Focus on Food Safety: Are you ready for the upcoming changes to traceability?

The United States is updating Section 204(d), which relates to traceability. In Canada, we should be paying close attention because any time the US makes a change, we see the impacts here whether the regulations reflect it or not.

I work with a lot of small businesses, and traceability seems daunting. The foundations of a traceability program focus on the following items:

1. Having good receiving and storage documentation practice, cataloging and inventorying incoming materials, purchase orders and bills of lading for lot numbers, and documenting receipt, storage and transfer to production.
2. Development of proper production and batch records indicating the lot numbers of specific ingredients and other inputs.
3. Application of a system for batch or lot coding (from CFIA’s durable life date coding, when appropriate), so that finished goods can be traced back to a production record. Some companies, if they have the ability in their lot coding printer, are even including production line and time of manufacture to their lot codes.
4. Registration with GS1 for a UPC or GTIN set for your goods packaging, case pack and pallet.
5. Developing a means of keeping sales records, showing who received what product, lot number or serialization block, and UPC or GTIN code.
6. Retaining records, noting that they should be kept for two years from the date of receiving product, and two years from the date of sale, and not necessarily the best before or manufactured dates.

Buy GS1

A lot of small businesses are getting into trouble for a couple things. First, it’s tempting to think you can save money buying a UPC or GTIN number from an independent wholesaler. You have to consider that for a single product, you’ll require two codes—one each for package, case and pallet. If you’ve got two to three unique products, a small business package at GS1 makes sense. Now if you have different-sized packages for the same product, each with three labels, you’ll need dozens of UPC codes.

The CFIA and other global food inspection groups are using GS1 codes as part of recall systems, making it essential to have authenticated codes. Retailers also need authentic codes from GS1. Independent retailers may not be verifying GS1 codes, but when a business scales to regional or national level, these codes are needed. I have often heard of small businesses redoing their packaging because their GS1 UPC codes were not unique to their products.

Keep records

Documentation and record keeping is another issue. Small businesses typically keep paper copies of receiving, production and shipping details. These paper copies must be organized properly so information regarding trace forward or traceback recalls can be retrieved rapidly. Electronic records are good, but ensure users are trained on best data entry practices, and keep a master code document. If you are doing electronic data management in spreadsheets, make sure to save unmodifiable versions (“marked as final” or “read only”) to prevent unauthorized users from changing records.

Before investing in a traceability enterprise resource planning software (ERP), carefully determine current and future company goals. Many small businesses will invest in an ERP only to find out that the software is not compatible with large retailers or distributors.

Potential changes

The US is likely to modify traceability based on risk profile of products. Watch for changes in the Canadian system too. For now, we’re seeing serialization on certain commodities like lettuce. This serialization allows traceability back to discrete events in manufacturing, and not just lot by lot blocks. Secondly, traceability will need to link back to critical tracking elements, such as growing, receiving, transforming, creating, and shipping. Key data elements, such as bills of lading, production records, UPC or GS1 codes, will also become essential for traceability and recall.  

Amy Proulx is professor and academic program co-ordinator for the Culinary Innovation and Food Technology programs at Niagara College, Ont. She can be reached via email at aproulx@niagaracollege.ca.

This article was originally published in the April/May 2022 issue of Food in Canada.