According to Centers for Disease Control and Prevention, each year, roughly one in six Americans become ill from eating contaminated food. Furthermore, according to the online magazine Food Safety News, food withdrawals, rejections and recalls cost the food industry $7 billion annually. In a previous article we discussed the regulations that the food and beverage industry will have to follow once the Food Safety Modernization Act (FSMA) is fully adopted. Food tracking and tracing is one of the issues that has drawn considerable attention. |
FSMA requires that the Food and Drug Administration (FDA) agency establish standards, monitoring and testing requirements, and recordkeeping practices, based on lessons learned after conducting several studies and pilot projects. In addition, the FSMA expands the conditions under which FDA has access to company records containing sensitive product-related information.
What is product tracing? Product tracing is the ability to know where a product came from and went to in the supply chain. Product tracing systems involves documenting the production and distribution of food so that in the case of contaminated food, the product can be traced back to its source. These systems enable food producers and retailers to take action more quickly and prevent illnesses. In the event of a product contamination, it is critical to have records that show where all products were distributed so that the product can be removed.
FSMA contains some references to product traceability, including: • recommendations for food traceability, including pilot programs for high-risk foods; • analyses of the economic and global trade impacts of track-and-trace systems on the food supply; • enhancing FDA’s authoriry to incorporate traceability.
Under the FSMA, the FDA has the authority to require companies to maintain records and conduct ongoing monitoring which exposes whether the company has adopted an effective system for controlling hazards on an ongoing basis. Many food producers and retailers have already implemented product tracing systems but there is no standardization as to how this is done. In each company, different amounts of information recorded will be recorded by their system, different forward or backward supply chain tracking can be implemented and different technologies will be used to maintain records.
We advise businesses from the food and beverages industry to evaluate the implications of FSMA requirements for existing regulatory compliance programs, and the legal risks associated with potential noncompliance under the law. FSMA wants to ensure that you can track and trace your products. Product tracking and tracing is critical at all levels of the food chain in order to protect public health by proactively isolating products that can create a food incident.
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