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Responsibility encouraged to achieve food safety traceability
By DOROTHY NOBLE
BALTIMORE (May 19, 2015) — A key component of the Food Safety Modernization Act is traceability. At the recent Food Safety Summit Dr. Jennifer McEntire, vice president of science operations, Grocery Manufacturers Association, offered at the working perspective on traceability.
FSMA’s proposed rules aim for prevention of foodborne illness. The ability to quickly trace an outbreak is critical to identifying the source to preclude further illness and to prevent future occurrences.
McEntire distinguished traceability from recall situations. Traceability is regulation-driven, whereas recalls are industry-driven.
Traceability is supply chain wide; recall currently follows the ‘one step forward, one step back” pattern.
In traceability, the scope of the issue is unknown, while in a recall, there is a specific known issue.
Searching to identify a common source characterizes traceability; locating a known product describes a recall situation.
Pointing to the FSMA proposed rules, McEntire noted that a recall plan is required in the preventive controls proposal.
In the foreign supplier verification standards for the imports proposal, the bio-terrorism act requires the “one forward, one back” measure.
To underscore the importance of speed, tracing should be accomplished in 24 hours in a recall situation. But depending on the product, tracing can be laborious and quite time-consuming. An outbreak of tuna sushi, for example, involves not just tuna but also all the ingredients in the preparation.
McEntire illustrated the time difficulties with the recall of peanut-contaminated cumin, which was announced on December 26, 2014. She said that even on this late April 2015 date, all the information relating to that incident is not yet known.
Because of public health considerations, however, she said that the Food and Drug Administration proposed rules could not pull back on timeliness.
McEntire called on a FDA spokesperson to address the need for improvements in the process, given the limits imposed in FSMA.
The spokesperson indicated that FDA could accomplish its standards under Sec. 204 in FSMA for high risk foods, but that it would be difficult, and the agency needed help to accomplish its goals of timeliness. “It will take everybody’s effort,” she stressed.
McEntire quizzed the audience regarding the person responsible for food safety in a company.
The responses spanned food safety or quality control personnel, inventory management staff, sales or processing personnel, or the information technology team.
She concluded, “It should be all of the above.” Also, top management must be supportive.
McEntire advised the attendees to understand the recall system, test their recall plan, and quantify their return on investment.
Further, understand their suppliers and customers, and their record keeping systems.
Finally, she said, “Be able to sell the value of improving traceability to your higher-ups.”
FDA has been court-ordered to issue the final produce safety and foreign supplier rules by October 31, 2015, and the preventive controls rule by Aug. 30, 2015.