Food Traceability in Foodservice Operations: An Essential, and Soon-to-be Required, Component of your Food Safety Plan
In June, I discussed the importance of having a solid food defense plan, and I provided you some resources for developing or strengthening your food defense plan. As I was writing those blogs, my mind kept turning toward food traceability. While they are distinctly different concepts, food traceability goes hand-in-hand with a food defense program. I would argue for your food defense plan to be effective, you must have an effective internal food traceability program, where you can trace the product back to the supplier (backward traceability), but also be able to trace the product from the supplier to the guest who was served the product (forward traceability).
Forward traceability is often the most difficult for foodservice operators. If you are a commercial restaurant operator, this can be extremely difficult if the guest pays with cash, where you have no records to track who dined in your establishment, let alone what food they may have consumed. In schools and other on-site feeding establishments, it can be made difficult due to the sheer number of guests/students fed daily. You might be able to track who dined in your operation on a particular day, but it generally gets a bit more complicated when you try to answer the question of which guests had a certain product from a particular case or lot number.
For several years, the U.S. food supply was only required to have a one-step forward and one-step back traceability. This meant you had to know where your product came from and where it went once it left your operation. The Food Safety Modernization Act provided the groundwork for the Food and Drug Administration to designate foods for which additional record keeping is required to protect the public health. The New Smarter Era of Food Safety Blueprint, laid out by the Food and Drug Administration included improved traceability as one of the four key elements, along with smarter tools and approaches for prevention and outbreak response, new business models and retail modernization, and food safety culture. These four elements serve as the building blocks for a more digital, traceable food system.
If you think that the changes to traceability will not impact your foodservice operation, think again. While it could still change, I would expect some changes to be coming to the traceability landscape for foodservice operations in the coming years.
If you think that the changes to traceability will not impact your foodservice operation, think again. While it could still change, the proposed rule provides only a few exemptions for foodservice operations. Two of the exceptions require the foodservice operation to have 10 or fewer full-time equivalent employees. Another partial exception is in place for schools who participate in farm-to-school programs under the guidance of USDA, but the rule would require them to maintain records of where the product was sourced for a minimum of 180 days.
Fundamentally, the proposed rule would require those who manufacture, process, pack, or hold food on a designated food traceability list to establish record keeping data of key elements associated with various Critical Tracking Events. Foods currently on the list are included in the table below.
The end goal of the Food and Drug Administration is to improve the tracking of food to enable end-to-end traceability. To achieve this, records for food product will need to be linked. If a foodborne illness outbreak were to occur, the foodservice operation would be required to provide traceability records in the form of an electronic, sortable spreadsheet to the Food and Drug Administration within 24 hours.
While the proposed changes are currently just that – proposed, I would expect some changes to be coming to the traceability landscape for foodservice operations in the coming years. If the proposed rule is accepted, it would become effective 60 days after publication in the Federal Register. Compliance date for the food industry would be two years after that date.
If you would like to learn more about food traceability, why it is important, how some foodservice operations have embraced traceability, and some tips on getting started – join us for our July SafeBites webinar where I will be presenting more information on Traceability. It is scheduled for July 21 at 1:00 pm. We would love for you to join us.
I hope you have a great 4th of July weekend. Be safe as you travel and enjoy family and friends. Risk Nothing.
[1] Source: Food & Drug Administration. (2021, July 1). FSMA Proposed Rule for Food Traceability. Food Traceability List. Available at: https://www.fda.gov/food/food-safety-modernization-act-fsma/fsma-proposed-rule-food-traceability
Keeping Food Safe While Serving Outdoors
This afternoon I met some friends for lunch and as I drove through our beautiful downtown area in Manhattan, KS, I noticed that many people were taking advantage of the gorgeous weather and dining outside with friends. For our local community - outdoor dining is one of the remnants of COVID that we actually have come to enjoy on beautiful days. With spring in full swing and summer just around the corner, many foodservice operations are taking advantage of the warm weather by offering outdoor dining options.
The Importance of Air Gaps in Providing Safe Food to All
Late last month, I was exploring job tasks that are important for entry-level foodservice managers to understand related to food safety. The usual items that you would suspect were on the list were certainly included – foodborne outbreaks; temperature danger zone; physical, biological, and chemical contamination; personal hygiene and proper glove use; HACCP systems, etc. But one thing I noticed was missing that really is integral to protecting the food supply in any foodservice operation is air gaps.
Flour Safety: Don’t Let E. coli become the Secret Ingredient in your Cake.
Earlier this month, we started to see information coming out about a foodborne illness outbreak from an unlikely source – flour. As of early-April, 12 people had fallen ill, and three people had been hospitalized as a result of flour contaminated with Salmonella. While the outbreak is still in its early stages, no individuals have died because of their illness. A specific source has not yet been identified in the outbreak, but all who have fallen ill have reported eating raw batter or dough due before developing symptoms – and flour has been identified as the only common ingredient in these batters and doughs.
Be Proactive and Don’t End Up in Food Safety Jail!
Ok, I admit – there really is no food safety jail. But there is jail and, while it is uncommon, you can be sent there for not practicing food safety. Just the other day, I ran across a news report about two individuals in Wales who were sent to jail (albeit a suspended sentence) for “failing to take action to protect food from the risk of contamination; placing unsafe food on the market; failing to comply with a Remedial Action Notice and operating the business without approval after permission to supply seafood was suspended.”
