13
Food Traceability
Gregory S. Bennet
CONTENTS
Bibliography ........................................................................................................................................................................................272
Food-borne diseases are here to stay. However, a company can
reduce the risk to its nancial resources and reputation by imple-
menting an effective and ef cient traceability system. From the
loading dock, along the processing line, and through arrival at the
nal destination, a traceability system can create a documented
chain of accountability. This accountability can, in turn, in u-
ence customer con dence—whoever the customers may be along
a product’s journey, from the origin to the end consumer. Ideally,
a traceability system’s aggregate information is suf cient to trace
back or track forward, thereby minimizing the negative effects of
a product recall. By increasing the speed at which affected prod-
ucts are identi ed, minimizing the number (volume or count) of
items affected, and accelerating the removal and recovery of the
affected items along the supply chain, companies can mitigate
the immediate crisis while gaining valuable information to help
avoid future recall events.
To accomplish this, several items are needed, including good
planning, up-to-date standard operating procedures (SOPs),
mock recalls, audits, laboratory tests, and training. This chap-
ter reviews many speci c tests that can be performed in food
analysis. However, food traceability is “systematic,” and the
analysis of a system’s approach or program is more qualitative
than quantitative at this time. Traceability is an emerging con-
cept and process, with mixed results. An analysis of this type
of system goes beyond the disconnected tests (laboratory) or
isolated veri cations. Thus, this analysis of food traceability
focuses on what could or should be analyzed, and identi es and
explains the distinct parts of the food traceability system. This
analysis also suggests the possible matrices of measurement. The
measurements are not per item or by an individual product, so
much as they are comparisons of changes between the before
and after in areas such as SOP changes, in quality control/quality
assurance (QC/QA), in audits, in comparisons of the number of
products affected, time to recall, time to contact vendors, time
to call regulators, and time to replace items. As experience with
traceability programs increases, with several years of compari-
son data from auditors and third-party laboratories, the data will
reinforce how well different approaches may affect traceability
and recalls.
The problem for most companies is that it is hard for senior
staff to analyze a program that they do not fully understand.
Many companies patch together an ad hoc recall program rather
than commit to an actual system. Fortunately, companies already
have the individual components—administration and procure-
ment departments, quality control—but often, they do not appre-
ciate how these must interact transparently and in coordination
for a successful food traceability program.
The tracing of the foods and ingredients involves the speci c
processes applied to the product, the point in the supply chain
where the process was done, and tracking the item’s movements
to the next process, packaging, and transportation. Processes
are usually internal or in-house activities within a company or
location, whereas product movements can be internal to a rm
and external between one entity and another. A traceability sys-
tem, to be more precise, involves the tracing or tracking of agri-
cultural commodities through data stored and shared, whether
results from laboratory tests and/or audits, through its numerous
changes (growth, modi cations, and processes) and its move-
ments from source origination (through the various elevators,
feed lots, millers, processors, packers, process re nement, con-
tainerizing, packaging, storage facilities, and modes of trans-
portation), and then onto its nal consumption location (grocery
store, restaurant, and school). This two-volume book reviews
many discrete clinical/laboratory methods to analyze food prop-
erties, components, and residues, not excluding synthetics and
adulteration. Food traceability naturally incorporates many of
these tests and more, but also de es simple quanti cation.
This chapter acknowledges the critical importance that each
chapter within this book makes toward food safety and its food
traceability, and summarily analyzes several of the standards,
traceability programs, mock recalls, and audits. Owing to the
relative newness of traceability regulations, most traceability
systems and programs analysis is in the nature of qualitative
measures or comparisons, whereas the well- established labora-
tory and audit ndings are more quantitative. Some of the same
quantitative tools, such as cost–bene t analyses, data veloc-
ity matrices (the speed, accuracy, and precision of traceability
data), and quality/purity scorecards, have been incorporated into
traceability programs. Food traceability, as mentioned, traces
and tracks food products along the food chain through the prod-
uct’s various transformations—it encompasses a product’s con-
tinuous, uninterrupted ow of data, test results from laboratories
and audits, whether sequential processing, mixing, added ingre-
dients, or from source to the nal customer. Food traceability
analysis involves internal/external reviews of its components
that include the following: (1) traceability standards, (2) QC/QA
265
266
programs, (3) traceability audits, and (4) the management’s back-
ing of the food traceability program. All these items are tied to
food safety and its traceability—to trace and track food from its
source to the nal destination, or as has been typically coined,
“from farm to fork.”
Food disease, contamination, adulteration, and the resultant
recalls pose a threat to food safety, and elicit a public health
response in the form of a recall. These are the leading reasons
why governments mandate food safety systems that focus on
traceability systems. From the globalization of ingredient sourc-
ing, to the proliferation of sales markets in all corners of the
world, the exponential increase in food-borne safety issues has
grown to affect millions of people. The alarm regarding affected
foods has become an ever-increasing national and international
event, especially over the past two decades. Some recent events
include Salmonella in smoke salmon (AP 2012), Listeria outbreak
with cantaloupes (Tomson 2011), clenbuterol in pork (Burnkitt
2011), mislabeled meat (Craymer 2013), and Escherichia coli
in sprouts (Martin 2011). At a minimum, these events and their
follow-on recalls, affected all food entities that used or came into
contact with the foods/ingredients involved. While it is true that
the company of the affected product directly and immediately
feels the impact, all members of the food supply chain that use
that type of product will also feel the drop-off effects in sales
too. Without an adequate traceability program to trace/track
the affected product, the effects upon the primary company and
subsequent supply chain recipients of the defective product are
magni ed. Traceability programs, with their standards, tests, and
audits, greatly help mitigate the scope and breadth of the problem.
