Traces of Truth

by Dan Malovany
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Ever since last year’s spate of highly publicized recalls involving peanut paste and problems with pistachios, among other foods, food companies along with retailers, and food service chains and the government stepped it up a notch or two when it comes to food safety. They had to.

For Jennifer Robinson, a quality leader for Horizon Milling, an affiliate of Wayzata, Minn.-based Cargill Inc., such a renewed effort in the name of food safety has nearly buried her department under a barrage of paperwork. First, she was hit by the proliferation of supplier qualification manuals that her department needs to read and review because each has slightly different requirements depending on the customer. Then came a flurry of supplier qualifying surveys that often required much of the same information to be provided over and over again.

“Supplier qualification is consuming a tremendous amount of my time,” Ms. Robinson said. “I’m reviewing manuals, completing surveys and preparing responses. It’s redundant, and if we had some way to share information in a streamlined, consistent manner across the industry where you have a portal, populate it once and make it available for other people to use, that would be fantastic.”

Compounding the matter, an increasing number of companies now want to conduct their own audits in addition to third-party audits, noted Barbara Heidolph, principal, technical service, ICL Performance Products LP, St. Louis, Mo. However, many of these audits cover more than 90% of the same material, and in addition to taking up valuable time, the difference between many is often insignificant.

“If you talk to a lot of food manufacturers who deliver product directly to the consumer, when they look at their suppliers, they are not convinced that third-party audits will capture things that truly put them at risk in delivering a safe product to consumers,” Ms. Heidolph said.

During the past year, Ms. Heidolph, Ms. Robinson and a task force from AACC International have been exploring key food safety issues and how eliminating audit redundancy may free billions of dollars that could be spent in other ways to improve safety. Despite all of the additional resources being spent on food safety, they added, the industry is still not identifying all of the risks, and food safety incidences are still being missed.

Step by step
That doesn’t mean the food industry hasn’t taken major steps in recent years in the right direction when it comes to food safety. The Bioterrorism Act of 2002, for instance, requires food companies to take a “one step forward, one step back” approach that significantly improved food traceability across the board, said Judi Lazaro, director of customer relations for AIB International, Manhattan, Kan.

“The truth is that the industry is far better off today than it was five or 10 years ago,” she said. “The Bioterrorism Act of 2002 made a huge impact on the industry. What people took for granted before, they’re actually holding themselves accountable for now.”

Food traceability today is a lineal progression that is designed to create a chain of documentation throughout the food manufacturing and distribution process. Each facility gathers lot information from invoices, packing slips, purchase orders or other bills of lading from incoming ingredients, or the “one step back” of the traceability process. After tracking the use of those ingredients through the production process, the specific facility determines its own subsequent “lot” that is documented on the final product’s packaging, shipping records or other bills of lading, thus creating the “one step forward” in the process.

Overall, the basic elements are generic, but the definition of what constitutes a “lot” is specific to the manufacturing plant, said Al St. Cyr, head of food safety education at AIB International. “They are sort of like GMP guidelines,” he said. “You have to meet the needs of your individual facility. You’re the expert in your system.”

The lack of standardization, however, makes traceability an inexact science and the subject of much debate, said Gale Prince, a Cincinnati, Ohio-based consultant with more than 40 years of food safety experience. For a bakery, a lot may be a day’s production of bread and reflected on the packaging by a “sell by” date. Or it may be based on flour usage, the use of a specific ingredient or even sanitation schedules. For some companies, it may be as specific as a single product made during a 2-hour timeframe.

“The controlling factor is what do you want as an economic exposure?” Mr. Prince said. “Do you want to risk a week’s worth of products or can you precisely identify one day’s production, or in some cases, just four hours of production? The precise definition of a lot depends on an operation, and what the manufacture determines it to be. The smaller the lot number, the better it protects that company economically.”

Mr. Prince served as part of the Institute of Food Technologists committee that submitted a comprehensive report on traceability to the Food and Drug Administration (FDA) this past November. The report mentioned that significant variability in tracing complicates the issue. Specifically, it cited such factors as how data are collected, how the information is captured and how it is shared among companies. Depending on the company, data may be logged manually or traced electronically through a hodgepodge of internally created proprietary and generic over-the-counter programs.

“It can be as simple as an Excel spreadsheet,” Mr. Prince said. “With a little bit of recordkeeping and diligence, you can do a pretty good job. Maybe not 100%, but you can do more than 90% of a good job.”

For instance, The Long Co. is rolling out an in-house designed software program where every ingredient it provides its members is supported by five documents, including a material safety data sheet, a product specifications sheet, a kosher certificate, 100-g nutritional information and a bill of lading with lot numbers, shipping data and other information, said Al Bachman, director of quality, research and development for the Chicago, Ill.-based bakers cooperative. The information will be available to its members on its Web site.

Unfortunately, Mr. Prince said much of traceability, especially from lot numbers for incoming ingredients and outgoing final products, is done by hand. That makes it difficult to respond to a recall request from the FDA, which typically requires the information be delivered within 24 hours.

