Whether you are a small or new grower just beginning to implement a traceability system, or you are an established grower interested in assessing your system for continuous improvement, ensuring all your produce is traceable not only protects consumer health, it can have business benefits as well.
A traceability system documents and tracks produce and supplies at least one step back (to the provider of the seeds, starter plants, soil, fertilizer, etc.) and one step forward (to the buyer or distributor). Although the grower itself need not track all the way to the consumer, having one forward/one back tracing at every point of the supply chain creates linkage from source to consumer — and back.
The mandates
The one forward/one back documentation requirements originated with the Bioterrorism Act of 2002, with some rules of the 2011 Food Safety Modernization Act (FSMA) adding requirements for further recordkeeping.
Although FSMA’s Produce Safety Rule does not include specific traceability standards, and some growers are exempted due to size or other factors, the rule states that all growers, even those that are exempt, “must prominently and conspicuously display, at the point of purchase, the name and complete business address of the farm where the produce was grown, on a label, poster, sign, placard, or documents delivered contemporaneously with the produce in the normal course of business, or, in the case of Internet sales, in an electronic notice.” (Read the full rule at bit.ly/2Ht1NMI.) From this, buyers — consumer or commercial — are provided with full “one-back” tracing for any produce they purchase.
Additionally, those who buy or sell more than 2,000 pounds of fresh or frozen produce in a day are required to comply with the recordkeeping requirements of USDA’s Perishable Agricultural Commodities Act (PACA), which can be helpful in the event of a traceback. Further regulation also may be coming from FDA, as the agency is still working with a FSMA requirement that it identify high-risk foods for which additional traceability recordkeeping requirements will be mandated. Thus, certain produce may be held to higher standards once these foods are identified and the requirements detailed.
Why trace produce?
The most important purpose of traceability, and the reason for the regulations and industry standards, is its ability to track product in the event of a contamination — whether that be of a pathogen, allergen, or foreign object — and withdraw or recall the specific lots from market or at any point in the chain when a contamination is detected.
But traceability also has business benefits. It can be used to investigate and settle customer complaints or questions and can help you keep track produce of each harvest and assess the compiled historical data on what is being purchased when, by whom and how much — enabling you to better determine future plantings and reduce loss. Traceability also can provide proof for claims such as organic, non-GMO, kosher, etc. — and guard against false or deceptive marketing of these claims.
Take the late 2017/early 2018 romaine lettuce E. coli contamination recalls as an example of the importance of traceability for both consumer and business benefit. If the lettuce could have been traced to a specific farm, field or greenhouse and lot at the start, it could have been withdrawn or recalled quickly, limiting both consumer and industry impact. As it is, even likely safe lettuce was trashed in consumers’ homes and left to wilt in grocery stores, not only because consumers were afraid to eat any romaine lettuce but because an FDA warning stated: “If you cannot confirm the source of the romaine lettuce, do not buy it or eat it. If you have already purchased romaine lettuce or products containing romaine lettuce and cannot confirm the source, throw them away.”
Thus, any producer of romaine lettuce who did not have a traceability program, or whose “one-forward” buyer could not confirm its source, was not only implicitly associated by default, but was essentially implicated as part of the problem.
An efficient, effective program
In building or assessing a traceability program, there are elements you should include to make it both efficient and effective.
Be selective, but thorough. To determine the produce on which your initial traceability efforts should be focused and which will be most beneficial, assess the products you produce for relevant and related food safety risks as well as potential for substantiating specific consumer-desired characteristics such as organic and GMO-free. From there, continue on to set up traceability for all your produce, particularly because new trends continue to emerge in product/pathogen contaminants.
Create lots. As noted in the definition at the beginning of this article, it is the application of “unique codes” that enables traceback to specific segments of produce. Generally determined by location, time of production, and/or process step (e.g., product change, clean break, etc.), this will specifically identify the scope of produce that may be implicated in a foodborne-illness outbreak or customer complaint, and limits the amount of produce that would need to be recalled. While your lot number may or may not continue on the produce to the final consumer, the recordkeeping of your “one-forward” buyer should have it documented.
Track steps forward and back. Produce growers are at the root of the food chain, so your tracking sets the foundation for the entire chain and can impact an entire industry — as the romaine lettuce contaminations evidence. While growers will have few steps backward, contamination can originate from packaging and other supplies, so protecting yourself can mean being able to identify a supplier as a potential source of a contamination. Although you cannot control the actions of your buyers once produce is out of your hands, it is not only federally mandated, but also beneficial to you, to ensure they have all the relevant business information at purchase.
It often has been said that we can’t test food safety into a product; in the same way, we can’t trace food safety into a product. In and of itself, traceability will not improve food safety. Rather a thorough, efficient system can make your food safety processes and procedures more effective.