A detailed traceability program allows the source company (dis-
coverer of the affected product) to better evaluate the exact num-
ber of units involved, and communicate the speci c data (lot #s,
etc.) to up- and downstream supply chain members. These supply
chain members can then determine whether they are affected, and
let the public know whether their product is involved or not.
Traceability, as mentioned, is systematic in its scope and
accountability. It goes beyond the rm’s walls and trucks,
encompassing all facets of the food supply chain. This includes
knowing where the ingredient came from, previous processes
involved, all the internal operations that the company performs,
and then downstream to data records for many other entities
that subsequently handle the product. The traceability concept
encompasses the process, program, and system that promote
and bring together the important information/data and results in
transparency, which is essential. Individual entities (companies,
processors, etc.) need a traceability program in the case of recall
or to identify and verify trait attributes, claimed processes such
as organic, geo-origins, chemical(s) used, and unsafe practices
or conditions such as temperature limits. Upon the discovery of
an unsafe ingredient, an electronic trace back through the com-
pany’s internal processes can determine whether the ingredi-
ent came from a source vendor. If so, the company (a) noti es
the vendor, and (b) determines whether this product went into
any other company products at another location, batch, and so
on. The company also determines which other products may be
affected within the company’s processing, handling, mixing, and
the like, and, whether the product affected has been shipped, to
notify the appropriate customers, government agencies and, if
necessary, the general public.
Handbook of Food Analysis
Traceability systems/programs involve and encompass rec-
ognized regulations (domestic, international), industry stan-
dards (mandates such as electronic records), shared data points
of agreed essential information elds (usually software driven),
tests (internal and third-party laboratories), and audits (internal
and third party). These help determine which key data, such as
noncompliance of critical temperature, formulation, adultera-
tion, and so on, can be shared, and alert up- and downstream
customers and vendors.
The details of traceability are typically built upon departments
already established within a company and the company’s legacy-
shared software systems. The departments include procurement,
accounting, information technology (IT), safety, quality control,
storage, logistics/transportation, laboratory, administration, exec-
utive staff, and the systems that tie or join departments together.
Data and information ows through unique and shared software,
GS1—or Global Standards1—is the most widely used supply
chain standards system in the world, protocols/barcodes, auditing
protocols, and laboratory testing.
Some sell their traceability software as some sort of “silver
bullet” that can stop recalls, an all-purpose answer to food safety
issues. Unfortunately, a truly effective traceability system/pro-
gram still needs to be based on evaluations and measurements;
it builds upon departments and systems/programs already typi-
cally in place by expanding data elds and accelerating the con-
nectivity of selective and essential data between departments.
This data, in turn, can be shared between source suppliers and
customers on a regular basis or in the event of a recall.
The key to government regulations is to know how and to what
degree the industry or rm must comply. If they produce in the
United States and then sell in the European Union (EU), then
both United States and EU regulations apply. The industry stan-
dards used within the company must be compatible with their
segment of the food chain and follow-on customers.
For foods and ingredients originating from, or imported to,
the United States, The Food Safety Modernization Act (FSMA)
(Public Law 111–353-Jan. 4, 2011), prescribes requirements for
food surveillance, reporting, and traceability. More speci cally,
FSMA Section 204 requires the Food and Drug Administration
(FDA) to improve its capacity to trace and track food during a
food-borne illness outbreak. Although the FDA has formulated
procedures to regulate traceability, little has been written to re ect
quanti ably signi cant evaluations and measurements pertaining
to the ef ciency/effectiveness of data reporting and of the traceabil-
ity program as a whole. Literature indicates fragmented reviews of
traditionally and well-sensationalized food safety culprits such as
meats, fruits, and vegetables, from consumers’ viewpoints, and the
industry or consumers’ willingness to pay for products with food
safety attributes, such as traceability. Few studies concern percep-
tions and views regarding food safety certi cation or food safety-
related knowledge or training (Peterson 2011).
The key EU traceability regulations include Regulation
European Commission (EC) No. 178/2002, which established
the European Food Safety Authority (EFSA), from which
Regulation (EC) No. 1829/2003 (concerning genetically modi-
ed food and feed), Regulation (EC) No. 1830/2003 (concerning
the traceability and labeling of genetically modi ed organisms
[GMOs], and the traceability of food and feed products produced
from GMOs), and its amending Directive 2001/18/EC.
Food Traceability
The interplay between Regulation (EC) No. 1829/2003 and
(EC) No. 1830/2003—Regulation (EC) No. 1829/2003 on genet-
ically modi ed food and feed was developed alongside (EC) No.
1830/2003 on traceability and labeling of GMOs and the trace-
ability of food and feed products produced from GMOs, both on
September 22, 2003. The two regulations are intended to oper-
ate in tandem and rely on each other for certain requirements.
Notably, the regulation provides traceability requirements for all
food and feed products that fall under the scope of Regulation
(EC) No. 1829/2003. These traceability requirements are of fun-
damental importance when labeling of the nal product relies on
information transmission in the absence of detectable GM mate-
rial in products.
