Журнал пищевой промышленности и технологий

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Product Traceability in the Age of the Food Safety Modernization Act

Delano A Chambers, Paul Gyles

In the age of the Food Safety Modernization Act (FSMA), if hazard analysis identifies a hazard requiring a preventive control, the facility must have a written recall plan describing the procedures to perform a recall of the product. At the heart of this prerequisite lies the ability to perform product trace one up to customers one back to suppliers (one up/one back) which were lacking, resulted in the mountainous paper trail with convoluted records, and long mock recall sessions. With limited product trace, the scope of potential product implicated in mock recall sessions could cripple brand and business in real recall sessions. Of such, a real-time product trace approach was sought using purchase order numbers. While unique to each company, purchase order numbers once issued has quantity, description, date, and time tied to each issued number, a good candidate for such task for bulk handling process. Customer issued purchase order was paired with internal purchase orders issued to suppliers and vendors. Supplier/vendor-issued purchase order number was paired with internal issued numbers, resulted in one of four methods to retrieve full history using customized user interface: the customer purchase order number, the supplier/ vendor-issued purchase order number, internal purchase order number, or date range. Results produced in seconds compared to the former approach of hours and days. Significantly reduced the gap and scope of the potentially impacted product. The approach successfully demonstrated in regulatory, customer, internal, and voluntary audits such as Safe Quality Food Program (SQF) since implemented March 2019. If the employee failed to move raw material to the customer sales order by scanning, or manually if scanner inoperable, then product trace would be lost, and of such, controls implemented to ensure orders cannot be closed without accountability. Time saved now focuses on further improving the process, customer, and supplier relations.