Traceability and Food Safety
Traceability regulations have been in force since 1 January 2005
04/10/2004
Oscar Hernández Prado, Paloma Cervera Lucini and Mª Luisa Aguilar Zambalamberri.
Article 18 of Regulation (EC) No 178/2002 of the European Parliament and of the Council, whose main objective is to agree on concepts, principles and procedures in relation to the free movement of safe and wholesome food, introduces, for the first time, for all food and feed companies, the requirement to have a traceability system in place from 1 January 2005 for "food, feed, food-producing animals and any other substance intended to be, or expected to be, incorporated into food or feed".
Traceability must be conceived as a system for identifying products or product groups throughout the food chain, especially for reasons of food safety, although the accumulated information can be used for other purposes established under Regulation 178/2002.
All companies must operate a flexible, fast and efficient document management system to identify and track products that arrive, are stored or leave their premises so that, in the event of any product safety issue, the necessary measures can be adopted. One of the essential requirements for achieving the objectives set out for this system is the total involvement of all the links in the food chain. Any break in the transmission of information at any point would render the entire system ineffective, making the efforts of other operators useless.
Although, at first sight, it seems to be something completely new, the management tool required in Regulation 178/2002 is implicit in the Hazard Analysis and Critical Control Points (HACCP) system that all food businesses must operate. The management of an HACCP system, the purpose of which is to limit hazards in relation to the production and marketing of food, requires the identification of products under the responsibility of the trader.
Furthermore, it should be mentioned that this requirement, in terms of its implementation, has already been made for certain sectors, including the necessary means, such as with Genetically Modified Organisms (GMOs), beef, fish and fishery products or eggs.
Apart from the legal requirement, monitoring an effective traceability system offers great advantages for traders, consumers and for the government.
In the event of health issues, customer complaints, production issues..., traders may recall products more quickly. It is also capable of establishing the cause of the problem and proving it with the necessary diligence, and decide the destination given to the said products. Effective management in the event of a crisis considerably reduces the damage to the commercial image of a brand.
Consumers will be more satisfied with and trust the products they consume if they have the guarantee that the information is transparent along the entire food chain.
The Public Administrations may act more effectively when handling health alerts, food poisoning situations..., thus limiting emergency situations which are so damaging to consumers and to businesses. Furthermore, the Public Administrations may place greater trust in institutions that have implemented a traceability system, as they make official control operations easier.
The first step may be the most difficult but also the most important. It is necessary to make a detailed review of all processes and registry systems carried out in the business and to assess their potential usefulness.
In some cases, we may find that all the necessary measures are already in place, for example, within the framework of the HACCP system, of product reception registers or supplier control. However, on most occasions we will find that certain specific traceability procedures have to be adapted or introduced.
It is advisable to contact suppliers and customers, officials from other institutions, auditors and authorities.
Although the steps may vary according to the literature consulted and, in any case, they will have to be customised and established by the head of the establishment, the following four steps are required to implement a correct traceability system.
Each company must group all the units it produces, manufactures, packages or, in broad terms, manages. They must then be identified.
The criteria for grouping products may be many and customised for each business. Examples may refer to time periods (weekly, daily, production by hours), the production line, place and date of capture (in the case of fish)...
The degree of precision with which products are grouped together determines batch size and must be defined by the company, seeking the best balance between reducing risks in the event of a product safety issue and the excessive economic and management complexity that greater accuracy requires.
The next decision will be to how to identify each batch that has been defined in terms of the activities performed and the circumstances surrounding each business. There are many methods, from simple hand-written labels to information technologies available today (bar codes, radio frequency chips...).
Whatever type of identification is used, reaction time should be minimum, making it possible to identify a product leaving a company, the products involved and the production and marketing processes followed.
Backward traceability will provide the possibility of obtaining relevant information linked to an intermediate or final product as far back as the origin of the raw material used. Points to consider in each company will be the name and address of the suppliers, the goods received to their identification, number of units and date of minimum durability or the date of reception.
The traceability of the process will link the products that come into a company with those that are shipped out. It is necessary to take account of the divisions, changes or mixtures affecting batches or groups as well as the number of points at which records or links have to be made with the established self-control system. A number of relevant aspects should be considered at this point, such as the identification of the products obtained as a result of the operations performed in the company, from which products, number of sales units produced or processes that have been carried out and when.
Forward traceability will provide information on where a given product has been distributed. It enables us to know the final product in which a given raw material has been used. All companies should register the name and address of customers, the goods distributed and shipment dates.
While the scope of traceability depends on a company's activities, in general, backward traceability is required whenever there is any supply of products from a supplier and process traceability is required when there is any type of combination, mixing or splitting of batches or groups of products that have been received. Forward traceability may only be overlooked when products are exclusively destined for final consumers.
The responsibility of each feed and food business in relation to traceability ends when the previous link and the subsequent link are identified in relation to a particular product in the market. Traders are not expected to be aware of all the processes raw materials have to go through until they become final products, but they must know what happens within the scope of their own activities. The information provided by each and every one of the operators involved in the chain will enable us to know the full history of the product.
The filing system chosen from among the full range offered on the market should allow a rapid response to any issue that may arise. It should be remembered that the record keeping method used within the framework of the HACCP system can help to establish a traceability system.
The description of the system includes the criteria for grouping of products, the scope of application and the general features of the plan. All documents connected with the products (raw materials, intermediate and final products), with marketing (suppliers and customers) and with any activities resulting from system verification procedures must be recorded.
During the periodic check to ensure that the traceability plan is working correctly, it is advisable to simulate a health alert situation. This can be achieved by selecting any product randomly and trying to identify the raw materials used and, in contrast, by selecting the documentation on any raw material randomly and trying to identify the product in which the said material has been used and its distribution data.
Key points:
- A good traceability system should allow us to act quickly and effectively
in the event of any problems that arise during the production and marketing of
food.
- It is especially important how product groups are defined and
identified.
- All the elements in the chain should be involved. In the event of any
interruption in the chain, the system becomes completely ineffective.
Regulation (EC) 178/2002 of the European Parliament and Council of 28 January 2002 laying down the general principles and requirements of food law, establishing the European Food Safety Authority and laying down procedures in matters of food safety. Official Journal of the European Union 1.2.2002
- McDonald's Spain Traceability Report (PDF)
- Traceability throughout the food chain. Menendez Pelayo International University (PDF)
- Traceability throughout the food chain. Eduard Mata Albert (PDF)
- Guide to implementing the Traceability system in the food business (PDF)
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