In general, almost all developed, and many developing nations
have their own food safety regulations or have built on various
international or industry standards. For importing/exporting
of foods/ingredients, it is critical to know the regulatory basis
by which that food/ingredient is governed. Some standards
have nearly the stature of regulations in some industries, such
as EurepGAP. The standards section will expand upon how an
industry or company is affected by some of these standards.
Standards are the practical, shop oor practices that can be
measured, laboratory tested, and audited. Often coined “best
practices,” this term does not give justice to the full impact these
standards have over whole industries. With the globalization of
product sourcing and sales markets, it is important to understand
the perspective of the standard, because there are distinct dif-
ferences and philosophical approaches between standards and
regulations.
EU regulations, compared to that in the United States, are
much more prescriptive and detailed, describing the how and
why rather than mere quality or tolerances of the end product.
EurepGAP is a good example of an on-farm-prescribed man-
agement and documentation program. In some cases, this pre-
scriptive type of program assists in protecting the environment,
people, or culture, while at other times, it may hinder innova-
tion and commerce. EU regulations have also had the effect of
in uencing peoples’ purchasing, agriculture, and eating habits
of other nations, by in uencing what they import/export from
other countries. In one case, a country that had planned to import
GMO corn (from the United States) for domestic use faced pos-
sible trade sanctions by the EU due to the GMO importation.
The EU threatened to ban agricultural imports from that country
if they imported GMO commodity products for fear that unap-
proved GMO products may be imported into the EU. This type of
practice is especially troublesome for developing nations regard-
ing imports and exports. Additionally, the understanding of each
country’s particular traceability regulation becomes especially
critical, and is not always harmonious with others. This is not to
suggest that progress is not being made. The United States, EU,
Canada, Japan, and several other developed, and nearly devel-
oped countries have agreed upon many facets of traceability.
Traceability rules and regulations, whether promoted by the
industry or the state, have grown and advanced tremendously.
Some standards such as Codex, International Organization for
Standards (ISO) 22000, and Hazard Analysis and Critical Control
Point (HACCP) standards are internationally recognized and have
helped streamline and re ne many regional and international reg-
ulations. Although some of these standards appear more detailed
267
than most U.S. companies are used to, they are relaxed enough
to offer opportunities toward innovation and competition. As has
been mentioned, several national and international organic organi-
zations are working toward greater rule harmonization for accredi-
tation and certi cation. This may further assist in expanding the
sale of items such as organic products in the global marketplace.
It is unclear how other regional and religious standards, and
their governed products, will be affected by the larger global
in uences that affect agricultural food, feed, and biofuel pro-
duction. There are numerous smaller organizations vying for
attention to persuade government of cials to enact rules and reg-
ulations that favor these particular groups. Often, these groups
are of the grassroots type and propose the bene ts of “buy local,”
preserve our economy, our countryside, our culture, and an
assortment of other mandates that are important to them. Some,
depending on the nature of the proposal, such as highlighting the
origins of the product (geolocation of production and/or process-
ing), have, in fact, been brought into legislation within the EU
and several other countries. Still other standards, such as Safe
Quality Foods (SQF) guidelines and rules, have expanded from
Australia into new markets, countries, and production industries,
and are expected to continue to do so. The kosher standard is
also expected to expand in both types of food prepared (not of
Jewish or Hebrew heritage), but also in pure volume prepared
under kosher guidelines. This is not due to a substantial increase
in Jewish or Hebrew population, but due to the public’s percep-
tion of cleanliness and safety of kosher-prepared foods.
The major international guides toward food traceability, safety,
and quality programs include Codex Alimentarius (CODEX) and
Food and Agriculture Organization/World Health Organization
(FAO/WHO) Food Standards, ISO 9000, ISO 22000, Total
Quality Management (TQM) approach, Deming’s Management
Program, Quality Control, and HACCP standards. Codex pro-
vides an overall forum for international participation, which has
resulted in programs and agreements in areas such as Guidelines
on Nutrition Labeling, Food Labeling (country of origin), and
Standard on Food Labeling (traceability). EurepGAP offers a
variety of services, although it is somewhat more restrictive in
its scope regarding the food supply chain. The most prominent
are the Integrated Farm Assurance (IFA) Program and Farm
Assurance Schemes (schemes include food safety, environ-
mental protection, occupational health, safety and welfare, and
animal welfare where applicable). These are primarily on-farm
systems that farmers follow to meet the prescribed demands of
their suppliers. They also offer systems that utilize benchmark-
ing frameworks to achieve certi cation based on ISO Guide 65.
EurepGAP also accredits bodies to conduct accreditation for its
benchmarking procedures.
Traceability standards offer much more than just opportuni-
ties to minimize recalls. Traceability helps market other traits or
credence attributes of interest desired by many individuals and
cultures, namely geolocations, religion, and other speci c quali-
ties or characteristics. These other regional and other religious
systems or standards include
Freshcare
Woolworths Quality Assurance (WQA) Standard
NCS International
268
British Retail Consortium (BRC)
FARRE
ARVALIS
SOPEXA
FNCIVAM
FNAB
ORGECO
Groene Hoed, or Green Hat
Buddhists
Hare Krishnas
Hindus (lower/high castes)
Mormons
SQFs in Australia
Japanese Agricultural Standard (JAS)
Halal rules
Kosher rules
American Institute of Baking—certi cate of standards,
audits, and technical/analytical services
A growing number of major food grocery chains now man-
date that, due to increased food/beverage safety regulations,
members of their supply chain must follow several standards
concurrently such as SQF, HACCP, and ISO 22000. This usu-
ally occurs in unison with the use of Enterprise Quality and
Compliance Management software, which offers packages such as
Document Control, Corrective, and Preventive Action (CAPA),
Nonconforming Materials, and so on.
