Traditional quality programs need to be taken to the next level of data granularity by performing item-level tracking and creating item-level, ingredient pedigrees for each finished goods that can be compared with the downstream, real-world outcomes that evaluate each finished good shipment across key consumer parameters.
“Quality managers should not be afraid to require upstream suppliers to use item-level tracking systems to capture the raw material and ingredient attributes at the item-level, because adopting this innovation will benefit the upstream supplier,” according to William R. Pape is founder and executive vice president of TraceGains.
Backlash from small-scale independent farmers has been one of the key factors slowing efforts to create an effective and efficient national food traceability system. The family farm has been a potent political force. Several vocal groups have leaned on elected representatives to oppose national traceability efforts as well as authored hundreds of Web sites, blogs and opinion columns to rally support against the National Animal Identification System (NAIS) and proposals to track fruits and vegetables.
One example of this anti-traceability effort came from the Farm-to-Consumer Legal Defense Fund regarding a lawsuit filed to block livestock traceability. The organization argued that, “Existing programs for diseases … together with state laws on branding and the existing record keeping by sales barns and livestock shows, provide the mechanisms needed for tracking any disease outbreak.” Similar arguments are offered to suggest that new fruit and vegetable traceability systems are unnecessary.
It is worthwhile to examine whether the existing systems provide the necessary tools for efficient and effective traceability as well as whether a national traceability system is really as threatening to the family farm as these detractors suggest.
Data from the recent Salmonella incident suggest that the most credible threat to the family farm may come from not having a national traceability system in place. The investigation, which first prevented off-farm shipment of certain tomato varieties from June 3 to July 17, and quarantined certain pepper varieties; the Wall Street Journal report this single event caused at least $250 million in damages to date.
“Not being able to ship highly perishable product for six weeks or more during the height of the growing season is more likely to negatively affect the small, independent farmer than the major grower, who has much deeper pockets. As a multi-generational farmer and current family farm owner, I know that few in the supply chain have shallower pockets than the independent, small-scale farmer,” argues Pape. A more efficient, electronic national traceability system could have sped up the process and substantially reduced the negative impact on the tomato and pepper supply chain.
To understand how a more effective traceability system a better understanding of the investigation process is required. Investigators begin with a rigorous food history from each victim, hoping to find evidence of a disease agent in the victim’s refrigerator or at a restaurant they frequented. If outbreak investigators cannot find a causal agent product at a victim’s home or eating place, they look to identify common food patterns from all victims. Because there was no hard evidence found in the current Salmonella Saintpaul investigation, investigators had to fall-back on this circumstantial pattern-matching, and tomatoes became the prime suspect.
While an improved electronic traceability system could not help take the food histories from victims, it would have helped discover and locate points in the supply chain common to all victims. When investigators found that eating fresh tomatoes was common to most victims, an effective national electronic traceability system would have allowed the health officials to rapidly dispatch testers to common upstream supply chain points to see if the disease agent could be found.
Limiting the possible contamination sources, by ruling out common points via negative test results, would have sped up the investigation and allowed for testing many more hypotheses. Unfortunately, the current traceability system does not allow this type of rapid hypothesis testing.
The Quarantine Dragnet
TraceGain’s Pape noted, “In the absence of clear information quickly pointing to a common contamination source, state and federal authorities really had no option but to quarantine an entire product and product variety category. All growers of these products, large or small, were caught in the quarantine net because officials didn’t — and still don’t — definitively know the source of the outbreak. Everyone was and is suspect until the supply chain tree is defined and tested.”
We have the needed traceability technology tools
Every food and beverage company in the United States, with few exceptions, must now keep one-up and one-down records about where they receive food, how specific incoming received shipments are connected to specific finished goods, and to whom the finished goods were shipped. “Even though these new FDA rules have the weight of law and stiff penalties for owners, directors and executive as well as the companies themselves, our traceability audits have yet to find a single company that can meet 100% of these new requirements,” commented Pape.
Exacerbating the problem is that current data are typically stored on handwritten documents that take hours to find and days or longer to review. A recent study of more than six hundred companies concluded that while the best-of-breed organizations believe they can comply and respond to a traceability recall in thirty-six minutes, the bottom half take an average of forty-five hours. The bottom quartile can take weeks to conduct an effective a recall. Given that each recall involves many companies in a supply chain, it is not surprising that recent national food safety investigations have taken so long and been so inconclusive.
The Cost of No Electronic Traceability
When no efficient and effective electronic traceability system exists to quickly test different epidemiological hypotheses about the origin of the illness, it takes a long time to rule out a prime suspect food product as well as specific supply chain members within that product’s supply chain. The result is that the entire product category is quarantined, affecting every stakeholder (manufacturer, distributor, packer, and grower — large or small). The stakeholder member most financially at risk and suffers most is the family farmer. Pape insists that, “The best way to protect the family farm is to create a national electronic traceability system with appropriate safeguards that can quickly zero in on the appropriate product and the specific location(s) involved in the outbreak so that the quarantine is measured in hours or days, not weeks or months.”
While improving the “common good” is important in electronic food traceability, there is actually an enlightened self-interest for the family farmer. By supporting national traceability, family farmers are voting to speed up national recall investigations so that markets can be quickly reopened. A national traceability system with a privacy-friendly architecture can go a very long way to protecting the family farm, and family farmers should be using their political clout to advance its design and implementation.
| Author Biography: |
Thomas R. Cutler is the President & CEO of Fort Lauderdale, Florida-based, TR Cutler, Inc.www.trcutlerinc.com
Cutler is the founder of the Manufacturing Media Consortium of three thousand journalists and editors writing about trends in manufacturing. Cutler is a member of the Society of Professional Journalists, Online News Association, American Society of Business Publication Editors and Committee of Concerned Journalists, as well as author of more than 300 feature articles annually regarding the manufacturing sector. Cutler can be contacted at trcutler@trcutlerinc.com |
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