbs and tubers 0.03-0.15 kGy

 Delay in fruit ripening 0.25-0.75 kGy

 Insect disinfestations including quarantine treatment and elimination of food borne

parasites 0.07-1.00 kGy

Medium Dose Applications (1 kGy to 10 kGy)

 Reduction of spoilage microbes to prolong shelf-life of meat, poultry and sea foods under
refrigeration 1.50–3.00 kGy
 Reduction of pathogenic microbes in fresh and frozen meat, poultry and sea foods 3.00–
7.00 kGy

 Reducing the number of microorganisms in spices to improve hygienic quality 10.00 kGy

High Dose Applications (above 10 kGy)

 Sterilization of packaged meat, poultry and their products which are shelf stable without
refrigeration. 25.00-70.00 kGy
 Sterilization of Hospital diets 25.00-70.00 kGy

 Product improvement as increased juice yield or improved re-hydration

It is important to note that these doses are above those currently permitted for these food items
by the FDA and other regulators around the world. The Codex Alimentarius Standard on
Irradiated Food does not specify any upper dose limit . NASA is authorized to sterilize frozen
meat for astronauts at doses of 44 kGy as a notable exception. Irradiation treatments are also
sometimes classified as radappertization, radicidation and radurizatio.

Pulsed electric fields and pulsed light:

Two new technologies for use in the food industry are described. The first method discussed uses
intense pulse of light. This pulsed light (Pure Bright) process uses short duration flashes of broad
spectrum "white" light to kill all exposed microorganisms, including vegetative bacteria,
microbial and fungal spores, viruses, and protozoan oocysts. Each pulse, or flash, of light lasts
only a few hundred millionths of a second (i.e., a few hundred microseconds). The intensity of
each flash of light is about 20,000 times the intensity of sunlight at the earth's surface. The
flashes are typically applied at a rate of about one to tens of flashes per second. For most
applications, a few flashes applied in a fraction of a second provide an effective treatment. High
microbial kill can be achieved, for example, on the surfaces of packaging materials, on
packaging and processing equipment, foods, and medical devices as well as on many other
surfaces. In addition, some bulk materials such as water and air that allow penetration of the light
can be sterilized. The results of tests to measure the effects of pulsed light on Salmonella
enteritiditis on eggs are presented. The second method discussed uses multiple, short duration,
high intensity electric field pulses to kill vegetative microorganisms in pumpable products. This
pulsed electric field (or Cool Pure) process can be applied at modest temperatures at which no
appreciable thermal damage occurs and the original taste, color, texture, and functionality of
products can be retained.
 High pressure processing of consumer packages
 A bulk processing line for high-pressure treatment of foods contained in bulk
packages. The contents are later transferred into retail packages.
 A high pressure processing system for pumpable foods
NOTE: Advances in predictive microbiology have also contributed significantly to food safety
management (McMeekin et al., 1993). Predictive microbiology, where the effects of food
formulation, processing conditions, packaging, and storage on the survival and growth of
microorganisms in foods can be measured and assessed, has enhanced the potential to apply
“equivalence” assessments in food safety management. ComBase is a database where data and
predictive tools on microbial responses to food environments are freely available via web-based
software. The database contains information about how microorganisms respond to different
food properties and environments.

REVOLUTION IN INTERNATIONAL FOOD SAFETY STANDARDS

The food supply chain on which we all rely extends farther and goes deeper than ever before. For
example, a piece of fruit grown in Africa can be on grocery store shelves in Europe within 24
hours of harvest. Coffee from Asia wends its way to shops across Europe. Lamb from New
Zealand is enjoyed across the UK and North America. With such a far-reaching supply chain in
place, carrying such an essential product as food, having the proper security and safety measures
in place is vital. A robust, independently verified food management system could make a real
difference by improving a food organization's flexibility, readiness and ultimate viability in the
face of an ever-changing risk environment. This is particularly true when set against the
backdrop of current economic pressures, when there is a temptation to cut corners. Under the
circumstances, the need for food safety has never been greater. And yet, to this day, there has not
been a unified, internationally accepted food safety management solution in place to do the job.