Whatever the standard, both internal and external audits help
con rm compliance of the standard. The standard’s perfor-
mance, including how well the standard was followed, is only
as good as its people, program, management, training, and the
like. So too are the auditors’ competencies, and who performs
the audit. The auditors’ results can weigh heavily upon all facets
of a company as well as on suppliers and customers. Auditors
must have both technical skills and knowledge of the art of audit-
ing to perform their job. Often, this goes from beyond the typical
checking the box to con rm an action, to understanding whole
systems and interpreting the management’s actions to meet com-
pliance (Surak 2014).
For the longest time, in-house testing has focused on the test-
ing of the product, or “product testing,” to ensure food safety.
Some in the processing industry feel that too much reliance is
put on product testing. This is especially true when processed
foods, and their input ingredients, are well known in both ori-
gins and safety, and when processed under a critical means of
control. The main advance in process testing or certi cation
has been prescribed by systems such as HACCP. HACCP was
designed because individual product testing could not meet the
requirements of detecting microscopic defects, such as E. coli or
Salmonella contamination in products. For example, raw ground
meat or fresh produce is nearly impractical and inef cient to
test. Typically, you can test the process by rst testing the n-
ished product for indications of microorganisms, which would
verify the effectiveness of the program. The second part is to
sample test the processing environment to determine sanitary
conditions. This can be further subdivided by product-contact
Handbook of Food Analysis
surfaces, non-food-contact surfaces, oors, sinks, work areas,
and changing rooms. Some programs include common hardware
such as sifters, areas where there may be product spillage such as
on conveyers, salvage or rework, dust collectors, drain traps, and
scraper blades (Surak 2014).
Another step toward increasing food safety is hazard analysis
and risk-based preventive control or HARPC. Traditionally, good
manufacturing practices (GMPs) provided the safety structure
for food governed by the FDA. These general rules or guide-
lines oversaw manufacturing, processing, and sanitary condi-
tions to ensure that food was safe. HARPC goes a step further
by identifying potential threats to the processing environment
and attempts to remedy the situation before an unsafe situation
develops. FSMA, Section 103, requires food facilities to formu-
late a written plan in place that evaluates facility hazards that
can affect all aspects of production, identify and implements
deterrent controls, and monitors control performance, rather than
deterrent controls to develop corrective actions, and veri es the
effectiveness of preventive controls. Validation of the program
will encompass preventive controls, monitoring effectiveness,
and compliance with corrective action (Lindstrom 2013).
The globalization of input supplies and expanded markets in
which to sell is intensifying, and this helps accelerate the haz-
ardous effects of unsafe foods. International sourcing, be it for
a single rm or by a company upstream and/or downstream,
shifts more and more activities beyond a company’s direct con-
trol. Companies are held responsible for a risk that someone
else (another rm) is exposed to, and they may unknowingly or
knowingly take and pass that risk to the next supply chain recipi-
ent. Quality standards are further muddled and confused when
cultural and economic differences compound a food safety issue.
Foreign markets, be it for sales or to purchase ingredients, have
different beliefs and experiences regarding food safety risks,
which directly affect safety measures and quality control pro-
grams (Oehl 2010).
Change can be dif cult for anyone, and manufacturers and
processors are not different in their resistance to it. Adding a
layer of oversight or controls only adds to expenses and reduces
pro ts. This has been especially true when voices of concern
suggested, several years ago, that food processors incorporate
scienti cally based safety programs, which many argued against.
But the programs were implemented, and they not only provided
safer products, but also helped many companies’ bottom line.
The same thing occurred when the notion of system procedures
testing and auditing was introduced, such as with HACCP. The
additional tests, laboratory work, monitors, and additional per-
sonnel were enough to discourage many members of the food
industry. However, once again, the additional overhead, tests,
audits, and so on proved bene cial to meet regulations, lowered
overhead, and increased safety.
The adoption of additional layers of safety or quality pro-
grams has several common characteristics. (1) The industry is
often reluctant to incorporate the planning, SOPs, audits, and
so on, that eventually they come to embrace. (2) With adoption,
an incremental increase in data transparency occurs, from data-
driven matrices that support improving the quality of inputs to
streamlining logistics and availability of readily available desk-
top data. The linkage distance time (source to user) between
data shortens; the qualities and traits of inputs coming in from
Food Traceability
vendors can be known and measured before they arrive on the
loading dock. In-house processing can be much more detailed
to detect defective product(s) more quickly, thus minimizing
rework and recall. Transparency and the amount of data stored
and shared between upstream vendors and downstream custom-
ers further improve safety, logistical controls, and reduce the
likelihood of recall.
