The ability for food manufacturers to recall contaminated food products was publicly tested last year in the Listeriosis outbreak. In addition to processed meat products, frozen corn and eggs were also whipped off shelves following reports of other food borne hazards.
The feedback from many of the stakeholders was that the systems in place at most levels of the food industry were simply not robust enough.
While you may have escaped this public scrutiny, tackling a real recall is completely different to conducting your mock recall. Only when the level of pressure and responsibility that goes with the need for rapid identification of the whereabouts and isolation of contaminated product literally means the difference between life and death, do you truly find out whether your traceability and recall systems work. And you don’t want to find out then, that they are not effective.
In order to be prepared, you need to understand the requirements of a full traceability system.
Traceability – now a BASIC legal requirement
The seriousness of having a reliable method for this aspect of consumer protection is highlighted by the recent inclusion of traceability as an additional requirement in the new hygiene regulation, R638 – Regulations governing general hygiene requirements for food premises, the transport of food and related matters. This regulation is promulgated under the Foodstuffs, Cosmetics and Disinfectants Act, (ACT NO.54 of 1972) and is the minimum legal requirement applicable to all food premises in South Africa.
R638 of 2018, Regulation 10
The person in charge of the food premises is responsible to ensure…
- there is compliance with these Regulations through the keeping of appropriate records,
but records applicable to processing, production and distribution must be kept and
retained for a period of at least 6 months after the shelf -life of the product;
- that foodstuff manufactured, kept or sold from the premises complies in all respects to the
provisions of the Act and the regulations promulgated there -under, including the
- and must ensure that a traceability system is maintained according to the best available
method and a recall procedure is in place and any incident requiring recall activation is
reported to the local inspector and the National Directorate: Food Control.
And the best available method is…
Other legislation defines the requirements for a batch or lot.
According to R146 of 2010, Regulations Relating to the Labelling and Advertising of as amended by R1091 of 19 November 2010, a…
“batch” means a definite quantity of a commodity produced essentially under the same conditions, not exceeding 24 hours.
This regulation goes on to prescribe that “A container of a foodstuff shall be clearly marked with a batch number in such a way that the specific batch is easily identifiable and traceable unless otherwise stipulated in terms of regulations published under the Agricultural Products Standards Act, 1990 (Act No. 119 of 1990) and the National Regulator for Compulsory Specifications Act, 2008 (Act No.5 of 2008).”
But can you trace your batch – really?
It’s not enough to know what the law says about batch or lot identification. Can you do it? Do you know which customer received which batch of product and how much of each batch? Many systems can trace which customers received which products but not to a batch level. Some systems can trace which batch of final product the customer received, but not which batch of ingredients were used in that batch. Can you trace your ingredient to specific production batch? Do you know which batch of sugar was used across several production batches if you use a bulk silo?
You do need to have control over ingredients and not just the final product. What would you do if a supplier advised that they had shipped you a contaminated ingredient? Would you be able to easily identify what batches of your product contained that ingredient? But not just as a recipe item, but that specific batch of ingredient?
In order to do this, each ingredient would need to be allocated unique batch numbers on delivery and this batch information would need to be carried over to every production record. In summary, many of the manual systems we use simply to not meet the requirements of lot traceability. The obvious solution is to use technology to assist you.
How long does it take YOU to conduct a mock recall?
As a responsible manufacturer, you should recall products that are a potential risk to the consumer. When a recall occurs, the regulations require you to publicly announce the recall. This poses a risk of reputation damage and so how do you minimize the impact of a recall?
Your mock recall programme is key and the time taken to account for all products is a key indicator of its efficacy. This “time to completion” is dramatically reduced by having the right business systems in place to make reporting data available – where your raw materials came from, where you shipped your finished goods and what modification/assembly did you do in the middle. The industry standard system for this type of data collection, storage and reporting is known as an ERP System (Enterprise Resource Planning).
Some ERP systems are designed for more financial functions, while others like SYSPRO are designed for manufacturers. Manufacturing ERP systems are designed for companies that purchase, assemble/produce (WIP), weigh/label product – a staple for the food industry, and sell by weight or unit for enabling trace back to each individual piece that makes up the product/or the recipe.
By capturing this data end-to-end, your ERP system has “traceability” built in. This built-in traceability and reporting make it quick and easy to get the trace back reporting you need. It’s a matter of simply running the right reports. This reporting dramatically reduces the time to complete the recall and therefore helps to minimize the financial and negative brand impact. And there are solutions for small companies right through to multi-nationals.
Time to improve your traceability
Given the increased legal emphasis in this area coupled with the reality of last year’s food borne tragedy, now is the right time to review your current systems and make improvements. Let’s be honest, many of the manual systems we use simply to not meet the requirements of full lot traceability.
It just makes business sense to maintain the confidence of your customers and/or shareholders by mitigating the adverse effects and media attention of the inevitable recall.
© Deirdre Fryer, SYSPRO courtesy of Food Focus.