March 2013: First Look! FDA Releases IFT Traceability Report and Lessons from Europe's Horsemeat Crisis Every Fresh Food Brand Should Learn
First Look! FDA Releases IFT Traceability Report
In September 2011, the FDA enlisted the Institute of Food Technologists (IFT) to evaluate the costs and benefits of traceability on the fresh food supply chain. Through pilot programs with growers, processors, and retailers of tomatoes, chicken, and peanuts the IFT developed proposed guidelines for the traceability requirements outlined in the Food Safety Modernization Act (FSMA). HarvestMark was pleased to be selected as one of the collaboration platform providers in the study, and several of our customers participated as suppliers.
The pilots focused on the current state of traceability in the food supply chain – its speed and accuracy, as well as costs and benefits. While they found some companies had advanced traceability solutions, the pilots also observed sophisticated growing operations with shipments tracked by pen and paper. The report found that participants typically achieved ROIs of less than 2 years on their traceability systems.
In our opinion, the most significant recommendations (of the top 10 listed below) for grower shippers were that the FDA require standardized recordkeeping for all participants in the supply chain – with no exceptions for risk classification. These records would include Key Data Elements (KDEs) such as harvest date, SKU, and so forth at each Critical Tracking Event (CTE) such as processing or packing. The FDA will also implement an electronic mechanism to acquire these CTEs and KDEs from participants in the event of a traceback investigation.
At HarvestMark, we believe traceability is the foundation for value creation – not the end in itself. As the report found traceability is more than just compliance and food safety, it also creates the platform for improving the efficiency of the supply chain, increasing freshness and quality, and connecting with consumers to earn trust.
So! You can read the 334 page IFT report or contact us to see how easy and affordable it can be to comply with all of these rules.
IFT’s 10 Recommendations to the FDA:
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.
2. FDA should require firms that manufacture, process, pack, transport, distribute, receive, hold, or import food to identify and maintain records of CTEs and KDEs as determined by FDA.
3. Each member of the food supply chain should be required to develop, document, and exercise a product tracing plan.
4. FDA should encourage current industry-led initiatives and issue an Advance Notice of Proposed Rulemaking or use other similar mechanisms to seek stakeholder input.
5. FDA should clearly and more consistently articulate and communicate to industry the information it needs to conduct product tracing investigations.
6. FDA should develop standardized electronic mechanisms for the reporting and acquiring of CTEs and KDEs during product tracing investigations.
7. FDA should accept summarized CTE and KDE data that are submitted through standardized reporting mechanisms and initiate investigations based on such data.
8. If available, FDA should request more than one level of tracing data.
9. FDA should consider adopting a technology platform that would allow efficient aggregation and analysis of data submitted in response to a request from regulatory officials. The technology platform should be accessible to other regulatory entities.
10. FDA should coordinate traceback investigations and develop response protocols between state and local health and regulatory agencies, using existing commissioning and credentialing processes. In addition, FDA should formalize the use of industry subject matter experts in product tracing investigations.
The European Horsemeat Crisis has Shoppers Bucking Beef Products
In January, a food safety authority in Ireland discovered that 30% of the beef burgers they tested contained horse DNA. The subsequent outrage – and testing – spread quickly across Europe (at least in those countries that typically don’t eat horse). One beef lasagna actually tested as being 100% horsemeat and the results indicate that food adulteration may be more commonplace and widespread than previously believed.
European officials conceded that their oversight had not been aimed at authenticating food products.
The horsemeat scandal has underscored the importance of traceability in ensuring shopper trust. Major retailers and brands were caught between having to explain whether they had control of their supply chain and had let this happen knowingly … or whether they had no idea what was going on in their supply chain. Shopper trust has plummeted and the European beef industry will feel the effects for quite some time.
Governments are scrambling to reassure the public that their food is safe. European regulators are increasing the frequency and thoroughness of inspections at meat processing plants. While the US has remained clear of the horse meat scandal (it has strict import requirements and no domestic horsemeat processors … Although coincidentally a US horse slaughterhouse is likely to be approved by the USDA, the first in since 2007).
Brands that can demonstrate traceability to inspectors as well as shoppers will be a step ahead. Creating a connection with shoppers in the produce aisle gives peace of mind—and a boost to your brand name. The ability to communicate food safety status, your farming principals and philosophy, and when produce was harvested gives shoppers trust in your fresh food.
Contact us to see how we can help your brand improve consumer confidence in your supply chain.
Public Perception is More Important than Ever
Food activists have been targeting the business practices of the largest packaged food manufacturers since the ‘90s. This has generally been good for fresh food brands as consumer preference has steadily shifted to fresh. Spotlighting epidemics like childhood obesity, diabetes, and heart disease has increased demand for a more plant-based diet. But the focus of food activists has been broadening to include the business practices of growers.
The recently released Oxfam Report, Behind the Brands casts an unflattering light on some ways that some organizations are exploiting the environment, workers, and neighbors of their growing operations. The tactics these food activists are using are straight out of the playbook of apparel activists who called for transparency around who was making the clothing and where it was made.
Growers not only have to worry about what the public thinks about their product but also about how the operations affect the communities they operate in. The ability to learn about the farming practices is becoming more and more important to consumers as exposés continue to be used to gain media attention for causes.
HarvestMark Connect gives growers the ability to differentiate in the grocery aisle by letting you tell your story directly to the shopper. With more than 9 out of 10 adults owning a smartphone, it is easier than ever to connect with shoppers to offer them recipes, selection tips, and gather real-time feedback about their experience. Learn more about how this revolutionary but simple technology can give you a leg up – and stay ahead of the calls for transparency.
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