March/April 2021 - 18

OPERATIONS
TRACEABIL ITY
Reducing the fear factor
EASING RECALL ANXIETY
STARTS WITH HAVING A PLAN
By Chuck Mead
Guest columnist
MANY GOOD HORROR STORIES
end with some version of " ...and
they disappeared without a trace. "
Coincidentally, disappearing without
a trace is a different kind of scary in
the produce industry. That is because
recalls in the U.S. are increasing at a
rate of approximately 10% annually.
This means there is real danger in
not having a plan for the traceability
of ingredients, which will help foster
an effective recall program, a crucial
component of food safety. A plan can
help keep consumers safe, strengthen
customer relationships and maintain
the reputation of the business.
Traceability is the ability to follow
(trace) an ingredient, packaging
material, processing aid or finished
product from harvest or receiving,
through production and to the first
delivery point away from the facility.
Recall is the ability to get that item or
material back or put it on hold until it
can be retrieved and or dispositioned.
Having a traceability and recall plan is
a necessity that supports the growing
complexity of the supply chain, better
detection of food safety issues, and
more efficient mandated reporting
by manufacturers and processors. It
is also a regulatory requirement in a
food safety plan and should include
management's strategy to take quick
and effective action when experiencing
a recall.
Importance of a traceability plan
Processors track their products
through all stages of harvest, packaging
of field-packed produce, production,
processing, distribution and retail. They
use recorded information to store and
18 MARCH/APR I L 2 021
share information about specific fields,
harvest crews, ingredients, packaging
and other raw materials. Even though a
facility or grower may have a traceability
program in place, the difficulty is often
in ensuring such a program is effective.
Employees may not understand the
reason for a traceability system,
mistakenly believing the procedures
are meticulous and burdensome, and
that the information is needed only
when a problem occurs.
An effective traceability plan should
define the team's actions through four
stages:
1. Identification: The ability to track
and trace a product through the
entire process and supply chain with
a lot or ID number;
2. Recording: This number is recorded
throughout the life of the product,
including each time it is received,
transferred, utilized as an ingredient
and as a finished product;
3. Establishing links: The lot numbers
are the thread that ties the food
material to all phases of its life, from
seed to store, butcher to barbeque,
plant to package; and,
4. Communication: Food processors
can then map the material through
the supply chain and use that
information to find it at any given
point in the process.
Define the recall plan
It is also a requirement to have
documented procedures and defined
responsibilities for carrying out a
recall due to the multi-faceted nature
of the process.
As a first step, it is important to
have an established HACCP, Food
Safety, Recall or Crisis Management
team that should include company
management, outside consultants
Chuck Mead
and legal representatives. It will be
their decision whether to initiate
either a market withdrawal or the
recall process. Though this differs
by country, in the U.S., the FDA shall
be notified in accordance with the
Reportable Food Registry program.
The FDA can force a recall if they feel
the processor is not acting in the best
interest of the public.
Notification to all entities that
may have product in their possession
is key to performing a successful
recall. Customer/contact lists must
be continually updated, so the right
personnel can be promptly notified.
Once quarantine of the product
has been communicated, obtain the
quantities of product in storage for each
individual consignee. Arrangements for
the return or verified destruction of
product should be completed in a timely
manner. The quantities of product will
be verified once again for reporting
to regulators, while also calculating
effectiveness of the recall.
Depending on the type of hazard
and class of recall, product may be
dispositioned. If the product were
contaminated with a pathogen or
undeclared al lergen, the l ikely
disposition would be destruction.
However, in some cases the product
could be reprocessed if the hazard could
be effectively removed and the product
March/April 2021

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