National Editor Tom Karst The FDA has just announced the release of the IFT report on pilot projects on food traceability. In keeping with the epic size of the produce safety rule and the preventive control rule released earlier, the IFT report on product tracing pilots is 334 pages.
Of course, one of the questions about IFT pilot on produce tracing is what kind of judgment it will render on the existing Produce Traceability Initiative.
Trying to find the "gist" of a 334-page report is the challenge; a good place to start may be the recommendations.
Let's look at what the IFT says about its findings and conclusions:
IFT was successful in conducting mock tracebacks/ traceforwards, ranging from simple (e.g.tracing one shipment of tomatoes or one lot code of peanut butter) to complex (e.g.finding convergence when tomatoes were sourced from two different growers; finding a common lot of ingredient between different processed food products manufactured in different facilities). The process of conducting a step - wise product tracing investigation was complicated and often times confusing.
Inconsistencies in the terminology, numbering systems, formatting, legibility, and occasionally the language sometimes required IFT to contact the submitting firm to gain clarity, increasing the time required to capture data before any meaningful analysis could begin. However , the pilot participants appeared to have many of the tools and processes in place which are required to allow the capture and communication of critical track and trace information (i.e., Key Data Elements; KDEs) at critical points of product transfer and transformation (i.e., Critical
Tracking Events; CTEs).
IFT observed that firms provided product tracing data in several ways. Ultimately, the way in which data were readily accessed and transmitted to IFT was dependent on the systems and processes in place within a firm to capture, store, and report this information.
Upon completion of the task, IFT determined that costs associated with implementing a product tracing system can vary widely as determined by numerous factors: the size of the firm facility, the method of product tracing already in use (i.e., manual or electronic), and the range of each firm’s capabilities to implement or improve its product tracing system, to name a few. Nevertheless, IFT is confident that a product tracing system incorporating its recommendations would greatly benefit the FDA as well as other state and federal partners,the food industry, and consumers. The recommendations are as follows:
1. From an overarching perspective, IFT recommends that FDA establish a uniform set of recordkeeping requirements for all FDA-regulated foods and not permit exemptions to recordkeeping requirements based on risk classification.