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Fight for Food Safety

Traceability: Keep your company from losing its way

By Shawn K. Stevens
November 15, 2011
It is difficult to overstate the importance of maintaining a system which maximizes effective and accurate food traceability. Certainly, failure can and has resulted in financial disaster and bankruptcy for even the largest of companies. Alternatively, having a system in place which ensures accurate traceability can make the difference between the continued success and the catastrophic end of any business.

In addition to new initiatives by USDA, the FDA has similarly recognized the importance of traceability, and focused much of the Food Safety Modernization Act’s changes on improving traceability in all foods, but especially produce. There is also the industry-led Produce Traceability Initiative, which has been developed to ensure that companies are maximizing the effectiveness of traceback procedures. It is also working to institute an industry-wide approach to bolster the efficiency of traceability systems across the produce industry.

We must ensure accurate traceability of food in order to safeguard public health. In the event of a foodborne illness outbreak, the capability to rapidly identify, isolate and establish control over any and all products that may pose a risk to the public is paramount. Effective traceability will minimize the amount of illnesses and by extension the severity of any outbreak. While the health of their customers is of course the primary concern of any company, the financial pitfalls associated with traceability failures can be enormous. This is especially true in the beef industry, where multiple raw materials from numerous upstream suppliers are comingled to produce ground beef products.

Without the ability to define the window in which potentially contaminated products may have been produced, FDA will — as it should — cast a net that is wide enough to ensure the capture of every possible product that poses any risk. USDA will likely soon follow suit. Lack of traceability can quickly balloon the universe of potentially affected products into devastating, even business-ending, proportions.

Because of numerous high-profile outbreaks and recalls, there has been a marked increase in the focus on traceability. The new rules coming into effect as a result of the FSMA’s passage have given rise to new technologies and software. In the short term, these new technologies will likely prove to be equally suitable for both FDA and USDA regulated products.

Take a look at your systems now, before a crisis arises. Doing so can ensure that when it comes to traceability, you (or your company) won’t get lost. 

KEYWORDS: FDA FSMA USDA

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Shawn Stevens is the founding member of Food Industry Counsel LLC, a law firm formed in 2014 to represent the food industry exclusively in regulatory and other matters involving food safety and quality. Contact Stevens at (920) 698-2561 or stevens@foodindustrycounsel.com, or visit his Web site, www.foodindustrycounsel.com.

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