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From: Food Quality & Safety magazine, August/September 2013

Letters to the Editor

Congratulations for showing Food Quality & Safety on FACEBOOK!!

This will make your excellent publication to be read by many more people and have greater influence to the entire field of Food Science and Food Safety.

There was one issue of Food Quality which fitted a special Food Microbiology lecture I gave that I requested 50 copies for my class…the materials came on time and EVERY student had a copy of that issue and read the material!!

Keep up the wonderful work under your new name: "Food Quality & Safety"

—Daniel Y. C. Fung, MSPH, PhD, Professor of Food Science

I enjoyed reading the article in the June/July issue under the section Safety & Sanitation titled "CIP: The Industrial -Grade Dishwasher" by Chad Enck.

I would like to point out one item that Mr. Enck overlooked in his article. That is that CIP is only successful when the equipment and processes are specifically designed to be hygienic and specifically for the purpose of CIP cleaning. Not all equipment or processes can be successfully CIP cleaned. It takes proper hygienic design and engineering of all of the components to assure that they will effectively clean while fully assembled.

Thank you.

—F. Tracy Schonrock, Acting Technical Director, 3-A SSI

I was a member of the traceability pilot study that was discussed in the June/July issue. The traceability pilot study conducted by the IFT is an excellent reference point and brings to light some very interesting data points surrounding traceability. However, I feel we missed some major points. As an industry we can accomplish traceability a little smarter, faster, and in a way that makes the collection of data more manageable, effective, quicker, and affordable. I remember a conversation I had with the author during the development of this report concerning traceability/recalls where I commented that “I feel one of the major problems we have with traceability is that we cannot define the difference between traceability and recalls. I feel when industry and or government trace a product(s) the process proceeds at the pace of a snail and when we recall it is completed at the speed of light.”

After an exhausting search of numerous documents, theories, and systems I have come to find and believe two things which define food traceability. Traceability as a general term is the "ability to chronologically interrelate the uniquely identifiable entities in a way that matters" and traceability is not inventory management on steroids. Traceability when we talk food safety is really the art of rapidly disassociating or associating a company(s) food product with a food event and it has only four data points. First, the name of the company; second, the location the product was actually harvested, prepared, or sold; third, the name of a contact within a company who handles traceability is authorized to communicate with the government, and; fourth, a defined TSL (traceability shelf life date window) to search.

In order for these four data points to matter, they must be reported to a centralized database so they can be viewed in a near real-time environment and be cost effective. To recall a product, the data requirements needed are much more complex, and in my opinion tend to follow some of the KDEs and CTEs called out in the IFT report. However, it has been proven time and again that once government recalls a product it comes of the shelf at the speed of light and more adequately phrased in less than 24 hours. After reviewing the pilot study report submitted by the IFT, I'm concerned that the recommendations given make for an extremely complex database management system, which the FDA would be forced to operate in a non-real-time environment. The report failed to accomplish the following points that are critical to food safety:

• Defining where traceability fits within a Food Event Cycle;
• Defining if a company is proactive or reactive in nature;
• Determining how data can be visualized to afford near real time product movement so to associate or dis-associate a company’s product with a food event;
• To explain to the government the pit falls of using products like the GS-1 as recommended by the PTI; and
• Cost.

How a company engages food safety and traceability is a dynamic entity. We can look at prevention measures, inspect them, conduct mock recalls, measure recall times, but when it comes to traceability, it’s about the how fast the response is once a contaminated product has been identified. The pilot traceability study discovered that if a company has a standard to operate from, it’s pretty easy to comply with a request. This where I have concerns with the report. It was discussed that KDEs CTEs and others similar to the PTI and GS-1 are deposited in a centralized database that traceability can be managed so to reduce the time needed in containment. This is very difficult process and I feel does not present a solution which is manageable. If you review the difference between food events that are short in duration against ones being long in duration, two factors come into play. First, the timed needed to go from the competition of the isolation component of a food event to the start of the containment side of a food event. Second, the association or disassociation of possible products and suppliers.

I strongly feel that the continued referring to the GS one and other standards is wrong. Industry companies have complex and proprietary inventory management systems, which they are not about to change. Nor does the current law require them to. If traceability is going to work industry has to come voluntarily. This means that traceability has to be managed in such a way that industry has no issue supporting the data requirements of a near real-time centralized database. Additionally, the government has to accept that there will never be a solution to all food outbreak problems without a complete overhaul of how we detect food outbreaks today. The only way solutions such as recommended by the PTI can ever be realized is that the entire food industry operates from a single standard. If the FDA was to evaluate the costs surrounding such a concept, they will come to the conclusion that it's impossible and can never be achieved.

—John F Granich, President CEO, US FoodTRACK



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