A corporation’s traceability program inherently bonds the orga-
nization together more closely via their safety culture, training,
and shared knowledge of quality performance. The key driver
for the success of the traceability program starts and ends with
not only the apparent buy-in of senior staff, but in their continual
embrace of the traceability program. All too often, traceability,
or its concept, is overlooked until a catastrophic recall happens.
Most traceability programs begin with evaluating and agree-
ing on not only safety aspects, but also the business goals they
support. Potential business goals may include (Jorgenson 2004)
the following:
Gathering the data necessary to support marketing
claims (such as 100% organic, GMO free, fair-trade
products, and adherence to humane animal agriculture
practices),
Proving compliance with contractual requirements
(meeting the speci cations of raw materials and ingre-
dients that are supplied to food manufacturers),
Verifying regulatory compliance (such as Bioterrorism
Preparedness, USDA National Organic Program
standards).
At food traceability conferences, it is common to have process-
ing and grocery stores’ vice presidents in attendance. Many of
these attendees echo that they know of traceability, or its concept,
and participate in versions of mock recalls. Additionally, most
senior executives depend on traditional internal/external food
audits and marketing reports to justify their system’s performance.
Competition between, and rigidity toward change or risk has
many department heads, directors, and vice presidents reluctant
to share data or power. In spite of modern computers, email, tab-
lets, voice conferencing, instant messaging, and cloud data shar-
ing, there are entrenched barriers and walls that restrict or retard
in-house communications of critical data ow. The traceability
program inherently makes bare where the open access/sharing of
data is buttressed against, be it in-house or external. Sometimes,
procurement people do not speak the same language as logistics
personnel. Departmental cultures sometimes con ict with one
another.
Whether in the mundane of a regular day, or in the heat of a
massive recall, senior management needs to be able to correlate
vast amounts of data from a wide array of sources to manage
the traceability program. Senior management needs to be able to
consolidate and analyze essential data from outbound, inbound,
and internally used products, to incorporate or issue certi cates
of analysis (COA), and to track divergence in HACCP control
points and send alerts as required. The traceability program
provides immediate measurements of farmer, supplier, proces-
sor, or transportation performances to gain actionable insight;
to ensure vendor compliance with records and veri cation; to be
269
able to engage in a surprise audit or mock recall with data and
with records that are immediately available; and to ensure a fully
immersed GS1 barcode system. This is accomplished by various
means and programs, some of which include enterprise resource
planning (ERP) systems that involve cloud-based technology,
mobile and remote accessibility, to advanced laboratory infor-
mation management systems (LIMSs), which can ensure that all
parts of the production and food supply chain data are captured
and analyzed. These help mitigate the chances of a defective
product and helps promote consumer safety (Philips 2012 and
Thurston 2010).
How a company responds to a recall can determine how will-
ing the customers will be to forgive the company, especially for
those who show a real commitment to doing the right thing. A
denial response, in the face of governmental involvement and
media publicity, only exacerbates the situation and prolongs the
recovery. Regardless of the reason or cause, honesty, transpar-
ency, and openness show that they acknowledge the issue or con-
cerns regarding their product, publically obligate themselves to
working with authorities and their customers to resolve the cause
of the recall, and make obvious their promise to protecting con-
sumers, even if it means a reduction in sales (Martinez 2012).
The recall program or plan embodies the legal and ethical
responsibilities that everyone from senior staff to line employees
have to ensure that their products are safe, hygienic, and labeled
correctly. Ultimately, it serves to satisfy the regulators and court
of public opinion. The program mandates their full cooperation
with federal/state agencies, ensures that all prerequisites of a
food safety program are followed, identi es all risks and pos-
sible risks and implements corrective actions to mitigate those
risks, incorporates a product identi cation methodology and
barcode-type tracking system, mandates and checks data record-
keeping, identi es a recall team and recall plan, and frequently
executes unannounced mock recalls that involve “one-up, one-
back” traceability.
The plan outlines and is organized by advanced planning, deci-
sion making, actions to be taken, communications to be completed,
removal of the affected product, and an after-action review. The
decision tree used to determine when to initiate a recall should be
clearly de ned as well as the actual recall process. The recall plan
maps the objectives of the recall program, its features, and general
considerations in its development, and its ongoing improvement.
Documentation, forms, templates, contact lists, and communica-
tion logs must be maintained accurately and up to date. Items such
as date, time, conversation details, and medium of communica-
tions of contacted government of cials, vendors, customers, dis-
tribution centers, wholesalers, importers, exporters, retailers, and
paid advertisements and media releases are critical. The recall
plan should hold historical information regarding previous recalls
and mock recalls; appropriate regulations, a listing of possible
issues that could likely be faced by the company, and a library of
past recalls experienced by other companies.
Mock recalls help prepare for the real thing and for the
required audits that take place. Mock recalls test the company’s
recall program and procedures to determine whether identi-
ed lots are quickly located, contained, and reconciled against
quantities produced, in the inventory, and distributed. The mock
recall also helps determine possible problems, and allows per-
sonnel to deal with the recall procedures. This then allows for
270
corrective actions regarding de ciencies in the program. Recalls
affect personnel and food safety programs involved in
Raw material inspection
Integrated pest management
Sanitation
Preventive maintenance
Hazard analysis and critical control points
Good manufacturing practices
Quality management systems
Food security
Microbiological monitoring
Environmental monitoring
Finished product inspection
Document policies
Employee training
Plans should be veri ed and conducted once or twice a year,
be unexpected, at inopportune times, as realistic as possible,
increase in dif culty with time, involve multilevel distribution,
include all departments, test all aspects of the recall plan, and
go beyond the company’s walls to vendors who sell ingredients
and customers of the product. Documentation is essential for all
activities, and all required forms/templates should be used. In the
end, all teams and departments must pull together to critique and
review all aspects of the mock recall. Ultimately, the key staff
will assess the mock recall’s effectiveness, identify issues and
de ciencies found during the exercise, and make the appropriate
changes to the program.
