Fresh Produce Discussion Blog

Created by The Packer's National Editor Tom Karst

Monday, September 22, 2008

FDA: international efforts in traceability and what some want in the U.S.

From the FDA notice of the upcoming traceability meetings, more notes on developmenets in oter countries and what some stakeholders are suggesting for the U.S.

G. International Product Tracing Systems Some countries have mandatory product tracing systems in place in various forms, although these systems are more prevalent with respect to animal identification than for food in general. The European Union (EU), in addition to having a mandatory product tracing system for animals, also requires a product tracing system for all food and feed businesses. Specifically, the EU requires all food and feed to be traceable "one step forward and one step back" in EU member states. Food and feed business operators must be able to document where a particular food or feed product came from and where it is going next. Specifically, they must be able to document the names and addresses of suppliers and customers, as well as the nature of the product and date of delivery. They are also encouraged to keep information on the volume and quantity of a product; the batch number, if one exists; and a more detailed description of the product, such as whether it is fresh or processed. Food and feed business operators must also have systems and procedures that allow them to provide this information to the competent authorities on demand. In addition to these general requirements, sector-specific requirements apply to certain categories of food products (fruit and vegetables, beef, fish, honey, olive oil) (Refs. 17 through 20). In 2007, the ED began a 4-year study to develop, test, and evaluate two full pilot product tracing systems-one for the tomato food chain and the other for the feed/dairy chain (Ref. 21). In 2006, Codex established principles for tracing food through production and distribution processes (Ref. 2). The Codex principles are intended to assist government authorities in utilizing product tracing as a tool within their food inspection and certification system. Certain private international standard setting organizations have also developed principles and other guidelines on product tracing systems for use by industry. For example, in 2007 the International Standards Organization (ISO) issued ISO 22005:2007, which provides general principles and basic requirements for designing and implementing a product tracing system along a food processor's supply chain.3 Another example is the GS1 Global Traceability Standard (Ref. 22), which is being used by the PMA, CPMA, UFPA, and other associations involved in the PTI.
H. Actions Suggested by Stakeholders
Some consumer advocacy groups have asked us to develop and implement emergency regulations that would require source tracing for produce (farm-totable); written food safety plans for farmers, processors, and packinghouses; and tighter controls on repacking (Ref. 23). Some industry trade associations have asked FDA and CDC to convene a meeting with industry representatives 3 ISO 22005:2007. "Traceability in the feed and food chain-General principles and basic requirements for system design and implementation." July 2007. Available for purchase at, http://webstore.ansi.org. and work together to minimize the human and economic impact of an outbreak (Ref. 24). These trade associations urged FDA and CDC to work in partnership with industry to find solutions to speed up and streamline outbreak identification and response. These trade associations also recommended that a working group be established to look at crisis management systems and that teams of industry experts be established to help in traceback investigations.

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