Take action to protect your business against the threat of a product recall by better understanding the fundamentals of an effective traceability system from Dean Hornsby of Redimark. This article was originally published in RCI's Kettle Talk magazine.
In 2018, a total of 382 food product recalls were registered
between the U.S. Food and Drug Administration (FDA), as well as the U.S.
Department of Agriculture Food Safety and Inspection Service (USDA FSIS). What
were the leading reasons for the recalls? Undeclared allergens accounted for 160
recall cases; milk, tree nuts, eggs, peanuts, soy and wheat representing the
largest offenders. (foodsafetymagazine.com)
If you produce confectionery products, you are most likely
sourcing ingredients from multiple suppliers that are derived from local and
even international sources. You rely on your suppliers to keep track of these
ingredients and provide the documentation for batch or lot identification. You
would expect your suppliers to notify you if they had a quality or safety
recall, but what about you? Would you know what products of yours would fall
under that same product recall?
THE IMPORTANCE OF TRACEABILITY
An effective product traceability system involves the use
of tracking and tracing systems and processes to record the movement of
incoming goods to outgoing product. Whatever system you use, it is important to
capture the data of incoming ingredients quickly and accurately. The packaged
products that you produce and ship need to be identified all the way back to
the batches of ingredients used.
- Once product is outside of your four walls, what now?
- Did you track where the product lot was shipped to?
- What about your customers or consumers?
- Would they be able to identify the offending batch of product?
This is the importance of product coding and
identification.
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Above: Key areas of consideration for a traceability system
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HOW TO TRACK PRODUCTS
Not only should your product traceability system capture
the data of incoming goods to outgoing shipments, it needs to index all
production activities to a unique batch lot number such as a kettle or oven
number, mixer, packaging line, etc. This primary-level batch lot number is the
license plate that travels with the product all the way to the customer and
consumer. If a supplier notifies you of an ingredient safety issue, your
traceability system should support a “where-used” function that allows you to
enter the secondary-level batch numbers of the ingredients used and all parent
level batch numbers should show as a result. The same holds true for the
production process activities. Should a metal mixing blade break, all batches
produced from the last inspection date of the mixing blade up until the new
inspection that found the failure must be identified.
CODING REQUIREMENTS
The primary-level batch code must be visible on your
product packaging. It should not be printed on parts of the packaging that can
be discarded such as a tear-away opening or throwaway cap. It should be printed
onto the permanent section of the packaging so that a consumer can locate the
code for identification. Printing of the batch code can be performed by many
different technologies. Inkjet coders offer the most flexible way to date and
batch code products by jetting the ink drops that form printed characters onto
the product as it travels down a product conveyor or through a flow wrapper.
Labels can be printed inline using a print-and-apply system, or offline in
batches that are hand-applied onto the product. Thermal Transfer Over printers
(TTO) print directly onto the film in the flow wrapping process—Label and TTO
technologies use wax ribbons for printing onto the label or plastic packaging
substrate.
More expensive coders, like lasers, can be used to vaporize
the package’s pre-printed ink surface to reveal contrasting date codes with the
natural packaging material color underneath.
FSMA’S IMPACT ON TRACEABILITY
The Food Safety Modernization Act
(FSMA) impacts small manufacturers (fewer than 500 full-time equivalent
employees) as of September 18, 2017 and very small businesses (less than
$1,000,000 in sales) on September 17, 2018.
The FSMA is a law that enforces preventative control
measures and enables the FDA to perform unscheduled inspections and force
product recalls instead of issuing voluntary recalls. The law can even allow
the FDA to force closure of production operations should improper preventative
control measures be found regarding food safety.
An effective product traceability system delivers what your
business needs to protect brand image, provide consumer trust, and meet your
product quality and safety goals.
LEARN MORE ABOUT TRACEABILITY Register
now to join RCI for Regional Conference in Nashville August 19-21, 2019. Dr.
Bob Strong, with SAI Global Assurance, will lead education on the importance of
traceability. Understand traceability and requirements for businesses of all sizes,
as well as consequences facing both your business and public health, if not
done properly. Register
today!
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