Traceability of Food is Essential to Safety
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By Fred PritzkerA recent collaboration involving the Institute of Food Technologists and the U.S. Food and Drug Administration (FDA) is intended to improve product tracing in food production and distribution.
The study, released in October 2009 and entitled Traceability (Product Tracing) in Food Systems, identified key data elements, use of electronic forms and standardized formats as a means to identify and track food products implicated in outbreaks of E. coli O157:H7 in foodborne illness outbreaks.
Traceability is an essential component of food safety regulation. Simply put, it is essential that every food’s supply chain from farm to retail store or foodservice outlet be known, recorded and easily accessed. This would allow for rapid detection of foodborne illness outbreaks, removal of adulterated products from the marketplace, consumer warnings and identification of wrongdoers in product liability claims brought on behalf of foodborne illness survivors.
Unfortunately, the system of traceability in this country is fragmented and incomplete. For example, there is no standardized system for the identification and recording of key data elements (e.g. physical location at which the product was handled, lot numbers, amount of product manufactured or shipped, recipients of shipped products, etc.). Nor are there record-keeping requirements for Critical Tracking Events (CTEs) – instances in which a product is moved between premises, is transformed or is otherwise determined to be a point at which data capture is necessary to trace the product.
These deficiencies are well known and long-standing. They endanger consumers and make it difficult to hold wrongdoers accountable for the harms and losses they cause. As food safety lawyers, we at Pritzker Olsen Attorneys are involved in virtually every major outbreak of foodborne illness. We believe the common sense recommendations in this report should be implemented without further delay.
