25 replies to this topic

[doobey]

What is your practical solution to the traceability challenge?

Hello Colleagues, I would like to share ideas on traceability methods and systems, more like a mini survey to identify best practice, learn and hopefully improve our systems.

What country are you located?
What are the laws on traceability in your country?
Do you use a specific traceability guideline?
What are your customer’s expectations and standards for recall and withdrawal?
What is your product and process?
What is your traceability system?
Do you use traceability software, other IT system or a manual system?
Is your company registered to any Standard e.g. BRC / HACCP / ISO 22000?
How well does your system work?

Cheers,
Doobey

Edited by doobey, 01 July 2008 - 10:25 AM.

[Simon]

Interesting topic Doobey, hopefully members will share their systems with you.

In the meantime I found this PDF primer article here: Food Traceability

Regards,
Simon

[Cathy]

In the U.S. it is expected that you can trace everything at least one step forward and one step back. "Expected" isn't the same as mandatory. We aren't at the point yet. Companies use a variety of methods. It would be nice to see more continuity between systems and food types. Most customers expect you to be able to complete a trace of any type within 2 hours. For example, take a finished product and trace back to what it was made of, or take a raw material and trace everywhere it went. My experience is from the meat and poultry processsing industry.

[Simon]

I believe in the EU the applicable legislation is (EC) 178/2002. Please can someone confirm.

I think you might find this useful:

Guidance Notes for Food Business Operators on Food Safety, Traceability, Product Withdrawal and Recall - A guide to compliance with Articles 14, 16, 18 and 19 of General Food Law Regulation (EC) 178/2002.

And relevant FSA website: General Food Law.

Regards,
Simon

[doobey]

Thank you for your input Cathy. The same requirements are found here in the UK, well in my experience anyhow. 1 step forward and 1 step back and my customers expect me to be able to reconcile everything within 2 hours. We are a small ready meals business. Also thanks to Simon for the brilliant document, I had not come across it before, I shall read it over the weekend, depending on the weather, which is looking good right now.

Cheers for now,
D

[GMO]

To your supplier and to your customer is all you can control, however, it doesn't stop a recall (see Sudan / worcestershire sauce recall).

Most factories I know still use paper. I thought it might be helpful for you to know some of the problems I have had with paper traceability systems:

Missing 1 vital piece of paper which stops the trace
Illegible writing
Cultural writing differences, e.g. a Polish 7 can look like a 4
Fabrication - some people will cut corners if they can unfortunately so paperwork completed in advance, or after the event

I've not had as much experience with electronic systems, at least not systems which also had a paperwork element but in the two factories I've seen, the problems have been:

Forgetting to scan (with barcode systems)
Descriptions of the ingredients on scanners being too vague so they don't know which one to pick
Lack of accountability; who did the scanning or the electronic paperwork?
Once something is electronic, people don't question it, they assume it's right

I've had recalls because both electronic and paperwork systems failed. I think which is best is more to do with discipline and close supervision at implementation stage than whether a system is good or not. Obviously you try and minimise the risk but as I said earlier, if there is a short cut, some people will find it.

[Charles.C]

Dear Simon,

Very interesting links indeed. I noticed these items in the first/second links respectively –

Nor is there any requirement for records to be kept identifying how batches are split and combined within a business to create particular products or new batches. For example, a cake manufacturer would not need to specify which batch of flour went into which cakes. However, internal traceability may be required by commodity specific legislation, for example beef labelling.

It is common practice among some EU food business operators to request trading partners to meet the traceability requirements and even beyond the “one step back-one step forward” principle. However, it should be noted that such requests are part of the food business’s contractual arrangements and not of requirements established by the Regulation.

The “even beyond” in second chunk is an almost ubiquitous request by importers IMEX, usually justified by statements like “due to EU regulations”.
I also believe that standards like BRC usually expect substantially more than 1+1, particularly in the forward part of “mock recall” presentations. This can become quite problematic where exports are involved.

Nonetheless, from a purely safety / risk aspect, I personally find the official non-requirement extremely surprising given the general overwhelming support for use of HACCP based systems. In addition, I think these days most manufacturers choose to implement internal traceability as far as possible since the potential downside is even more scary.

Rgds / Charles.C

[a_andhika]

Dear Doobey,

Interesting topic. In my country, there is no mandatory regulation that manage the traceability and withdrawal procedures. The goverment only gives ultimatum to companies to withdrawn their products when the National Agency of Food and Drugs Control found nonconformities, but they dont direct how the withdrawal procedures should be.

