One key area of critical infrastructure protection, as outlined in President’s Homeland Security Presidential Directive-9 (HSPD-9), is enhancing the protection of food and agriculture defense. Securing an increasingly global food supply-chain, however, has proven a daunting challenge as witnessed by the series of high-profile food-poisoning cases in the past five years involving bagged spinach, lettuce, tomatoes, wheat flour from China, hot peppers from Mexico and last winter a salmonella outbreak apparently related to peanut products blamed for killing several people, sickening hundreds more and leading to the recall of more than 1,500 peanut-related products.

To address the task of better ensuring the supply-chain The Food and Drug Administration's Center for Food Safety and Applied Nutrition (CFSAN) last week released a report from the Institute of Food Technologists (IFT), which recommends clear objectives be set for all users of a simpler, globally accepted food supply chain.

The report, titled Product Tracing in Food Systems, was commissioned as part of the agency's ongoing examination of food product tracing practices.

“ Food can become contaminated at many different steps in the supply chain,” the report says, “ Experience in conducting foodborne disease outbreak investigations suggests that improved product tracing abilities could help identify products associated with disease more quickly, get risky products off the market faster, and reduce the number of illnesses associated with foodborne illness outbreaks.”

IFT collected product tracing related information from industry representatives through telephone discussions and meetings with targeted groups, and from a number of other resources. A total of 58 food companies categorized as produce (38%), packaged consumer foods (14%), processed ingredients (7%), distributors (5%), foodservice (17%), retail (12%), and feed (7%) were consulted.

Key to effective tracing, the report explains, is a uniform system for allowing a product to be traced through the supply chain. For example, the report says, “each time a lot number is changed, the original and resulting lot numbers must be recorded. Similarly, if a lot number is unchanged, but the product moves between facilities, this information must be recorded so that the path of the product can be followed. The key data elements that should be provided in an electronic form using an approved standardized format, for each case containing a product of interest include: As a best practice, the lot number and name of the manufacturing facility should appear on each case of product, and the lot number(s), quantity and shipping location should appear on invoices and bills of lading.”

In regard to record keeping the report recommends that “each facility handling a product must record its specific transactional portion of the information for each Critical Tracking Event.

“ Critical Tracking Events (CTEs),” it explains, “ are those instances where product is moved between premises, is transformed, or is otherwise determined to be a point where data capture is necessary to trace a product.”

Neglecting to capture appropriate data elements at a CTE, the report warns, will result in a break in the product tracing chain, since CTEs capture changes in information, such as changes in lot numbers,that provide the link between products within a product pathway.

With regard to product transformation, it adds, “ information captured at those CTEs must be able to accurately match ingredients or incoming material, at the lot level, to outgoing product. Each lot number of each case of shipped product should be recorded, even if “first in, first out” practice (FIFO) is adhered to.”

The report urges that records be maintained for two years or the shelf life of the product, whichever is longer, with each entity providing this information to FDA, as requested, in an electronic format within 24 hours.

Additionally the report calls for better standards for accurate internal tracing food companies.

“ For products that do not undergo further processing or transformation (e.g., the case is not opened) a one-to-one relationship between incoming and outgoing lots must be maintained,” it says. “For example, if a pallet contains cases with different lot numbers, those cases will need to be followed individually through a system.”

To accomplish these goals, the report explains, there needs to be agreed-upon nomenclature and standardized ways of expressing information.

Critical to transforming food tracing is making data available in an electronic format.

“ For operations not currently using electronic databases or other electronic systems, who wish to continue using a paper-based system, the transfer of data to an electronic format should be required,” the report declares. “This transfer may be done through third parties, but would be required to be done regularly, such as daily, to be kept current.

Further the report says the ability to trace product should be part of a standard third party audit, so that the correct capture of the data elements specified can be determined. The appropriate identification of CTEs, and adherence to accurate internal tracing should also be assessed.

A final component of a more robust tracing system is training. “Guidance should be developed that details how CTEs should be identified, and provides definitions for terms such as “lot”,” the report says. “Educational product tracing compliance modules should be developed and all segments of the food industry and regulatory community should be trained in their use.”