food recall and traceability -...

Food Recall and Traceability

Usa Bamrungbhuet

National Bureau of Agricultural Commodity and Food Standards

Inception workshop

“Principles and further activities for Codex implementation of International Food Safety Standards in ASEAN Countries”

17 – 19 September 2012, Royal Princess Hotel, Bangkok


• Consumer concerns about food safety have increased.

• This is a result of various events relating to food safety.

• An outbreak of food poisoning caused by the E. coli 0157:H7 in 1996

• Outbreaks of disease in animals that could be transmitted

to human

• The presence of chemicals above acceptable limits in food

and feed , can threaten both the quality and safety of the

product.

• A number of crisis concerning food safety and quality and their effect on consumer health have dented confidence in foodstuff.

• In some cases food trade has also been severely disrupted and the export of food products has been prohibited.

• These problems have had wide-ranging impacts throughout the food chain, and have brought about substantial reform in food production, regulation.


• Food Recall “ The action to remove food from the market at any stage of the food chain, including that possessed by consumers”

• Traceability/product tracing (T/PT)

“ The ability to follow the movement of a food through specified stage (s) of production processing and distribution”


Codex Standards Related to Food Recall

• General Principle of Food Hygiene (CAC/RCP 1- 1969)

• 5.8 Recall Procedures :

• Managers should ensure effective procedures are in place

to deal with any food safety hazards and to enable to

complete, rapid recall of any lot of the finished food from

the market. Where a product has been withdrawn because

of an immediate health hazards, other products which are

produced under similar conditions, and which may present

a similar hazard to public health, should evaluated for

safety and may need to be withdrawn. The need for public

warnings should be considered.

• CAC/RCP 1- 1969(continued)

• Recalled products should be held under

supervision until they are destroyed, used for

purposes other than human consumption,

determined to be safe for human consumption, or

reprocessed in a manner to ensure their safety.


• Other Code of Hygienic Practices

Code of Hygienic Practice for Eggs and Egg Products (CAC/RCP15 – 1976)

Refer to the General Principles of Food Hygiene

Code of Hygienic Practice for the Transport of Food in Bulk and Semi – Packed Food

Refer to the General Principles of Food Hygiene and, as appropriate, other Codex Codes of Hygienic Practice shall be applied.


Proposed Draft Principles and Guidelines

for National Food Control System

In order to respond to food safety emergencies, consideration should be given to the establishment of a national food safety emergency plan with establishment of a coordination arrangement with links to public health authorities, law enforcement and intelligence agencies, food recall systems, risk assessment specialists, the food industry, and others.

The national food control system should have procedures covering the prompt removal of unsafe food. These procedures should ensure that products that are deemed to be unsafe should be recalled, appropriately dealt with to ensure consumer protection. Where distribution has occurred, appropriate consumer notification should be given.


Proposed Draft Principles and Guidelines

for National Food Control System

Recall systems and other market withdrawal systems should be a coordinated effort between the national government and food business operators. If the competent authority requests a recall, operators should have an affirmative duty to recover recalled products and to destroy or dispose of them properly. National laws should include penalties for companies that fail to comply with recall requests.

In order to promote consumer confidence in food safety and ensure fair practices in the food.


Codex Standards related to T/PT

General Principle of Food Hygiene (CAC/RCP 1- 1969)

9.1 Lot Identification

Lot Identification is essential in Product recall and also helps effective

stock rotation. Each container of food should be permanently marked

to identify the producer and the lot. Codex General Standard for the

Labeling of Prepackaged Foods

9.2 Product Information

All food products should be accompanied by or bear adequate

information to enable the next person in the food chain to handle,

display, store and prepare and use the product safely and correctly.

• An Issue in CCFFP, TFAF,

TFFBT, CCFH, CCFL,

CCFICS, CCGP,

Regional Codex Coordinating Committee


CCGP

Codex Definition

CCFICS

Codex Principle


• Discussion in CCGP

The place of traceability in risk management

The use of traceability for product integrity,

authenticity and identification

The use of equivalent measures

Practicability of its application in developing

countries

Consumer confidence and information

concerning the nature and origin of products


• High costs reason for applying

• Extent in consumer health

protection

• Ensuring fair trade practices


The extent in consumer health protection

• To consider as part of food safety risk management

• To achieve ALOP from that risk

• Other appropriate measures achieve the same ALOP

and less costly

• To apply to some part or throughout the food chain

• As a case-by-case basis depending on the nature of the

risk and ability to manage


Ensuring fair trade practices

• Country of origin

• Organic farming

• Religious concerns such as kosher or halal

• Animal welfare

• Environment


Question of how to achieve ALOP or legitamate

objective

• What are the modalities?

• What information needs to be transmitted?

• When and how to integrate into international

regulatory?

• Practicability in developing countries?


Question of how to achieve ALOP or legitimate

objective

• Need justifications for food safety and their economical

practicability in developing countries.

• Take into account other measures for food safety risk

management process achieve same ALOP and may less

costly or more appropriate in a given situation.

