Traceability in the feed and food chain Jin Moon Kim Jiang Nan University, China

ISO 22005:2007 established the principles and requirements for the design and implementation of a feed and food traceability system.

General Food Law – Implementation Guidelines (EU)

Traceability: EU General Food Law Regulation defines traceability as “the ability to trace and follow a food, feed, food- producing animal or substance.... through all stages of production, processing and distribution”.

From the EU’s legal point of view, the requirement for traceability is limited to ensuring that businesses are at least able to identify the immediate supplier of the product in question and the immediate subsequent recipient.

EU importers often demand trading partners to apply traceability systems beyond the legal requirements.

The identification of the origin of feed and food ingredients and food sources is of prime importance for the protection of consumers, particularly when products are found to be faulty. Traceability facilitates the withdrawal of foods and enables consumers to be provided with targeted and accurate information concerning implicated products.

ARTICLE 11: IMPORT OF FOOD AND FEED ARTICLE 12: EXPORT OF FOOD AND FEED ARTICLE 17: RESPONSIBILITIES OF MEMBER STATES ARTICLE 18: TRACEABILITY ARTICLE 19: WITHDRAWAL, RECALL AND NOTIFICATION BY FOOD BUSINESS OPERATORS

ARTICLE 20: WITHDRAWAL, RECALL AND NOTIFICATION BY FEED BUSINESS OPERATORS

II. ARTICLE 18 TRACEABILITY

II.3.2. Implementation of traceability requirement i) Identification of suppliers and customers by food business operators. A food business operator should be able to identify any “person” from whom it received its food/raw materials. This person can be an individual (for example a hunter or a mushroom collector) or a legal person.

Examples of traceability tools and labels

Sheep and goat tag, Lithuania Initials of the Animal Recording Centre (Agriculture Information and Rural Business Development Center) Country code 6-digit individual animal identification number

Date of issue Ear tag number Origin Name and address of owner Cattle passport, Germany

Label on beef steak, Belgium Traceability bar code Country where animal was born Country where animal was fattened Country where animal was slaughtered

Origin Category Weight Traceability code Label on oranges, Belgium

ii) Internal traceability Food business operators should be encouraged to develop systems of internal traceability designed in relation to the nature of their activities (food processing, storage, distribution etc). An internal traceability system will benefit the operator by contributing to more targeted and accurate withdrawals (avoid unnecessary wider disruption).

iii) Types of information to be kept The first category which shall be made available to the competent Authorities in all cases: Name, address of supplier, nature of products which were supplied from him. Name, address of customer, nature of products that were delivered to that customer. Date of transaction / delivery.

The second category includes additional information which is highly recommended to be kept: Volume or quantity Batch number, if any. More detailed description of the product (pre-packed or bulk product, variety of fruit/vegetable, raw or processed product).

iv) Time of records keeping For products without a specified shelf life, the general rule of 5 years applies; For products with a shelf life above 5 years, records should be kept for the period of the shelf-life plus 6 months;

For highly perishable products, which have a “use by” date less than 3 months or without a specified date, destined directly to final consumer, records should be kept for the period of 6 months after date of manufacturing or delivery.

III. ARTICLE 19 WITHDRAWAL, RECALL AND NOTIFICATION WITHDRAWAL, RECALL AND NOTIFICATION BY FOOD BUSINESS OPERATORS BY FOOD BUSINESS OPERATORS

1. If a food business operator considers has reason to believe that a food which it has imported, produced, processed, manufactured or distributed is not in compliance with the food safety requirements, it shall immediately initiate procedures to withdraw the food in question from the market and inform the competent authorities thereof.

2.Food business operator in retail or distribution activities which do not affect the packaging, labeling, safety or integrity of the food shall, within the limits of its respective activities, initiate procedures to withdraw from the market products not in compliance with the food-safety requirements.

3. A food business operator shall immediately inform the competent authorities if it considers or has reason to believe that a food which it has placed on the market may be injurious to human health. 4.Food business operators shall collaborate with the competent authorities on action taken to avoid or reduce risks posed by a food which they supply or have supplied.

IV. ARTICLE 20 WITHDRAWAL, RECALL AND NOTIFICATION BY FEED BUSINESS OPERATORS

In practice, traceability systems are record keeping procedures that show the path of a particular unit or batch of product or ingredient from supplier(s), - through all the intermediate steps which process and combine ingredients into new products, and - through the supply chain to customers and perhaps ultimately to consumers.