As for the traceability and withdrawal procedures, every company has it own ways, depend on system that they use. Mostly, in here we are still counting system from ISO 9001 and ISO 22k. As for myself, I am adapting the ISO 22k system. We have two kind of treacebility:
1. Tracing: we trace where a non conformance Raw Material goes to (WIP or products), this part is harder, because we have so many kind of WIP and products.
2. Tracking: we track a non conformance FG from customer. From it batch number, we can track every Raw Material and their batch number, so we can define what material or process that has nonconformance. This is easier, because we are focusing only to one products. But if the non conformance material goes to many products, thats what I call troublesome...
However, when a Star Yum! auditor came visit us last May, somehow we manage to clear them in two hours, manually... Its quite annoying...

For the withdrawn procedure, I hate when we have to do simulation if a non conformity products went to the distributor. Because we have to found every single customer that demanding products from our distributor. Its a big pain in the a**.

Regards,


Arya

[Simon]

In my opinion full and fast traceability can only be achieved with computerisation. I'm not saying it's not possible with manual systems, but it's not as fast and is rather labour intensive not just on the information gathering when something goes wrong, but more creating the traceability trail in the first place.

Also computers / barcoding can still have accountability as there is a link to who is logged on to the computer or scanner at the time of the activity. It also creates records that are always legible, safely stored and retrievable. When you are relying on people to record data or pick the right product by reading a code they will make mistakes from time time, no matter how diligent, well trained or experienced (hang over, tired, worries, losing the plot – whatever). At lease with scanning this takes out human error, albeit they still can miss scanning things altogether, but there are ways to minimise this also.

Regards,
Simon

[YongYM]

Dear Simon:

Yes, I totally agreed with you.


Yong

[AS NUR]

computer traceability sample in my previous company using SAP.. That can trace up stream or down stream method

[a_andhika]

Dear Forum,

Yes I agree that computer is much better than manual in order to record. But how so ever, I dont think manual system can be totally diminished even when you are applying computer system. The input for computer still coming from manual right? On the other hand, I guess no company will ever take a chance in global competition without computer. Mine too, even the computer portion for traceability still relatively low on us. But I dont think its a big deal, as long as we record all the traceability needs neatly. I've seen few company that still using manual record but certified with ISO 9001 or 22k.

I've heard an interesting story from an auditor, it happen when she audit the traceability system of a company that proudly say can accomplish the tracing procedure within one hour by using computer. Instead of succeeded within one hour (probably when simulate it, they able to do less than that), they have to took more than three hours! And its all just because one link is missing! Sorry, but fully computer system is not a guarrantee in my opinion. System only works well when the executor (read:man) works well..

Regards,


Arya

[Cathy]

I agree - any system can fall apart due to a missing detail. I've seen SAP systems and ROSS work well but if people miss something, it can fall apart and increase the size of a recall rapidly.

One couple of things to note

This isn't just food safety and HACCP. Being able to trace is an important part of Food Defense as well. Food Defense audits include tracing requirements now.

Split batches happen often in production. One portion goes one way, and another portion heads elsewhere. The trouble I've seen is when your incoming material is actually part of a split batch as well. It's important to understand your supplier's code or lotting systems as well as your own.

Finally - don't forget rework. In some industries this is a huge issue. If you carry over part of a batch into the next day's production - both days are impacted by any problem that may occur. If that chain of carrying over is not broken routinely you can have a long period of product implicated by a food safety concern unless you can prove otherwise.

[Simon]

I've heard an interesting story from an auditor, it happen when she audit the traceability system of a company that proudly say can accomplish the tracing procedure within one hour by using computer. Instead of succeeded within one hour (probably when simulate it, they able to do less than that), they have to took more than three hours! And its all just because one link is missing! Sorry, but fully computer system is not a guarrantee in my opinion. System only works well when the executor (read:man) works well..

I understand what you are saying Arya, but given the choice of a manual system and a computerised system I would always choose computerised. But. I would sure as heck make sure that the expensive computer system could not be spoiled by a human error.

I agree - any system can fall apart due to a missing detail. I've seen SAP systems and ROSS work well but if people miss something, it can fall apart and increase the size of a recall rapidly.

One couple of things to note

This isn't just food safety and HACCP. Being able to trace is an important part of Food Defense as well. Food Defense audits include tracing requirements now.