A recall plan has several parts including a mock recall. A
recall plan must be written and includes a table of contents,
dated, and approved by a corporate authority. It should include
its goal(s), de nitions, statement of recall plan, legal require-
ments, roles and responsibilities, how to run a mock recall, and
include all necessary templates, logs, forms, and ow charts.
This framework should include when a recall should be initiated,
includes the decision tree used to determine a recall, memos/
emails of discussions, and team members involved. It also deter-
mines whether the recall should be a trade recall (product held
by warehouses and distribution centers) or consumer recall. This
is where the recovering product is held, not only by warehouses
and by distribution centers, but also through all forms of outlets
in which the consumer may have had contact (Burson 2003, Get
Fresh 2010, Nelson 2010, San lippo 2008).
Recall procedures prescribe what the company intends to do
to manage the recall. This includes assignments of roles and
responsibilities, investigation of the complaint/condition, identi-
cation of the affected product, noti cation of affected entities,
and removal of the defective product. The recall manager/coor-
dinator should have a well-de ned and recognized authority by
the management (in writing) to execute all activities of the recall.
This includes tasks such as documentation of all recall decisions,
activating assets for priority assistance, and creating a recall
committee. The recall committee should include the following:
Recall manager
Regulatory affairs
Handbook of Food Analysis
Management (Admin)
IT
Quality/safety
Accounting
Procurement
Public relations
Customer service
Logistics
Marketing
Operations
Production
Maintenance
Records management
Legal
Sales
Janitorial
Outside services as needed
Investigation of the complaint or condition includes receipt
of the complaint/condition, an investigation, and its evaluation.
The sources of a complaint may come from in-house testing, cus-
tomer complaint, a supplier, or government authorities. If it is
from a customer, the complaint should have complainant contact
info, reported problem, product ID/lot #, product location, pur-
chase date, and illness and injury details. This information then
goes to the appropriate staff or committee for determination of
the hazard and evaluation of safety concerns, decision on a prod-
uct removal plan, communication with authorities, noti cation of
legal and insurance, and recording of all activities pertaining to
the recall such as dates, actions, communications, and decisions.
The issue may include microbiological results beyond acceptable
limits, chemical contamination, the presence of foreign mate-
rial, adulteration, labeling error, packaging defect, or improper
processing.
To help identify defective products, all products, their quan-
tities, brands, and sizes, should be barcode/GS1 listed and dis-
tributed to all consignees, account addresses, contact-named
personnel, and contact phone numbers/email addresses. Each
product at each stage should be identi able. On farms, records
should include the name of the product, grower, farm (acre-
age—section, township, and range), harvest dates, supervisor,
scale tickets, identi cation of the carrier that transported the
product, weather conditions (if necessary), truck/product desti-
nation, storage and packing info, and bills of lading. For food
processors, more information is generally available and required
to discern one product lot from another. This should include
the nature of the problem, including the brand name (to include
product description, package size, and package type), use by
or best-before date, the lot, batch, or serial number identi ca-
tion, quantity of batch, date, and volume released, the number
of affected products, and distribution list of possible customers
(including importers and exporters). A recall checklist helps
ensure that all facets of the recall plan are achieved.
The noti cation of affected entities or customers must be done
swiftly and include all appropriate regulatory agencies, the dis-
tribution network, attorneys, newspapers, extension food safety
Food Traceability
educators, and consumers (when necessary). Recall notices go to
agencies and businesses, whereas press releases go to the public or
consumers. Of note, regulatory agencies should be noti ed as soon
as the decision to recall a product has been made, and updated
throughout the recall. Members of the distribution chain should
be noti ed swiftly by telephone, fax, email, letter, and the like;
followed by a written recall notice to all consignees that includes
all relevant recall information. A con rmed receipt of all noti ca-
tions regarding all those involved in the distribution chain must
be recorded. Consumers must be noti ed by the most effective
method, usually beginning with press releases of all the relevant
information that the public should know. To ensure that the distri-
bution of the affected product is stopped and arrangements are in
place to recover affected products, customers (distributors, whole-
salers, and retailers) will need at a minimum to know the product
name (batch code and/or expiration date), why the product is being
recalled, where to return the unsold product, and whom to contact
at the company for further information. A summary of data should
be made in detail to help facilitate affected products.
The removal stage of the affected product includes its removal,
control, disposition alternatives, measure of the recall plan’s effec-
tiveness, and recall closure. The affected product should be held,
inventoried, segregated, and handled in a predetermined manner,
and all quantities and identi cation codes must be recorded to
assist in reconciliation. Tracing may take one or many forms, such
as trace by work order or lot number. Typically, food businesses
use intermediate distributors and may not be in a position to pro-
vide distribution information for further down the distribution
supply chain. It may be useful, therefore, for businesses to check
that their distributors have a similar ability to quickly provide a
list of their customers receiving the food product and a means
to quickly notify them. Affected products may be recovered by
returns to retailers, returns via distribution supply chain, or direct
returns from customers. If the distribution is widespread, it may
be necessary to establish collection sites across a wide area.