Public Health Security and Bioterrorism Preparedness and Response Act of 2002 (United States)

The events of Sept. 11, 2001 reinforced the security of the United States. US Congress responded by passing the Public Health Security and Bioterrorism Preparedness and Response Act of President Bush signed into law June 12, 2002 (Public Law ). The Bioterrorism Act

The Bioterrorism Act prohibits food from an unregistered foreign facility from being delivered for distribution in the United States.

Proposed Food Safety Regulations by FDA Under this rule, manufacturers, processors, packers, distributors, receivers, holders, and importers of food, including pet food, would be required to keep records identifying the immediate source from which they received the food as well as the immediate recipient to whom it was sent.

What records must be established and maintained by non-transporters of food? Sources - the name of the firm, type of food, date received, quantity and type of packaging, the immediate transporter previous sources. Recipients - in addition to the above information, identify the specific source of each ingredient that was used to make every lot of finished product.

Who Must Register? Domestic and foreign facilities that manufacture, process, pack, or hold food for human or animal consumption in the U.S. are required to register with FDA. Includes, but is not limited to, secure facilities e.g., G.O. warehouses and carrier facilities who perform these functions

Which Facilities Are Excluded from Registering? Nonprofit facilities Retailers Farms Restaurants

Fishing vessels, except those that engage in processing as defined in FDA’s seafood HACCP regulations (21 CFR 123.3(k)) Facilities subject to the exclusive jurisdiction of the U.S. Department of Agriculture

What Food Commodities Are Excluded? Personal use food accompanying a traveler Food immediately exported (without leaving the port of arrival) Meat, poultry, and egg products (subject to the exclusive jurisdiction of the USDA) Homemade goods shipped as gifts

Proposed Food Safety Regulations by FDA continued This record-keeping rule is to help the FDA track foods implicated in future emergencies, such as terrorism-related contamination.

As of July 10, 2008 Total facilities registered. US , Japan 22482, China 19720, Mexico 15716, Canada 13981, Italy 13539, France Korea 5587, N Korea 33, Australia 4018, Germany 3767, Vietnam 5358, UK 3368

Under Bioterrorism Act, all food shipments are required to notify FDA in advance. FDA is currently reviewing approximately 33,400 prior notice submissions per business day (Sept 26, 2007).

Global Food Supply

The United States trades with over 150 countries/ territories with products coming into over 300 U.S. ports (2008). FDA lacks the resources to inspect a meaningful proportion of these products when they arrive at the U.S. ports of entry. Only 1% are being inspected. In the last decade, the number of food entry has tripled.

Approximately 15 percent of the overall U.S. food supply by volume is imported. However, in certain food categories a much higher percentage is imported. For example, approximately 60 percent of fresh fruits and vegetables consumed in the U.S. are imported. Imports of seafood rose from less than 50 percent of U.S. seafood consumption in 1980 to more than 75 percent today.

There is a great international awareness with respect to the need for traceability.

The role of China in supplying food and food ingredients in recent years

Individual shipments of food and ingredient exports from China to the United States have gone from 82,000 in 2002 to 199,000 (x2.4) in reaching up to 300,000 in 2008 (FDA).

China has become the leading supplier of many food ingredients, such as apple juice, a primary sweetener in many foods; garlic and garlic powder, a major flavor agent; sausage casings and cocoa butter.

China supplies 80 percent of the world's ascorbic acid — vitamin C. (used as a preservative and nutritional enriching agent in thousands of foods). One-third of the world's vitamin A now comes from China, along with much of the supply of vitamin B-12 and many health-food supplements, such as the amino acid lysine.

The price in 1995 was $15 per kilogram. Today, the price from China is $3.50. (cannot buy elsewhere, only one supplier left in the US). That's globalization.

Globalization update Chinese government approved plans to allow U.S. FDA inspectors in three Chinese cities, Beijing, Shanghai and Guangzhou, from 9 to 12 U.S. inspectors in offices in each of the three cities (June 18, 2008) by the end of this year. The issues to be totally resolved: Chinese inspectors not allowed in the U.S.

