This report on the pilots, which was required by the Food Safety Modernization Act (FSMA), offers recommendations to FDA on how to improve product tracing in a way that benefits all stakeholders. The report provides important findings to help regulators resolve foodborne illness outbreaks earlier and enable the food industry to respond to them quicker. As a result, the public health impact of an outbreak will be greatly reduced. Based on eight case studies of previous outbreaks, improved product tracing had the potential to reduce the public health impact by up to 55% of total illnesses and reduce the economic impact by up to $14 million per outbreak.
The results of the pilots also suggest that if a food company improves its ability to trace products, the company can expect to also achieve improved business processes, increase supply chain confidence and possibly expand their markets. Many companies in the food industry consider product tracing a subset of supply chain operations, and product tracing may not be a dominant consideration when making investment decisions. However, the threat of not having product tracing capabilities in the event of a foodborne illness outbreak represents significant risks to a firm.
Pilot Study Findings and Recommendations
As part of the report submitted to FDA, IFT conducted a pilot looking at fresh produce and another pilot for processed foods. Tomatoes were selected for the fresh produce pilot, and foods consisting of chicken, peanuts and/or spices were selected for the processed food pilot. Foods selected for the pilots had been associated with outbreaks between 2005 and 2010. Key findings from IFT's analysis of current product tracing practices indicate the following challenges associated with outbreak investigations:
· Tedious and difficult to sort through hundreds of pages of documents
· Confusion when data definition is lacking
· Inconsistent item descriptions
· Wrong or incomplete information cause delays
· Companies operating under multiple names are difficult to identify as sources
Although FSMA limits FDA to enacting additional recordkeeping requirements to "high-risk foods," outbreaks during the last several years reinforce the fact that foods previously considered "low-risk" can quickly find themselves on the "high-risk" list. Therefore, IFT suggests that FDA take the opportunity to advise the entire food industry on "best practices" for recordkeeping through the use of guidance documents.
Additional IFT recommendations to the FDA include the following:
· Clearly identify the types of data that industry needs to provide during an outbreak investigation
· Require each member of the food supply chain to develop, document and implement a product tracing plan
· Pursue the adoption of a technology platform to allow FDA to aggregate and analyze data reported in response to regulatory requests
· Coordinate traceback investigations and develop response protocols between and among state and local health and regulatory agencies
· Offer extensive outreach and education around future regulations and expectations
"IFT expects that these recommendations will not only help protect consumers, but also help develop a better framework for industry and government to focus on food system improvements in the coming years," said IFT President John Ruff.
The FDA is soliciting input on the IFT report and will issue its own recommendations in a report to Congress. The full IFT report and additional materials are accessible at www.ift.org/traceability.