A mock recall begins when the recall team chooses a mock
product, a location where a consumer bought the product, and
further identi es a lot of a given product and lot number that
tested positive for a speci ed contaminant. Step 1 is to initiate
the recall program and perform trace-back procedures, identify
sources using the lot #, identify where all possible lot #s may
be located, and as an evidence (for review later), get records
and supporting documents for each of these activities. Use pre-
planned spreadsheets for inventory accountability for items such
as product implicated, # of units, processed date, and so on. Step
2 is to conduct trace-forward procedures to identify all nished
products that contain the defective ingredient, to include all cus-
tomers and the disposition of the product. Verify communica-
tion systems (such as contact information, test emails, faxes, etc.)
to outside contacts. Step 3 is to adjust the recall plan to correct
issues found during the exercise, and records of the mock recall
should be documented.
During the postrecall evaluation, it is important to achieve a
clear understanding of why the recall was required, what caused
the contamination or the product to become defective, if it was
a labeling issue, whether written procedures were not being fol-
lowed, whether proper laboratory tests were conducted, whether
there was enough or proper in-house expertise, and why supervi-
sors or senior staff were not made aware of possible de ciencies.
271
Within these reports, matrices, and scorecard successes and short-
comings, regarding items such as media noti cation and regions
noti ed, to the percentage of the product reacquired, can be exam-
ined and reviewed. Appendices should include recall committee
members and key personnel contact information, document tem-
plates, spreadsheets, and forms, additional resources/government
agencies, and a detailed listing of assigned responsibilities.
The mock recall is a practice run for an actual recall, and
the simulated exercises are based on current food products that
can be improved. The mock-recall exercise is an opportunity to
practice and resolve any problems prior to an authentic recall.
Ultimately, traceability occurs within a system, and not at an
individual rm.
There is no quick x, no software, and no test, which will pre-
vent a recall. Some software providers may help facilitate the
implementation of, or improve, a traceability program by incor-
porating the working safety and QC/QA programs tied to labora-
tory tests and audits that most companies already have.
In general, current voluntary procedures provide a wide-
ranging, technically based doctrine to diminish microbial food
safety hazards and outline good agricultural practices (GAPs),
good farming practices (GFPs), good processing practices
(GPPs), and GMPs. On the farm, this can include water and
manure issues, worker hygiene, land history, and surrounding
properties to transportation/warehousing, on through to process-
ing and manufactures (Pabrua 2004).
The basis for a successful traceability program is the meld-
ing or overlapping of safety and QC/QA, administration, logis-
tics, accounting, and IT departments’ views of traceability. This
includes working more closely with increased transparency of
data, and with a more commonly shared language. What makes
a traceability program work is the enhanced or greater integra-
tion of these and ancillary departments when combined with
executing the program’s associated SOP, mock recalls, lab test-
ing, and in-house/third-party audits. The traceability program
can be evaluated and tested by reviewing mock recalls, in-house/
third-party audits; and most importantly, the development of an
internal traceability cost/bene t analysis and scorecard matrix
of traceability data velocity (or how fast and accurately critical
traceability data can be shared).
A traceability program is unique in its formation and imple-
mentation. Critical, as mentioned, is that the senior manage-
ment and/or executive staff has absolute buy-in for all to see
and believe. Otherwise, the program is lost, awaiting external
regulations to force corporate change. In assisting senior staff, if
no internal traceability specialist is available, the advice or con-
sultation from a recall insurance/assurance provider may help
greatly in shaping how the traceability program is implemented
and mitigates its overall expenses.
The rst place to start is the safety department, which should
provide to the senior management (1) an accurate and all-inclusive
database of ingredients and their speci cations to include pur-
chasing contracts (with speci cations and certi cation of analy-
sis [COA]), vendor traceability/safety programs, and so on—that
all company departments have helped develop; (2) a detailed
and comprehensive vendor-purchasing agreement that lists, and
shows proof of, compliance in regard to federal rules and regula-
tions, be it domestic or foreign suppliers highlighting the type of
auditing protocols followed, frequency, and results, if there are
272
indemni cation clauses, and if changes are made in regard to who
processes, packages, to changes in lot size; (3) a preferred certi ed
auditing program to be used by in-house and third-party auditors
(and protocols to address corrective actions) and speci c auditors
who understand the products and appropriate cultural practices
used to include the knowledge of category risks, likelihood and
symptoms of adulteration, historical data, social media, to recent
intelligence; (4) a detailed prescription of preventive controls and
monitoring/testing program to include items such as HACCP and
risk analysis that tie both statistical validity and sound sampling
methodology; and (5) an encyclopedic traceability program to
include its development and implementation, meeting all regula-
tory mandates and able to track and trace all items one step for-
ward and one step back, to include cleaning agents, materials, or
environmental changes of signi cance (Ades 2012).
