Regulation (EC) No 178/2002 of the European Parliament and the Council, which is primarily intended to approximate the concepts, principles and procedures for the free movement of safe and wholesome food, in its article 18, introduces, for the first time with horizontal nature, for all food and feed businesses, the requirement from 1 January 2005 for a traceability system  “for food, feed, food-producing animals, and any other substance intended to be, or expected to be, incorporated into a food or feed” .

Traceability should be conceived as a system for the identification of products or groups of products throughout the whole of the food chain, especially justified for reasons of food safety, although the information obtained may be used for other purposes established by Regulation 178/2002.

Each business shall have a documentary management system which permits the identification and monitoring of the products entering, remaining and leaving their business in an efficient, effective and quick manner, so that in the event of a loss of safety in the product, the necessary measures can be adopted. One requirement that is essential for achieving the objective of this system is the total commitment of all the links in the food chain. A break in the transmission of information at any point will invalidate the whole system, rendering the efforts of all the remaining operators useless.

Although at first glance this appears to be something completely new, the management tool required in Regulation 178/2002 is implicit in the Hazard Analysis and Critical Control Points (HACCP) system which every food business is obliged to have. The management of the HACCP system, the purpose of which is to reduce the risks associated with food production and marketing, undoubtedly requires the identification of the products under the responsibility of the food business operator.

In addition, it should be noted that the application of the requirement has been brought forward by some sectors, even establishing the means, as is the case with Genetically Modified Organisms (GMO), beef, fish and fish products or eggs.

Importance of the traceability system.

Besides the legal requirement, the monitoring of an appropriate traceability system has major benefits for food business operators, consumers and the Administration.

In the event of health problems, customer complaints, production errors, etc., the food business operator is able to rapidly withdraw the products. They are also able to establish the cause of the problem and demonstrate it with due diligence, as well as decide on the destination of the products. Efficient management in the event of a crisis significantly reduces the damage to the commercial image of the brand.

Consumers feel more satisfied and confident about the products they consume, if they have the guarantee that information transparency exists throughout the food chain.

The Administration is able to act more efficiently in the management of health notifications, intoxications, etc., reducing alarm among the population, which would otherwise imply considerable damage for both consumers and the industrial sector. In addition, the Administration may place greater confidence in those establishments which have introduced a traceability system, facilitating official control activities.

How to start.

The first step may be the most difficult, but it is also the most important. A detailed review is required of all the registry systems and processes performed at the establishment, assessing their possible use.

In some cases, we may find that all the necessary activities are already being performed, for example, under the framework of the HACCP system, the entry and exit records-books, or the control of suppliers. Nevertheless, the majority of times we will find that it is necessary to adapt or incorporate procedures specifically for the purposes of traceability.

Suppliers and customers, the managers of other establishments, auditors and the competent authorities should be contacted.

Procedure:

Although the procedure may vary depending on the bibliography consulted and, in any case, it will be specific and decided by the manager of the establishment, the four steps necessary to establish a correct traceability system are laid out below.

Define how the products are to be grouped:

Each business should group the set of units which produces, manufactures, packs or, in broader terms, handles and, identify it.

The criteria for grouping products may be multiple and specific to each establishment. Examples of these include the time period (weekly, daily, by time of manufacture), the production line, place and date of capture (in the case of fish), etc.

The degree of precision with which the products are grouped together will determine the size of the group and should be defined by the business, seeking the maximum equilibrium between the reduction of risks in the event of a product safety incident, and the excessive economic and handling complexity brought about by greater precision.

The next decision consists in how to identify the group which has been defined according to the activities carried out and the circumstances which come together at the establishment. There are multiple methods, from simple handwritten labels to all the computer technologies available today (bar codes, radio frequency chips, etc.).

Whatever the identification type used, the reaction time should be kept to a minimum, permitting the product leaving the business, the products involved and the production and marketing processes adopted to be quickly linked together.

Define the sphere of application (backward, process and forward)

Backward traceability will permit, from an intermediate or end product, the relevant information associated with the product to be efficiently obtained, until reaching the origin of the raw materials. Points to be considered in each business include the name and address of the suppliers, the goods received with their identification, number of units and the date of minimum durability or the date of receipt.

Process traceability permits the products entering a business to be linked to the products leaving a business. It is necessary to consider the divisions, changes or mixes of batches or groups, and the number of points at which it is necessary to establish records or links to the self-control system already established. Relevant aspects at this point include the identification of the products obtained as a result of the operations developed in the business, from which products, number of sales units produced or which processes have been completed and when.

Forward traceability will provide information about where a certain product has been sent. With this, starting from a raw material it is possible to find out the end product of which it forms part. The names and addresses of the customers, the goods distributed and the date of departure from the establishment should be recorded.

Although the scope of application of the traceability will depend on the activities of the business, in general terms, backward traceability will be necessary whenever there is a supply of products from a supplier, and process traceability whenever there is any type of combination, mixture or division of the batches or groups of products received. Forward traceability can only be omitted when the products are exclusively intended for the end consumer.

The responsibility of each food and feed business with regard to traceability ends when the previous link and the subsequent link are identified in relation to a specific product placed on the market. The food business operator is not expected to know the complete path taken by a raw material until it becomes an end product, but only what occurs within their own sphere of activity. The sum of the information provided by each and every one of the operators involved in the chain provides information about the complete history of the product.

Define the necessary documentation

The filing system chosen from among the wide range available in the market should permit a rapid reaction in the event of an incident. It should be noted that the record maintenance system within the HACCP system may be of assistance when assembling the traceability system.

The description of the system includes the criteria for grouping the products, the sphere of application of the plan and its general characteristics. All documentation relating to the products (raw materials, intermediate products and end products), to the marketing (suppliers and customers) and to the activities generated as a consequence of the procedure for the verification of the system should be registered.

Establish mechanisms for verifying the system

The simulation of a health notification would be practical during the regular review to ensure that the traceability plan is being applied correctly. To do so, select a product at random and try to determine the raw materials involved and, to the contrary, randomly select the documentation for a raw material and try to find out the product in which it was used and its distribution.

Key points:

• A good traceability system must permit rapid and effective action in the event of a problem during the production and marketing of food.
• The method used to define and identify the product groups is of particular importance.
• All the elements of the chain should be involved. In the event of a break, the system is rendered inefficient.

Remember:

Regulation (EC) No 178/2002 of the European Parliament and of the Council, of 28 January 2002, laying down the general principles and requirements of food law, establishing the European Food Safety Authority and laying down procedures in matters of food safety. Official Journal of the European Communities 1.2.2002.