Industry voices concerns about 'enhanced' traceability

by Jay Sjerven
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WASHINGTON — Randy Gordon, vice-president of the National Grain and Feed Association, recently urged officials of the Food and Drug Administration and the U.S. Department of Agriculture’s Food Safety and Inspection Service to consider the limitations of product traceability procedures for industries that handle large volumes of commingled commodities before the agencies establish additional requirements.

Mr. Gordon conveyed the grain industry’s concerns during a two-day public meeting on food and feed traceability convened by the F.D.A. and the F.S.I.S. in Washington, Dec. 9-10. The meeting drew representatives from federal agencies, food and feed manufacturers, retailers and consumer organizations. Its purpose was to hear views on how to improve product traceability systems, which is a priority of the Food Safety Working Group established by President Obama in March.

Mr. Gordon participated in a panel discussion on challenges in tracing animal feed, but his comments reflected problems confronting all manufacturers of grain-based foods.

“While the ability to effectively trace products — backwards and forwards — through the supply and distribution chain is an important component of an overall food/feed safety plan, scarce financial and human resources need to be allocated in a way that maximizes product safety,” Mr. Gordon said. “As F.D.A. and F.S.I.S. consider ‘enhanced’ product-tracing systems, their practicality and cost as well as the real value-add they bring to further enhancing food and feed safety, need to be critically analyzed.”

Mr. Gordon said a typical country grain elevator may originate grain from roughly 250 suppliers in truckload quantities of 900 bus or less, amounting to about 4,500 individual inbound shipments per year. Once commingled, stored and handled, outbound shipments from a country elevator may contain some grain from all of the facility’s suppliers, he noted. The volumes and number of potential sources of supply increase even further at the terminal and export elevator levels.

Mr. Gordon said a typical feed mill manufacturing 100,000 tons of feed annually might originate grain from 10 or more different country elevators and use more than 100 different feed ingredients. The mill might receive and ship more than 5,000 truck shipments in a year.

For each feed ingredient, the mill might have between 2 and 15 suppliers. For a finished feed containing grain and 10 other feed ingredients, there may be more than 12,000 different sources for the grain portion of the shipment alone, and more than 80 different immediate sources of feed ingredients contained in the finished feed, Mr. Gordon said.

Further, the 80 different immediate previous sources of the feed ingredients in the finished feed shipment represent only one step back in the supply chain and does not account for the multiple supply sources that each feed ingredient supplier may be using to manufacture ingredients shipped to the feed mill, Mr. Gordon added.

“These examples illustrate that outbound shipments from grain elevators, grain processors and feed mills typically consist of hundreds to thousands of potential sources,” Mr. Gordon asserted. “In tracing products, our industry can narrow the search based on timeframes of receipt and distribution. But complexities associated with tracing grain and feed products stored, handled and transported on a commingled basis — combined with the relatively low risk of these commodities to human or animal health — need to be considered carefully as F.D.A. evaluates any new ‘enhanced’ product-tracing requirements.”

Mr. Gordon also asked the F.D.A., as it considers additional product-tracing requirements, not to require segments of the grain, feed and processing industry to keep records in a specified electronic format, which he said would be “both technologically challenging and cost-prohibitive.” Mr. Gordon said current Bioterrorism Act recordkeeping regulations permitting paper records are adequate to facilitate a trace-back and trace-forward investigation of grain, feed and grain products.

He asked the F.D.A. to recognize that requiring the assignment of a lot code or number would have limited benefits for products stored and handled in an unpackaged, bulk form, as is the case with most grain and feed. And he asked the F.D.A., before it establishes new product traceability requirements, to consider first the impact of its new Reportable Food Registry, activated in September, on increasing the speed and accuracy of product tracing targeted specifically at products that facilities determine may pose a serious risk to human or animal health.

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