Good progress has been made by the industry to date. It was concern over potential risks in the
food supply chain that prompted the creation of a number of early food safety sector initiatives
and standards, including HACCP and the BRC and IFS retailer driven food manufacturing
standards along with Euro GAP for the pre-farm gate sector. But it was not until the publication
of international food safety management system standard ISO 22000 in 2005 that there was a
single standard covering the entire food supply chain.

Adoption of ISO 22000 throughout all sectors of the industry has been relatively poor. In
particular, in the highly influential food manufacturing sector, it quickly became apparent that
ISO 22000 had limitations. From a technical perspective, the requirements on prerequisite
programmes (PRPs) were not deemed to be specific enough to meet stakeholder needs.

Another limitation revolved around the position of the internationally recognized organization,
the Global Food Safety Initiative (GFSI). Without the appropriate PRPs and scheme ownership,
ISO 22000 could not be benchmarked by the GFSI and given the same approval as other
standards.
"The food safety landscape is very straight-forward," says Steve Mould, worldwide quality
management systems manager at Kraft Foods. "Food safety standards need to be recognized by
the GFSI but ISO 22000 could not on its own. ISO 22000 gives lists of PRP topics to consider,
but because it covers the whole of the food industry, it does not include PRPs for each step:
otherwise it would need to be the size of an encyclopedia. Something else was needed to fill the
gap and give ISO 22000 the support that was needed.

BRC Global Standard for Food Safety

“The BRC (British Retail Consortium) Global Standard for Food Safety was created to ensure
supplier compliance and secure retailers’ ability to guarantee the quality and safety of the food
products they sell. Today it is used worldwide as a framework for any business (retailers and
processors) to assist the production of safe food and the selection of reliable suppliers.”

The BRC Global Standard for Food Safety is one of the operational tools most frequently used
for due diligence and supplier approval. It helps companies to select and qualify their suppliers.
Thus, the system reduces the overall costs of the supply chain management and increases the
level of safety for customers, suppliers, and consumers. Regarded as a ticket-to-trade, the
standard is also a great opportunity to demonstrate your company’s commitment to food safety,
quality, and legality, and to work on continual improvement.

What is the standard?

The main retailers in the United Kingdom were concerned about food safety because of their
direct responsibility in case of an incident. To take control of the situation, retailers require that
all food suppliers be certified to a specialized standard to ensure that they comply with quality
and safety demands, and legal requirements. After the first issue in 1998 the standard was
regularly improved, involving international stakeholders in the supply chain. Today it is a global
tool based on the most recent and updated food safety standards and methodologies. The
requirements in the standard are related to the quality management system and the HACCP
system, supported by detailed prerequisite programmes, that is a set of GMP (Good
Manufacturing Practice), GLP (Good Laboratory Practice) and GHP (Good Hygiene Practice)
requirements.
The BRC Global Standard for Food Safety enables the Organization to:

 Provide evidence of commitment, and, in case of a food safety incident, legal defense in
the frame of the “due diligence” concept.

 Build and operate a management system capable of helping you to better meet
food quality/safety requirements and legal compliance, with specific reference to the
legislation applicable in the countries where the finished product is consumed.

 Provide a tool for food safety performance improvement and the means to monitor and
measure food safety performance effectively

 Facilitate reductions in product waste, product reworking, and product recall.

 Certification to BRC Global Standard for Food Safety also supports efficient supply
chain management by reducing second party audits and increasing your overall supply
chains reliability.
TRACEABILITY IN FOOD SUPPLY CHAIN:FOR ENSURING SAFETY

What Is Traceability?

