[Tracking Systems] Global Traceability

Trace-back systems are becoming more common in the industry, with a certain level required by the Bioterrorism Act. But there is still a great deal of variability from one to the next — in how lots are determined and identified, what electronic system is used — if indeed the upgrade has been made from paper tracking, and whether a system can integrate with that used by a company’s customer or supplier — one forward, one back. It is enough of a challenge on a domestic level, but when supplies are taken to the global level the matter becomes that much more complex.

The challenges of tracking and traceability have continued to plague the industry as consumers avoid entire lines of produce while regulatory officials attempt to trace back sources of contamination outbreaks. With the latest Salmonella outbreak this summer, tomato producers could only sit back and wait as the investigation continued to expose illnesses — with almost 1,300 people identified by mid-July, and the investigation then transitioning to jalapeno and serrano peppers.

While a more integrated trace-back system would not solve all investigative issues, it certainly would assist in and speed trace-back efforts for source identification. “In fresh produce we see a lot of variability in lot identification that people use,” said American Phytopathology Association Plant Pathologist and Food Safety Expert Dr. Trevor Suslow, with the more advanced programs able to trace a lot back to the individual field, worker and even hour processed. “These sorts of things assist in any trace-back initiative. To get to the heart of it and exclude those (suppliers) who couldn’t be involved are critical aspects,” Suslow said.

REACTIVE OR PROACTIVE. One of the issues is the tendency of reaction vs. pro-action. What is found, Suslow said, is that systems tend to be most advanced for those commodities that have had recurring issues or have a size or value that can support the cost of advanced initiatives. “It’s not that the technology is not available, it’s really who is applying it at this time,” Suslow said, adding, “It’s certainly time-consuming and costly.”

There also are global issues of system standardization, he said. “The greatest challenges have to be the issues of what is a lot and how do you separate and segregate produce coming in from different locations?” Particularly with produce, which breaks down to individual components that may be ripening at different times, co-mingling and repacking are integral to providing customers with a quality product. At the same time, he said, “it is very hard to maintain lot integrity. You can do it, but it is a lot of record keeping and tracking.” And this is true with produce whether it is grown domestically or across the globe.

Despite these challenges, trace-back programs are continuing to advance on a global level, at least in part because of large buyers who are beginning to demand harmonized, global standards. While producers in smaller niches may not yet be facing major requirements, “anyone engaging in global trade will have to have a system in place,” Suslow said.

THE GOOD NEWS. The ripe and rotten sides of the tomato, so to speak, are that a solution does exist, it just needs to be put into action, said Gary Fleming, vice president of industry technology and standards for the Produce Marketing Association (PMA).

“It drives me crazy to hear people say, ‘We need to find a way to do this.’ We’ve already found a way,” Fleming said. “We just need to educate everybody and get it done.”

Fleming, along with Canadian Produce Marketing Association (CPMA) and United Fresh Produce Association (United Fresh), represents PMA on the steering committee of the Produce Traceability Initiative. The initiative consists of more than 30 companies, representing all segments of the supply chain. “We have a large majority of the market on the initiative,” Fleming said. “These are the industry movers and shakers, and we’ve represented every facet of the industry.”

Since its inception in 2007, the committee has met four times, and has developed an action plan for establishing industry traceability best practices and goals, and began work on the four elements determined to be key to implementing industry-wide traceability standards, which include:

1. GS1 was endorsed as the produce industry standard. Developed by the international standards organization GS1 (formerly known as EAN-UCC), it was chosen because it is already being used by many, and it was determined to be the most efficient worldwide approach to achieve system-wide traceability.
2. The initiative is to begin with standardization of case-level identification then move to the item level, primarily, Fleming said, because the supply chain currently uses some form of case identification, so standardization of that is the simplest first step.
3. Still needed is a “vehicle for public declaration,” Fleming added. Both buyers and sellers need to have a means to state their support for and commitment to traceability standards.
4. In addition, a means of industry education needs to be developed to enable dispersal of information as quickly as possible.

Although the initiative is starting in the produce industry, the goal is to roll it out to other foods as well.

GLOBAL STANDARDS. At the heart of the standardization is the GS1 coding, using the system’s Global Trade Item Number (GTIN), which is similar to the U.S. UPC coding but allows for more information. Identifying commodities by numerical coding rather than description is critical because word-based descriptions can vary significantly, while, like a UPC code, each attribute in a numerical code can have a specific meaning that is recognizable worldwide.

“The GS1 standard is used in 108 countries worldwide, so we are not asking them to use a standard that they are not already familiar with,” Fleming said, adding that what is new is that they need to put it into a bar code that is electronically readable and storable. And those with current proprietary systems would need to add an integrative feature.

The transition of the recent Salmonella outbreak from tomatoes to peppers illustrates one of the key issues with traceability today. “Because of the length of time and duration of new cases, I am that much less sure that the initial analysis was correct,” Suslow said. And it is the unknowns and amount of time that has passed that bring home the complexities of tracking such commodities, particularly with the vast amount of repacking and comingling done with produce.

The critical elements needed are to define exactly what a lot is and differentiate product coming in from different farms, Suslow said, “to narrow the scope of traceability in the shortest amount of time possible.”

PRODUCE TRACEABILITY INITIATIVE. This is exactly the goal of the Produce Traceability Initiative, which has three key identifiers to be integrated in the GTIN: lot number, packer data and harvest data, with the coding updated at each step.

“Anyone that changes the composition of a case would have to create a new GTIN,” Fleming said. As long as a case remains unopened and unchanged, its GTIN will remain that of the shipper, but once a case is opened, resorted, repacked or its contents otherwise changed, a new GTIN is generated that links to previous GTINs of all the contents of this case, and that number is used until the next change — up to consumption.

The ultimate goal is to take this traceability to the item level, but there are some key challenges associated with that, particularly as relates to produce. As regards the PLU stickers, Fleming said, “the challenge we’re going to have is space.” Then there is the issue of productivity. With increased label changes, sort lines and product stickering, “adding this information would have a significant impact on packaging productivity,” he said. “There are some significant operational challenges and costs to going that step.” But it is an area that the committee will continue to investigate; it is the final item of the group’s charter.

The Produce Traceability Initiative was started because of the 2006 outbreak of E. coli in spinach, Fleming said. “No matter how many food safety protocols are in place, something will slip through the food safety net.” And while one forward/one back is a bioterrorism requirement, he added, FDA does not specify how this must be done (i.e., paper tracking is acceptable), nor does it have the resources to follow back to ensure it is happening.

By implementing a standard electronic system across the global supply chain, if an incident occurs, the product is readily traceable to the previous handler, who can trace one step back and so on. “We have an electronic record that people can quickly isolate.” And basing the system on the existing, global GS1 system means the industry is not being asked to integrate something new.

The means for efficient traceability do exist, Fleming added. “Now we just need to find ways to get the industry to move on the initiatives, rather than just talking about it.” 

The author is staff editor of QA magazine.