Food Safety: Product Traceability Plans

Food Safety: Product Traceability Plans

As the recent horsemeat scandal in Europe illustrates, the supply chain for processed foods is a complicated global endeavor. It also focuses our attention on the need for transparent food traceability—the ability to know where meat, vegetables, or any food product started and ended its journey to your plate.

In this country, the Food and Drug Administration is in the process of implementing the 2011 FDA Food Safety Modernization Act (FSMA). One component of that law will require producers of high-risk foods to implement the means to trace food products both forward to the consumer and back to the grower in the event of a discovered contamination or recall.

The FDA has not yet issued rules for high-risk food tracing but is in the process of gathering data and soliciting public comment. A published report (PDF) on food tracing pilot projects initiated by the FDA and USDA included recommendations that the FDA should consider developing standardized electronic mechanisms and a technology platform for collecting product data. In addition, the report endorsed:

  • Requiring each member of the food processing chain to develop, document, and exercise a product tracing plan;
  • Setting uniform recordkeeping requirements for all regulated foods and not permitting exceptions based on risk classification; and
  • Requiring food companies to identify and maintain Critical Tracking Events (CTEs)—critical points of product transfer and transformation—and Key Data Elements (KDEs)—the capture and communication of critical track and trace information.

Woodard & Curran will monitor developments as the FSMA requirements evolve.


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