ISO (International Organization for Standardization), which develops voluntary

international standards for products and services, defines traceability as the “ability
to trace the history, application, or location of that which is under consideration.”
This definition is quite broad. It does not specify a standard measurement for “that
which is under consideration” (a grain of wheat or a truckload), a standard location
size (field, farm, or county), a list of processes that must be identified (pesticide
applications or animal welfare), or a standard identification technology (pen and
paper or computer). It does not specify that a hamburger be traceable to the cow or
that the wheat in a loaf of bread be traceable to the field. It does not specify which
type of system is necessary for preserving the identity of tofu-quality soybeans;
controlling the quality of grain used in a particular cereal; or guaranteeing correct
payments to farmers for different grades of apples.

The definition of traceability is necessarily broad because food is a complex product

and traceability is a tool for achieving a number of different objectives. As a result,
no traceability system is complete. Even a hypothetical system for tracking beef—in
which consumers scan their packet of beef at the checkout counter and access the
animal’s date and location of birth, lineage, vaccination records, and use of
mammalian protein supplements—is incomplete. This system does not provide
traceability with respect to bacterial control in the barn, use of genetically
engineered feed, or animal welfare attributes like hours at pasture and play time.

A system for tracking every input and process to satisfy every objective would be
enormous and very costly. Consequently, firms across the U.S. food supply system
have developed varying amounts and kinds of traceability. Firms determine the
necessary breadth, depth, and precision of their traceability systems depending on
characteristics of their production process and their traceability objectives .

 Breadth describes the amount of information collected. A recordkeeping

system cataloging all of a food’s attributes would be enormous, unnecessary,
and expensive. Take, for example, a cup of coffee. The beans could come
from any number of countries; be grown with numerous pesticides or just a
few; be grown on huge corporate organic farms or small family-run
conventional farms; be harvested by children or by machines; be stored in
hygienic or pest-infested facilities; and be decaffeinated using a chemical
solvent or hot water. Few, if any, producers or consumers would be interested
in all this information. The breadth of most traceability systems would
exclude some of these attributes.

 Depth is how far back

or forward the system
tracks the relevant
information. For
example, a traceability
system for
decaffeinated coffee
would extend back only
to the processing
stage. A traceability
system for fair-trade
coffee would extend
only to information on
price and terms of trade between coffee growers and processors. A
traceability system for fair wages would extend to harvest; for shade grown,
to cultivation; and for no genetically engineered, to the bean or seed. For
food safety, the depth of the traceability system depends on where hazards
and remedies can enter the food production chain. For some health hazards,
such as Bovine Spongiform Encephalopathy (BSE, or mad cow disease),
ensuring food safety requires establishing safety measures at the farm. For
other health hazards, such as foodborne pathogens, firms may need to
 establish a number of critical control points along the entire production and
distribution chain.

 Precision reflects the degree of assurance with which the tracing system can
pinpoint a particular food product’s movement or characteristics. In some
cases, the objectives of the system will dictate a precise system, while for
other objectives a less precise system will suffice. In bulk grain markets, for
example, a less precise system of traceability from the elevator back to a
handful of farms is usually sufficient because the elevator serves as a key
quality control point for the grain supply chain. Elevators clean and sort
deliveries by variety and quality, such as protein level. Elevators then blend
shipments to achieve a homogeneous quality and to meet sanitation and
quality standards. Once blended, only the new grading information is relevant
—there is no need to track the grain back to the farm to control for quality
problems. Strict tracking and segregation by farm would thwart the ability of
elevators to mix shipments for homogeneous product.

What Does It Do?

Firms have three primary objectives in using traceability systems: improve supply
management; facilitate trace back for food safety and quality; and differentiate and
market foods with subtle or undetectable quality attributes. The benefits associated
with these objectives include lower cost distribution systems, reduced recall
expenses, and expanded sales of products with attributes that are difficult to
discern. In every case, the benefits of traceability translate into larger net revenues
for the firm. These benefits are driving the widespread development of traceability
systems across the U.S. food supply chain.