Split batches happen often in production. One portion goes one way, and another portion heads elsewhere. The trouble I've seen is when your incoming material is actually part of a split batch as well. It's important to understand your supplier's code or lotting systems as well as your own.

Finally - don't forget rework. In some industries this is a huge issue. If you carry over part of a batch into the next day's production - both days are impacted by any problem that may occur. If that chain of carrying over is not broken routinely you can have a long period of product implicated by a food safety concern unless you can prove otherwise.

One thing is for sure, having a robust traceability system is in everyone's best interest.

Thank you all for your input.

Regards,
Simon

[okido]

Hi Simon,

It is more than common practice in the EU actually, it is the law that operators in the food chain can trace “one step back-one step forward”.
The guideline for one step in the chain is traceability within 4 hours.
The detail in which you want to trace is a matter of economical risk or customer demand.
A poor tracing system could lead to large unnecessary recalls or blocked products by the local authority.
There is a duty to report major calamities to the local authority.

Have a nice day, Okido

[GMO]

Also computers / barcoding can still have accountability as there is a link to who is logged on to the computer or scanner at the time of the activity.

Don't be so sure... I am currently trying to implement a paperless system and we were talking about log ins. I innocently asked a question of "does the system record the log in with the data?" and they said "no". It comes down to people designing IT systems who don't understand what is required from a quality system.

Also I have used SAP extensively along with other systems using scanning. It is honestly very difficult to make sure that an operator does what they should. Mistakes I saw included; scanning too much packaging to a line (making you look like you'd overused by 300% and leaving you with a part pallet which the system says isn't there), scanning of ingredients to the wrong line, logging in as eachother etc.

All of the above are solvable but we ended up employing someone to solve the issues. It was a full time job initially!

Also, and this will make you laugh, remember a pallet label is a label; it does not necessarily represent a pallet! I once had an issue with some pallets made and our records said we'd made 20 at a certain time. What I didn't know is pallet labels were being preprinted by the staff and so the pallets I'd put on hold were actually labels in a drawer! If an operator faked paperwork, they'd know they were doing something wrong and potentially illegal, preprinting labels will only ever be found out when you have an issue (unless you happen to check first.) The problem with computer based traces is it requires people to understand a process which initially probably seems esoteric.

[Simon]

Don't be so sure... I am currently trying to implement a paperless system and we were talking about log ins. I innocently asked a question of "does the system record the log in with the data?" and they said "no". It comes down to people designing IT systems who don't understand what is required from a quality system.

You're right about IT people and Quality Systems. However, I have had the opposite experience. Shop floor systems are normally bespoke so should allow for traceability of log ins. If the QA person is involved.

Also I have used SAP extensively along with other systems using scanning. It is honestly very difficult to make sure that an operator does what they should. Mistakes I saw included; scanning too much packaging to a line (making you look like you'd overused by 300% and leaving you with a part pallet which the system says isn't there), scanning of ingredients to the wrong line, logging in as each other etc.

I'm not doubting you suffered these and I can see it, again however, a lot of this can be designed out. Production can be split into smaller work units on the system so that only material issue to that work group can only be used by that work group and stuff like that. Computer says no! And logging in as each other well if something goes wrong then that's a disciplinary matter. Over issuing could be a problem, but I'm sure could be controlled in a well designed system.

All of the above are solvable but we ended up employing someone to solve the issues. It was a full time job initially!

Totally agree here. In a past implementation the company thought they would be able to reduce staff, in actual fact the new system needed much more information and more admin work. The information was great though.

Also, and this will make you laugh, remember a pallet label is a label; it does not necessarily represent a pallet! I once had an issue with some pallets made and our records said we'd made 20 at a certain time. What I didn't know is pallet labels were being preprinted by the staff and so the pallets I'd put on hold were actually labels in a drawer! If an operator faked paperwork, they'd know they were doing something wrong and potentially illegal, preprinting labels will only ever be found out when you have an issue (unless you happen to check first.) The problem with computer based traces is it requires people to understand a process which initially probably seems esoteric.

Don't you just love people.

Everything is possible good and bad, as the old computer addage goes "Garbage in Garbage Out" - GIGO. If well designed and managed and with excellent training and support a computer system can streamline the process and reduce the opportunities for human error. Or on the other hand it can be crap.

Regards,
Simon

[GMO]

Don't you just love people.

