RQA - Recall News

The Challenges of Traceability

This article highlights the numerous challenges in achieving robust, efficient and economic traceability as well as measures to tackle these challenges.

Traceability is essential to meet regulatory requirements, support consumer safety and manage effective recalls. Within Europe, the legislation that governs food and drink traceability requirements is EC178/2002. Traceability of non-food consumer goods is a requirement of Directive 2001/95/EC on general product safety. European law requires a company to be able to trace back to their supplier and forward to their first customer, i.e. "one up, one down". It is fairly easy to meet this requirement through keeping records of deliveries and despatches. However, this does not meet some of the main goals of business, such as: protect and develop the brand, grow profits, safeguard consumers and customers and enhance the company's reputation.

The challenges to achieving 100% robust traceability can be placed in three broad areas:

1. Process
Bulk storage - often one batch of ingredient may be added on top of an earlier delivery or batch.
Continuous processes - e.g. water supplied as an ingredient may be processed continuously for addition to product.
Rework - off cuts, process start-up, damaged product etc. may be added back at various points in a process if product safety criteria are met. In some processes rework from one batch may be added to a different batch.
Accumulation - to assist in minimising downtime on packaging lines, accumulation tables may be used to store product that is later gradually fed back into the production stream.
Value Adding activities/Promotions - for example where a product has another product added to it. (e.g. twin-packs of different products).
Product Returns - some products may be returned, checked and despatched as part of a future delivery, others may be reprocessed or destroyed.
Mixed lot deliveries - suppliers may deliver a number of batches of the same ingredient in a single shipment or series of shipments.

2. Systems/Data
Labelling and product identification tools - these often lack consistency within supply chains and may consist of some or all of the following - alphanumeric human readable printing, 1- D and 2-D bar-codes (GS1 standard or customised by system providers), RFID.
Enterprise, Manufacturing Execution, Laboratory Information and Warehouse Management Systems - may predefine process requirements that constrain a business' ability to cost effectively manage traceability.

3. People
Procedural - failure to follow rules and standards can adversely affect the ability to trace product.
Errors - mis-recording of information is a common source of mistakes.

Addressing the challenge:

  • Once current processes are mapped they must be risk assessed to determine the level of risk of failure, and, therefore the degree of traceability that is required to meet the business' risk appetite (or allowable value at risk). If the risk of failure is deemed to be unacceptably high, then either the core process needs to be revised or the level of traceability must be increased. Upstream and downstream risks should also be considered as these may impact upon the local risk assessment. Include the impact of systems' constraints and people within the risk assessment.
  • Define "the product" as consisting of the physical entity, the information that travels with it along the supply chain (e.g. lot code, ingredients, Best Before, labelling) and the records that are held by each agent along the supply chain.
  • Establish rules and stick to them.
  • Test the ability of the business, its suppliers and customers to trace on a regular basis.

 Further Reading/ References:
The General Food Law is available on the DG SANCO website
http://ec.europa.eu/food/food/foodlaw/index_en.htm

Guidelines on the Implementation of Traceability
http://ec.europa.eu/food/food/foodlaw/guidance/index_en.htm

Directive 2001/95/EC
http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:32001L0095:EN:HTML

GS1 Guidance on Traceability
http://www.gs1.org/traceability

To find out how RQA Europe can help you achieving 100% robust traceability click here to contact us

The winner of RQA Europe's prize draw has been selected

The winner of RQA Europe's exciting quarterly prize draw, which is open to those who subscribe to the RQA recall newsletter, was drawn on the 18th of December. The lucky winner is the employee of Plum Baby, Mr  Stephen Groves. The prize was the IPod Nano with 8GB or space for 2,000 songs / 8 hours of video and has been sent to the lucky winner.

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Christmas greetings to all of our readers! We will be back in the New year with lot's more news and discussions on product recall issues.

RQA Europe wishes you a warm and wonderful Christmas!

 

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