“Traceability to improve supply management”

Industry analysts calculate that during 2000, American companies spent $1.6 trillion
on supply-related activities, including the movement, storage, and control of
products across the supply chain. The ability to reduce these costs often marks the
difference between successful and failed firms. In the food industry, where margins
are thin, supply management, including traceability, is an increasingly important
area of competition. A firm’s traceability system is key to finding the most efficient
ways to produce, assemble, warehouse, and distribute products.

Electronic coding systems, from the granddaddy barcode system to cutting-edge

technologies like radio-frequency identification systems, are helping to streamline
the U.S. food supply system. As technological innovation drives down the cost of
these devices, more firms across the food supply chain are using electronic tracking
systems. In some cases, buyers manage these systems to monitor internal supply
flow. In others, firms establish systems that link suppliers and buyers, allowing them
to automate reordering. Retailers such as Wal-Mart have created proprietary
supply-chain information systems, which they require their suppliers to adopt.

Inventory-to-sales ratios are further evidence that U.S. companies are embracing
new logistic systems to better control inventory flow. The ratio of private inventories
to final sales of domestic business has fallen by half since the end of WWII. The
same trend can be observed in many sectors of the domestic food industry,
including natural, processed, and imitation cheese; cereal breakfast foods; and soft
drinks and carbonated waters. In each case, the inventory-to-sales ratio fell, with
the largest decline in the cereal sector, where the ratio fell from over 8 percent in
1958 to 3-4 percent in the early 1990s. This downward trend in inventories reflects
growing efficiencies in supply management in the U.S. food industry, including
traceability systems. This trend is expected to continue as food manufacturers
continue to adopt technologies already in use in other industries.

“Traceability for safety and quality control”

Traceability systems help firms isolate the source and extent of safety or quality
control problems. This helps reduce the production and distribution of unsafe or
poor-quality products, which in turn reduces the potential for bad publicity, liability,
and recalls. The better and more precise the tracing system, the faster a producer
can identify and resolve food safety or quality problems. One surveyed milk
processor uniquely codes each item to identify time of production, line of
production, place of production, and sequence. With such specific information, the
processor can trace faulty product to the minute of production and determine
whether other products from the same batch are also defective.

Many buyers, including many restaurants and some grocery stores, now require
their suppliers to establish traceability systems and to verify, often through third-
party certification, that such systems work. The growth of third-party standards and
certifying agencies is helping push the whole food industry—not just those firms
that employ third-party auditors—toward documented, verifiable traceability
systems.
“Traceability to market and differentiate foods”

The U.S. food industry is a powerhouse producer of homogeneous bulk

commodities such as wheat, corn, soybeans, and meats. Increasingly, the industry
is tailoring goods and services to the tastes and preferences of various groups of
consumers. Consumers easily spot some of these new attributes—green ketchup is
hard to miss. However, other innovations involve credence attributes,
characteristics that consumers cannot discern even after consuming the product.
Consumers cannot, for example, taste or otherwise distinguish between
conventional corn oil and oil made from genetically engineered (GE) corn.

Credence attributes can describe content or process characteristics of the product.

Content attributes affect the physical properties of a product, although they can
be difficult for consumers to perceive. For example, consumers are unable to
determine the amount of isoflavones in a glass of soymilk or the amount of calcium
in a glass of enriched orange juice by drinking these beverages.

Process attributes do not affect final product content but refer to characteristics
of the production process. Process attributes include country of origin, free-range,
dolphin-safe, shade-grown, earth-friendly, and fair-trade. In general, neither
consumers nor specialized testing equipment can detect process attributes.

Traceability is an indispensable part of any market for process credence

attributes—or content attributes that are difficult or costly to measure. The only way
to verify the existence of these attributes is through recordkeeping that establishes
their creation and preservation. For example, tuna caught with dolphin-safe nets
can only be distinguished from tuna caught using other methods through a
recordkeeping system that ties the dolphin-safe tuna to an observer on the boat
from which the tuna was caught. Without traceability as evidence of value, no
viable market could exist for dolphin-safe tuna, fair-trade coffee, non-biotech corn
oil, or any other process credence attribute.