As countries all over the world are pushing for stricter regulations on food products and food systems are becoming increasingly globalized, a noticeable trend has come to the forefront of new criteria for auditing. As many in the industry have noticed, food safety auditors are asking facilities to perform progressively more demanding traceability drills. While this can be frightening for some (particularly members of your recall team), for others it marks a new milestone of progress in our collective food safety efforts.
A few short years ago, most facilities counted themselves proud to complete a mock recall with a single ingredient traced “one forward, one back.” For many, this may still be the case; especially when some or all of your paperwork is done by hand, having a workable traceability system can feel like a massive effort. Yet the latest trend developing and already evident in many audits (your GFSI schemes, for example) is a directive for auditors to ask for more – perhaps to see all of the ingredients in a product traced and mass balanced, perhaps with packaging included, perhaps with verified COAs included in the trace packet. The “perhaps” is what worries us – it can be tricky to anticipate the expectations of your auditor, which is daunting in itself, let alone with a timed exercise. If your first trace drill of this magnitude is under these conditions, it can lead to major frustrations and even failed audits. If your company has sophisticated inventory systems and properly managed records, you may not need to worry. You may have even been coached on these expectations already.
On the other hand, members of a small, paperwork-driven facility, or even a larger company that hasn’t properly prepared, can have a more difficult time. This does not mean that compliance is impossible, or that it is any less important to have the capability to trace everything you make, completely and efficiently. Recalls are an uncomfortable and ubiquitous fact of the industry at present (and will be until we become more adept at prevention rather than reaction, but that is a topic for another time), and the best way we have to recover food we know to be unfit for consumption is to solidify our trace systems. Thus, most audits and regulatory agencies have given this a top priority when updating codes, criteria, and inspection directives.
I believe the expectations of the future will be even more stringent: faster results, more hypotheticals and obstacles posed to your team, more proof required, and information beyond “one forward, one back” – auditors will want to see that you can call up your distribution center or customer and ensure that your shipping records match what they have received. In fact, many audit schemes are already asking for this to be included in your annual mock recall. How do you prepare for this eventuality and gain peace of mind that your supply chain records are in tip-top shape?
Answer: you must challenge your capabilities. Some ways you can start making strides today:
Conduct extra exercises, as many as you need to feel comfortable in your abilities. Whether or not it is required by your customers, perform off-hours drills and include hypotheticals to plan for extenuating circumstances (maybe you have had a natural disaster and your inventory systems aren’t working – would you still be able to perform your drill?). Some facilities choose to link their mock recall with their crisis management drill, a choice with its own pros and cons.
Cross train your co-workers to ensure a wide network of individuals can perform the trace to your standards, as well as understanding their roles in verification and validation of your recordkeeping systems.
Back up your receiving, storage, usage, and shipping records to multiple (secure) locations, whether this involves storing files on separate servers or using a combination of electronic and paperwork records.
Work with your purchasing team to ensure that supplier monitoring is a constant priority. Being lax on suppliers is a mistake that companies often make not only for financial reasons, but also because we want to think that the inherent risks are lesser than they are. We also tend to assume any potential risks fall back on our suppliers more than ourselves – not true. Make sure that all of your supplier contact information is up to date, and ask to audit their facilities and their own trace exercises where possible.
Work to secure certificates of analysis for every lot where possible and perform your own testing as needed for your process. This assures that you have taken charge of the food safety of your own products. It can also help you avoid needing to perform a recall at all.
Review your process and identify potential recordkeeping pitfalls. For example, blending together multiple batches of ingredients, especially in a tank that is not often emptied, can make it extremely difficult to trace these lots effectively, and may lead to contamination of good lots with bad. Think about options available to reduce your risk, whether you can empty and clean equipment more often, use more precise measurements or better trained personnel when recording quantities, or add a control step after your product exits the holding vessel. This will vary greatly by product, but never assume you have explored all the options until comfortable with your process. In the same fashion that expectations are evolving, so too are the fields of food safety and technology. While many companies may not approve buying elaborate new equipment any more than implementing electronic inventory systems due to cost restraints, there is always a viable solution, and it needn’t be costly.
Use your resources from industry colleagues and college extension programs to publications and message boards to seek new ideas.
Important to remember is the end goal, whether you are a manufacturer, farmer, broker, or regulatory inspector. We need to look beyond passing an audit or inspection, conceiving into existence a world of safe, reliable nutrition for ourselves and our families.