IFT Report Released

The IFT Report is extensive and contains an immense amount of information. There are several parts that should be reviewed to have a comprehensive understanding of the report.

1. Executive Summary - Technical

2. Executive Summary - Economic

3. Tactics for Improving Food Product Traceability

4. Economic Report

5. Technical Report

To read the Exec summaries and the full economic and technical reports with highlights you can view them at our website http://www.usfoodtrace.com/ under "Current Updates". It's a lot of reading but scan thru the highlights and focus on areas you feel important to you.

FoodTRACE is VERY pleased with the IFT report....we are acknowledged as potential solution providers and described in the grouping of Information Transfer Platform systems.

Also, a joint FDA/FSIS meeting in D.C. is being held on December 9 and 10.... FoodTRACE will be there and presenting as well. If you have any questions or comments please write to us at info@usfoodtrace.com.

FDA & FSIS Joint Meetings on Traceability Announced for December 9 & 10, 2009

The FDA & FSIS have announced meetings for December 9th and 10th in Washington D.C. These are public meetings both attendance and participation is allowed. FoodTRACE, as we have done in the past with other FDA meetings, will be attending and openly discussing traceability needs for food. You can see the entire 26 page announcement which include their questions of concern at this link:

http://www.fsis.usda.gov/Frame/FrameRedirect.asp?main=http://www.fsis.usda.gov/OPPDE/rdad/FRPubs/Docket_no_FDA-2009-0523.htm

Other than focus on the questions, below are some statements included in the above referenced announcement. As you read this, we hope you can see how fully FoodTRACE has been developed to be the most effective form of traceability available for food.

The purpose of the meeting is to stimulate and focus a discussion about mechanisms to enhance product tracing systems for food. This discussion will help FDA and FSIS determine what short and long term steps the two agencies should take to enhance the current tracing system.

Federal food safety agencies need to increase the speed and accuracy of traceback investigations and traceforward operations. FDA and FSIS intend the public meeting to stimulate and focus a discussion about the core elements of product tracing systems, and mechanisms to enhance product tracing systems for food.

The public meeting is intended to address product tracing systems to facilitate traceback investigations and traceforward operations for food products. A traceback investigation is an investigation to determine and document the distribution and production chain, and the source(s), of contaminated (and potentially contaminated) food, often in the context of an outbreak of foodborne illness. A traceforward operation is an operation to determine the distribution of contaminated (and potentially contaminated) food.

Food contamination events, often involving foodborne illnesses, have emphasized the importance of efficient and effective product tracing systems, particularly the importance of linking shipments of contaminated (and potentially contaminated) food backward and forward through the supply chain through the efficient assembly and review of product tracing records.

Timely and accurate information gained from records available during a traceback investigation or traceforward operation may:
Help limit the public health impact of a foodborne illness outbreak
Enable public health authorities and the food industry to provide targeted and accurate information about affected food to consumers, and, as a result, restore or enhance consumer confidence in food safety
Help limit the source of the problem to a particular food or to a particular region or locality
Help prevent future outbreaks by enabling the applicable Federal or State regulatory agency to more rapidly investigate firms where contamination may have occurred

In practice, reviewing multiple records to find information relevant to a particular traceback investigation or traceforward operation takes time and decreases the efficiency of product tracing.

Recent traceback investigations conducted by FDA demonstrate the the FDA's ability to identify the source of an outbreak can range from days to months after CDC notifies FDA that a specific food has been implicated in an outbreak.

Traceback investigations and traceforward operations have demonstrated that FDA needs to be able to respond to the size and complexity of the food supply chain with a product tracing system that is more sophisticated, effective, and efficient in its capacity to link the contaminated food along the distribution chain and that reflects and responds to changing production and distribution patterns.

Considerations for an Effective Product Tracing System
A whole chain product tracing system consists of information elements provided by persons in the supply chain to other persons in the supply chain or to regulatory officials (e.g., during a traceback investigation). Key information elements of a whole chain product tracing system may include:
Who manufactured the product
Who is sending the product forward in the supply chain and who is receiving the product
Who is transporting product in the supply chain
The physical location at which food is received or released
An adequate description of the food that is received or released
The date and time food is received or released
A lot or code number (or other identifier of the food)
The quantity of food and how it is packaged
The specific source of each ingredient used to make every lot of finished product
A shipment identifier (such as an invoice number, airway bill number, or bill of lading, and,
A means to link information about food that is received to food that is released both internally and externally throughout the distribution chain

Most product tracing systems (including FDA's regulations in 21 CFR part 1, subpart J) are designed and implemented as one up/one down systems rather than as whole chain systems. In a one up/one down system, the focus is on the immediate previous source of food an the immediate subsequent recipient of food, as well as the immediate previous transporter and the immediate subsequent transporter.

In section V.A. 4 of this document, FDA is seeking comment on whether some information in the product tracing systems should be sent further in the supply chain than one down.

Traceback investigations for fresh produce have highlighted several particular challenges associated with tracing fresh produce back through the supply chain (73FR at 55115 at 55118). For example:
Fresh produce is perishable and may no longer be available for testing by the time the outbreak is detected
Fresh produce is often sold loose, without any packaging that would provide information about its source
Containers in which the fresh produce was shipped, which may have provided information about its source, may also have been discarded by the consumer or end user long before a traceback investigation is initiated

Common industry practices add a layer of complexity. Examples of such practices are:
Repacking fresh produce from multiple sources
Commingling food from different sources, shipments or lots
Exchanging food with other local farms or businesses
Re-using and sharing shipment containers from other farms/businesses
Using different names for the same fresh produce as it travels throughout the supply chain
Substituting a different variety or size of fresh produce without documentation
Not assigning a lot or code number (or other identifier of the food) to the fresh produce that goes forward into the supply chain