Everything is possible good and bad, as the old computer addage goes "Garbage in Garbage Out" - GIGO. If well designed and managed and with excellent training and support a computer system can streamline the process and reduce the opportunities for human error. Or on the other hand it can be crap.

Regards,
Simon

Oh yes, I agree. The problem is with computerised systems is people don't necessarily realise that faking the system is as bad as faking paperwork because they don't sign their name. It's a constant battle to make people realise that.

I used to work in production and my manager openly admitted that when they had a KPI on line code reliability where overproduction penalised you as much as underproduction (on a shelf stable product) he would not print out pallet labels for the overproduced pallets until the next process order was live. What he didn't realise is the traceability on when that product was made was linked to the time the pallet label was printed so if there was an issue at 5pm; the QA people putting the pallets on hold didn't realise the pallets 'made' at 10pm were also affected. In fact, no-one realised it was an issue at all until I worked in both production and QA. The problem is with computer systems is it can give you a false sense of security and it might look like it's working and it's difficult to prove it's really not unless you are very suspicious, very knowledgable about the system or get them to admit it! Before I realised the issue, people would be looking at a computer screen saying "the issue started at 8:30 so the pallet at 8:27 should be fine" not realising their control wasn't that good (and for that matter, whether the clocks were all working to exactly the same time!)

So my message is; be cautious, be suspicious, look for unusual patterns (e.g. 5 pallets produced in 5 mins then breaks) and work in production for a bit if you can (but then that applies to all quality systems lol!)

[Charles.C]

Dear All,

As an extension of GMO’s labelling comment, I can insert one more “economic” spanner into this discussion.
I agree unconditionally that proper traceability is the way to go. However one additional aspect is that for an exporter the depth of sampling at final customs reception in some countries is related to number of codes in a container. Up to a point this is statistically defendable but the practical result is that, depending on the case, it can sadly incur a small fortune both in money and delay time. This can encourage imaginative labelling techniques for the gambling inclined.

Rgds / Charles.C

[AS NUR]

dear all..

in my opinion.. to have a good traceability we must have :

1. Integrated people who always follow the rule..

2. Good system both of computerized or not.. that give more objective data..

3. good training to maintenance the capability of people.

so.. what the other opinion?...

[Simon]

So my message is; be cautious, be suspicious, look for unusual patterns (e.g. 5 pallets produced in 5 mins then breaks) and work in production for a bit if you can (but then that applies to all quality systems lol!)

Good advice GMO, I respect your real life experience, I can be too theoretical sometimes. Although I do have some practical experience.

Monitoring unusual activity and actual V's exepcted results is vitally important.

Regards,
Simon

[Simon]

Any more comments on this?

[a_andhika]

Dear Simon,

Yes I think monitor the unusual activities and verification is important for the traceability. Sometimes we enjoy our "comfort" zone too much, and didnt realize (or even didnt want to know), that somewhere outhere... in other zone, the procedures is not going with well. And the impact will came to us just like a snowball comes from the hill, firstly it was a piece of cake... then suddenly become gigantic and hit us badly!

And I am absolutely agreed with GMO. Even a sophisticate computer programme needs an audit, not only the person and the system. And once again, its proved that human (especially a curious one like you), is better than a computer:) No matter it was manually or automatically, IMO the executor still playing the bigger scene.


Regards,


Arya

[Simon]

Yes I think monitor the unusual activities and verification is important for the traceability. Sometimes we enjoy our "comfort" zone too much, and didnt realize (or even didnt want to know), that somewhere outhere... in other zone, the procedures is not going with well. And the impact will came to us just like a snowball comes from the hill, firstly it was a piece of cake... then suddenly become gigantic and hit us badly!

And I am absolutely agreed with GMO. Even a sophisticate computer programme needs an audit, not only the person and the system. And once again, its proved that human (especially a curious one like you), is better than a computer:) No matter it was manually or automatically, IMO the executor still playing the bigger scene.

Computer systems allow for much easier data collection and reporting and the smart people can then look for the unusual patterns and problems and opportunities for improvements. A fool would rely solely on the computer and the people using it. It's not lack of trust just good due diligence.

Arya when you say “curious people like you” do you mean curious inquisitive or curious strange?

Regards,
Simon

[AS NUR]

sometimes.. wehave to do some trial (mock up Recall) to test our traceability system... and i Think that correlate with withdrawl system..