In Canada, about 40 per cent of recalls are due to undeclared allergens, or mislabelling issues, not food that is inherently unsafe to consume. In those situations, it is only unsafe for people who have an allergy or sensitivity to the unreported ingredient. How did those companies get into such a recall position?
Often, it is because of an operational failing. Typically, when new products are developed they are done so with specific raw ingredients from specific suppliers. The profiles of those ingredients dictate the claims that can be made about the finished product. In the real world of manufacturing, suppliers are sometimes out of stock of key ingredients, so, substitutions are accepted. If purchasing doesn’t confirm that any substituted ingredient purchased also satisfies required claims for kosher, allergens or certifications like organic or gluten free, and your staff uses that substitute when making the finished good, you could find yourself in an allergen recall position.
Similarly, if warehouse staff accidentally picks the wrong raw material, such as non-organic whole wheat flour instead of the organic whole wheat flour, you could find yourself in a recall position. Often, such a miss-pick would not be detected by quality control staff reviewing paperwork because the picker thought he was picking the correct ingredient, and therefore carried that error forward on the paperwork. You may not discover this until you look for non-organic whole wheat flour and find less than you expected, and then you may never know which batch or batches were affected.
Clearly, these are operational mistakes, which fall under the purview of purchasing managers, operations managers, warehouse managers and production managers. Yet all too often it is only QC staff who are offered training in traceability. Are such mistakes preventable? You bet they are – through a combination of traceability training and the use of technology.
Food companies are moving beyond traditional warehouse management systems to using food specific manufacturing and warehouse management software. What’s the difference? Food specific inventory and manufacturing software doesn’t look at just items and quantities. It goes further to take advantage of GS1-128 barcode labels that include relevant segments for traceability, such as the date of expiry, and the lot or serial number information. By having the technology that can interpret these industry standard barcodes, a warehouse worker could scan a label and be alerted immediately if the raw ingredient was expired, or if they were trying to pick a raw ingredient that was not on that recipe. The one scan would capture not only the SKU, but also the lot information so no one is writing lot numbers down, removing an opportunity for human error and providing additional assurance that the right ingredients are going into the right products. For purchasers, such software could ensure that the entire allergen or certification profile of a raw material is easily accessible while they are on the phone with suppliers, so if substitution decisions need to be made, informed buying is immediately possible.
Traceability is not an isolated function; it is a whole company issue. It’s time to split responsibility for traceability between QC for the production of safe food and the operations/systems staff for the 40 per cent of recalls that they’re in a better position to prevent.
Judith Kirkness is the author of The Traceability Factor, founder of Traceability Matters and a principal consultant at Minotaur Software. Contact her at Judith@traceabilitymatters.com