While some suggest (software providers and academia) that
they can determine where in a farmer’s eld mycotoxin or E.
coli may have originated, a processor’s practical focus must be
on what the company can realistically control and measure. In
this case, the focus should be on products that are most likely
to be recalled for reasons such as E. coli and Salmonella, prod-
ucts such as vegetables and meats that have had a proportion-
ally larger volume and frequency of recalls. The choice can be
based on the cost of a past recall or likelihood of a product being
recalled. It is suggested that a speci c product line (e.g., veg-
etable or meat product), or beta-processing plant (if a company
has several processing plants), is designated to design and test
the new traceability program. This is especially critical for items
such as imported spices, seafood, vegetables, meats, and items of
unknown quality.
Once a product line and/or plant is determined, an outline
of how, and what, to measure is critical. Cost/bene t analysis,
quality/purity evaluations, and data velocity scorecards must be
developed and compared to in-house and third-party preaudit
assessments of the traceability program, which will help dem-
onstrate the degree of implementation success the traceability
program has accomplished.
The traditional system of documentation is moving from paper
based to computer- or electronic based. However, many of our
more modern technology systems are still very fragmented in
regard to integrating individual traceability systems to one
another in the supply chain. Lack of interest by senior manage-
ment, disassociated administration training of the traceability
processes, and line workers not being able to connect the dots as
to why traceability matters and where it ts in, needs to be over-
come. The company’s strategic plan should include traceability
and its concepts. From there, products and process locations can
be determined to develop the traceability beta program. As the
program develops, mock recalls can be added to audits and labo-
ratory tests as a measure for the management to determine com-
pliance and the risk factor. Traceability program training needs
to be developed and standardized, including emphasizing the
need to be more transparent and linked to improve interactions.
The cost of diverse government regulations, proprietary service
offerings, and incompatible commercial solutions to companies
and the global supply chain call for de ning traceability as a core
business process, which should be supported by voluntary busi-
ness standards that are accepted around the world. Food-borne
diseases are here to stay; however, a company can help diminish
Handbook of Food Analysis
the risk it bring through the loading docks, along the process
line, and through the end consumer with a traceability program
that helps reduce risk, helps reduce negative brand name expo-
sure, and improves the bottom line through improved supply
chain logistics accounting.
BIBLIOGRAPHY
Ades, G., C. W. Henry, and F. Feldstein, The food safety challenge
of the global food supply chain, Food Safety Magazine, Dec
2011/Jan 2012, 17(6), 32–66.
Burkitt, L., Hundreds in China fall ill: Additive suspected, Wall Street
Journal, 2011, A10.
Burson, D., Product Recall Guidelines, University of Nebraska—
Lincoln IL, created Sept. 2, 2003, http://www.foodsafety.unl.
edu/haccp/advanced/Product%20Recalls.pdf.
Cannon, B., Mock Recall Procedures, John B. San lippo and Sons,
Inc., NPSA Annual Meeting, 2008. http://www.ilovepecans.
org/wp-content/uploads/2013/06/mock_product_recall.pdf.
Corder, M. and Choi, C., Product Withdrawal and Recall Procedures
Manual, Get Fresh Produce, Bartlett, IL, August 23, 2010.
Craymer, L., New Zealand pushes technology to head off mislabel-
ing of meat, Wall Street Journal, 2011, A1.
Jorgenson, B., Technology for the supply chain: Bene ts, costs,
Perceptions presented at the International Food and
Agribusiness Management Association (IAMA) Conference,
Montreux, Switzerland. Published by John Deere FoodOrigins,
June 14, 2004.
Lindstrom, E., FDA’s HARPC is like HACCP, Food Processing, 2013,
74(3), 15.
Martinez, J., Response to crisis de nes a company, Food Safety
Magazine, 2012, 73(3), 13.
Martin, T. W., L. Stevens, and J. W. Miller, Rare germ drives out-
break, Wall Street Journal, 2013, 128, A9.
Nelson, R., What’s a Mock Recall and How Do I Perform One? SE
Regional Fruit and Vegetable Conference, Savannah, GA, January
7–10, 2010. http://gfvga.org/wp-content/uploads/2010/03/8.-
How-to-Conduct-a-Mock-Recall-Nelson.pdf.
Oehl, F., D. Floyd, and A. Fowler, Food safety’s new regulatory reality:
Are you prepared? Food Safety Magazine, 2010, 16(2), 30–48.
Pabrua, F. F. and J. Williams, JR, Challenges, progress and solutions in
produce safety, Food Safety Magazine, Dec 2003/Jan 2004. http://
www.foodsafetymagazine.com/magazine-archive1/december-
2003january-2004/challenges-progress-and-solutions-in-
produce-safety/.
Peterson, C., Results of a new national survey, Food Safety Magazine,
2011, 17(2), 12–14.
Phillips, D., Fast and transparent, Food Processing, 2012, 73(2), 72–73.
Smoked salmon blamed for salmonella outbreak, Wall Street Journal,
2012, A10.
Surak, J., Progress on the ISO 22000 front, Food Safety Magazine, 2014,
20(1), 20–23.
Thurston, C., LIMS in food safety traceability efforts, Food Quality,
2010, 17(2), 33–35.
Tomson, B., Contaminated water cited in listeria outbreak, Wall
Street Journal, 2011, A7. http://www.wsj.com/articles/SB100
01424052970204485304576641112740698384.
(Portions of this work were derived from the research that went into
Gregory S. Bennet’s publication Food Identity Preservation
and Traceability: Safer Grains, CRC Press, 2009.)