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
Exclusion and Restrictions: Understanding Employee Health and the Food Code
I received a call earlier in the month from a foodservice operator who suspected that one of their employees may have fallen ill and wondered if they had to send the employee home for the day. Once I started to ask a few more questions, it became obvious that the operator wasn’t really in-tune with the food code requirements on restrictions or exclusions for employees who may not be feeling well. Given that most operations are dealing with staff shortages currently and the fact that we are about to head into the fall and winter – when we tend to see an increase in upper respiratory and other illnesses, such as the flu - it seemed like a very timely and important topic for the blog this month.
Cross Contamination and the Surfaces that go Unnoticed
In October, I ran across a new research study published in the Journal of Food Protection in early-September. The article explored cross contamination in consumer kitchens during meal preparation. One of the authors was a previous SafeBites presenter, Dr. Ellen Shumaker, at North Carolina State University. Although the setting was consumer kitchens and not the commercial kitchen many of you deal with daily, the findings were very applicable to what we often see in the foodservice setting.
Emergency Preparedness: The Not-so Calm After the Storm
If you and your foodservice operation have been hit by an emergency or other disaster, what comes next and how do you move forward? Much of the answer to this is predicated on the actual disaster that you are dealing with – a flood is certainly a much different than a fire, but some of the food safety considerations remain the same if your business has been left intact and has not been damaged by the disaster.
Emergency Preparedness and Responding to a Disaster with Food Safety in Mind
As I write the first blog this month, the realities of the devastation in Florida are coming to light as we also deal with the aftermath of Hurricane Fiona, which impacted Puerto Rico late in September. Recent news has been focused on the recovery efforts for all who have been impacted. Thus, I thought it would be fitting this month to discuss emergency disaster planning resources in our first blog and delve into recovering from a disaster in our second blog later this month.