• To consider the tracing of the products as an additional

tool only for the cases when a risk to human health has

been identified


• The 27th CAC (2004) has adopted T/PT

Definition

Traceability/product tracing (T/PT)

“ The ability to follow the movement of a

food through specified stage(s) of production processing and distribution”


• CCFICS

Set of Principles of T/PT

concerns that members have raised with respect to T/PT

the scope of the principles with respect to both food

safety and fair practices in the food trade;

mandatory versus voluntary application of

traceability/product tracing; and

the rationale for when and how to apply

traceability/product tracing.


• The 29th CAC (2006) adopted “ Principles

for Traceability/Product tracing as a tool

within a Food Inspection and Certification

System (CAC/GL 60-2006)


PRINCIPLES FOR TRACEABILITY / PRODUCT TRACING

• A set of principles to assist competent authorities in utilizing traceability/product tracing as a tool within their food inspection and certification system.

• May be applied, in order to contribute to the protection of consumers against food-borne hazards and deceptive marketing practices and the facilitation of trade on the basis of accurate product

• Is one of a number of tools that may be utilized by a competent authority within its food inspection and certification system

• may apply to all or specified stages of the food chain (from

production to distribution), as appropriate to the

objectives of the food inspection and certification system.

• should be able to identify at any specified stage of the food

chain (from production to distribution) from where the

food came (one step back) and to where the food went (one

step forward), as appropriate to the objectives of the food

inspection and certification system.


• does not of itself improve food safety outcomes or promote fair practices in food trade, i.e. it must be

applied in combination with a measure or requirement

• ensuring the implications of implementation are fully considered (i.e. especially for developing countries

• the exporting countries should not have to replicate the traceability/product tracing tool of the importing country, it

need only meet the objectives of the importing country’s food inspection and certification system


The Need for further Guidance on

Traceability/ Product Tracing

• A questionnaire where developed to gather

information on member countries experiences of

developing Traceability/Product Tracing

requirements,

• Some of the comments received indicate that

there is a strong present need for further

guidance, while other comments point out that

development of guidelines, including identifying

potential gaps at this point is premature.

The Need for further Guidance on

Traceability/ Product Tracing

Comments have been given which point out some elements of importance that need to be considered if guidance should be developed, for example;

• Guidance should be developed based on practical experiences;

• must accommodate the various approaches used by countries;

• must accommodate the wide spectrum of systems (electronic and non-electronic) used for T/PT; and

• Must provide flexibility for future developments in the field.

• should be feasible even for medium-sized or small companies, rather than only major companies.

Implementation of food recall

and Traceability across the food chain

• Purpose of a Food Recall

there is rapid removal of unsafe food from all

possible stages of the supply chain;

the concerned consumers and customers are

informed; and

the food under recall has been retrieved, destroyed

or reprocessed

• Traceability is an effective tool with which food

business operators can trace food throughout

the food chain.

• The most common legal requirement is for food

business operators to have, as a minimum, a

documented one-step-back/one-step-forward

traceability approach.



• In the context of a food recall, the objectives

of traceability are to:

identify uniquely a lot/batch/consignment of

food in a way that allows tracing of the physical

flow of the food forwards through the food

chain to the immediate customer and tracing of

the physical flow of raw materials backwards to

the immediate supplier;



• In the context of a food recall, the objectives

of traceability are to:

create and maintain accurate traceability

records that can be provided within a short time

period when needed for recall or at the request

of the competent authorities.



The first priority is to identify where the food has

been distributed (trace-forward activities).

This ensure rapid cessations of the use, distribution

and sale of the food to be recalled.

Following the initiation of trace-forwards activities,

trace-back activities should occur in conjunction with

the recall, to identify any other implicated food



Trace-forwards activities

The purpose of trace-forward activity is to identify the

physical location of the affected product in the food

chain.

The objective of the trace-forward process is to obtain

the most complete list of possible of all customers or

entities that received the affected, and to inform them

about the recall and the actions that are expected of them

in order to remove the product from the market.



Trace-back activities

The purpose of trace-back activity is to determine whether there are other products on the market or in the food supply chain that may have been affected by the same hazards as the food subjected to the recall.

The competent authority should work together with the food business operator to ensure that a trace back investigation is performed to ascertain that there is no other affected food on the market.



Conclusion

• T/PT has been proven useful, once there is an ability to trace a product that can be traced for whatever purpose.

• T/PT has the benefit however of being applicable to the management of previously unforeseen or unidentified risks which makes it an important tool.

• A number of countries have chosen to incorporate the T/PT tool in the food legislative framework for use by the competent authorities.

• Codex has developed a definition and a set of principles for national authorities.

Further consideration

Whether guidance on T/PT should be

developed or not ??

• FAO/WHO Guide for Developing and Improving National

Food Recall Systems

• Report of the Eighteenth Session of the Codex

Committee on General Principles

• Report of the Twentieth Session of the Codex

Committee on General Principles

• Report of the thirteenth Session of the Codex Committee

on Food Import and Export Certification Systems

• Report of the Fourteenth Session of the Codex

Committee on Food Import and Export Certification

Systems

•

Reference

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