Chinese Mud Carp (called "dace" in Hong Kong) (Vietnamese catfish) Five species: farm- raised shrimp, catfish, eel, basal, which is similar to catfish, and dace, a relative of carp.

Recent allegation involving Mexico The San Luis Obispo Tribune - Aug 15, :23 PM Las Vegas Sun - Aug 15, :44 PM Fox News – Aug 15, :20 PM Salmonella outbreak strain has been confirmed in 1,423 patients, with the latest known illness beginning July 24, Salmonella outbreak strain has been confirmed in 1,423 patients, with the latest known illness beginning July 24, 2008.

The nationwide salmonella outbreak is finally winding down but federal health officials can't yet say how the few tainted Mexican peppers they've found could explain such widespread illness. FDA investigators had finally traced the problem to a single fresh-pepper farm in Mexico.

Ingredients now come from all over the globe. The notion of guaranteeing food safety ‘from field to fork’ may be no longer possible for any one industry.

Today, there are just too many factors for one company to control. You need to look one step above you and one step below, not just at your company. It should be a continuous learning supplier in which all share the same goal: quality.

The Safe Food Act

H.R. 1148, The Safe Food Act of 2007, 110th Cong. (2007). This bill was introduced February 15, 2007 by Senator Durbin and Representative DeLauro

The Safe Food Act further mandates the establishment of a national system for “tracing food and food producing animals from point of origin to retail sale.” The Act would allow companies to issue voluntary recalls should their product be deemed unsafe, but also grants authority for the Food Safety Administration to issue a mandatory recall if the company fails to do so.

This will ensure quick removal of contaminated products from the market and increase consumer confidence in the food supply.

Country-of-origin labeling (COOL) program

Mandatory COOL becomes effective on Sept. 30, Under the COOL regulation, retailers are required to notify customers of the country of origin.

Covered commodities - muscle cuts of beef (including veal), lamb, chicken, goat, and pork; Ground beef, ground lamb, ground chicken, ground goat, and ground pork; Wild and farm-raised fish and shellfish; Perishable agricultural commodities - macadamia nuts, pecans, ginseng, and peanuts.

Only about 30% of all beef sold in the U.S. annually, because sales into foodservice and of processed products are exempt.

Macadamia nuts Macadamia integrifolia foliage and nuts

Characteristics of traceability systems The basic characteristics of traceability systems are: - identification of units/batches of all ingredients and products, - information on when and where they are moved or transformed, - a system linking these data.

Implementation

Simply conduct one-up and one-back traceability (i.e., the ability to determine the supplier of a raw ingredient or the destination of a finished good) may no longer be sufficient to operate in today’s market. Consumers today demand much higher assurances of safety and quality.

Machine-readable identification, e.g. bar codes and radio frequency tags, has Machine-readable identification, e.g. bar codes and radio frequency tags, has been rapidly replacing or supplementing simple hand-written or labels.

Traceability is often discussed as two linked processes: Track – Track – Ability to physically locate articles or items inside a facility - to a specific location or to identify articles or items used to fulfill an outbound sales order (e.g., where it is and where it went).

Trace Trace – Ability to search historical records identifying manufacturing processes, and the source of ingredients or components, etc. (e.g., how it was processed and what was done).

Barcodes

RFID An RFID system consists of an antenna and a transceiver, which read the radio frequency and transfer the information to a processing device, and a transponder, or tag, which is an integrated circuit containing the RF circuitry and information to be transmitted.transceiverdevice transponder integrated circuit

Summary

EU General Food Law (ISO 22005:2007) The identification of the origin of feed and food ingredients and food sources is of prime importance for the protection of consumers. Traceability facilitates the withdrawal of foods by providing targeted and accurate information on the implicated products.

Record keeping for the immediate source and recipient. The origin and distribution of food and feed products are identified and government authorities can make quick response to the potential threats to the U.S. food supply. The U.S. Bioterrorism Act

The Safe Food Act The Safe Food Act further mandates the establishment of a national system for “tracing food and food producing animals from point of origin to retail sale.”

Country-of-origin labeling program (COOL) Under the mandatory COOL regulation, retailers are required to notify customers of the country of origin.

Thank you !

The amount of information that can be carried by the identification system has The amount of information that can be carried by the identification system has also been increasing rapidly; many systems can now carry > 2000 characters of information. This has implications for enhancing the operation of traceability systems.