“In many cases, you’re talking about a complicated big stack of paper and problems with handwriting, and when you go to search for information, it’s almost an impossible task to gather all of that information if you have to do it manually, especially from the distribution side of the business,” he said.

From a historical perspective, Ms. Lazaro stressed, food companies are doing a much better job than in the past.
“It was not uncommon 10 years ago for someone to say, ‘If we had to recall, we would recall everything.’ That is not the norm anymore,” she said. “Today they are saying, ‘If we had to recall, we would recall this, this and this, but not this.’ I think the industry is going in the right direction.”

No farm to fork
Unlike other industries, Mr. Bachman said, bakers face several challenges that complicate the process of traceability. Many ingredients such as flour and oil, for instance, are made of a blend of crops from multiple farms. A batch of flour may come from hundreds of sources, which makes traceability back to the farm neither practical nor possible.

“To me, the two fallacies with the whole traceability issue are that the retailers and the farmers are exempt,” Mr. Bachman said. “How does it do anybody any good when you don’t know where the ingredients came from or how the product is being sold to the public? Everyone in the middle is taking care of it with one step forward and one step back, but you may be buying a yeast food with five components in it. You buy it from a supplier with a lot number, but I don’t know anything about where those five components came from originally or anything about them. So my traceability is really zero.”

AACC International addressed this issue in its comments to the FDA and the U.S. Department of Agriculture’s Food Safety Inspection Service earlier this year. It noted a lack of sufficient technical and experimental information is available to make definite statements about what can or cannot be accomplished in the traceback of cereal grains. Additionally, the group stated there must be a balance in the value created vs. the costs incurred by tracing grains from the farm level to final distribution points.

If there is an issue with flour, however, it may affect more than one company, Mr. Prince said. Fortunately, most baked products have the “kill” step where the heat from the oven or fryer eliminates many microbiological issues. Still, he added, that kill step doesn’t eliminate problems caused by ingredients adulterated by chemicals or foreign matter. Additionally, unbaked ingredients such as peanut butter or creme in sandwich cookies need to be carefully monitored for microbiological issues, he said.

Traceability has been brought up as part of the Food Safety Modernization Act before Congress. If the legislation isn’t passed, the FDA may move forward on a variety of food safety initiatives via the regulatory route, said Lee Sanders, senior vice-president, government relations and public affairs, American Bakers Association, Washington, D.C.

Ms. Sanders noted that ingredients such as sesame seeds that typically come from abroad may provide traceability challenges. Minor ingredients also may pose a problem, especially if they come from a distributor, Mr. Prince said. Often, such intermediate dealers don’t like to share the source of their ingredients for fear their customers may go directly to the source and eliminate the middle man for a cheaper price.

Know your sources
Traceability also has improved by the burgeoning Global Food Safety Initiative (GFSI), which is being pushed aggressively by major retailers and international food companies to establish more uniform food safety standards. Because mock recalls are part of the process, Mr. Prince said, such audits may gauge the effectiveness of a company’s food traceability program.

Although many companies see GFSI as step in the right direction for improved recordkeeping, Ms. Heidolph said, the worldwide initiative has only been in the U.S. for a little more than two years. She added that many food companies are still in the early stages of the certification process while others find themselves delayed because of the lack of qualified auditors. Additionally, GFSI is made up of multiple audits, including product certification and food safety management certification, and the number of audits included has continued to grow.

In many instances, Ms. Heidolph said, it’s not the audits that are a problem. Rather, it’s the quality and consistency of those conducting the audits.

“If we had our dream world, it would be to have an auditor equivalency program just like that of a CPA certification,” Ms. Heidolph said. “Do auditors make a difference? You bet.”

Ms. Robinson said the food industry also needs more collaboration when it comes to traceability and other food safety issues. As the altruistic mantra goes, eating safe food is a basic human right. This effort would be enhanced by food safety collaboration, she added. Programs such as traceability require companies to share information to be effective. At the same time, the food industry has developed a much-required culture of confidentiality designed to prevent proprietary information from getting into the hands of competitors.

“We’re looking at what’s the best audit at knowing whether my suppliers are meeting their requirements without me having to go there personally,” Ms. Robinson said. “We’ve seen customers going from ‘we’ll need this audit’ to ‘we’ll accept any audit’ to ‘I will have someone personally from our company visit your company to make sure that you’re delivering on your promise.’ It’s an emerging issue. Historically, companies focused mainly on what was happening within the four walls of their businesses. Today there is a much more outward focus.”

According to Mr. Prince, the bottom line is a matter of trust. During last year’s recall of peanut paste that was tainted with Salmonella, he said, many companies got burned because they relied on the Peanut Corporation of America and its documentation of its processes.

“You need to know who your suppliers are and what their programs are,” Mr. Prince noted. “I live by the motto, ‘know your supplier,’ but as in any industry, there are always a fraction of folks who shouldn’t be there. That’s why we have to do all of this testing and checking.”

The author is executive editor of Baking&Snack, a sister publication to This story originally appeared in the August 2010 issue of Baking&Snack.

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