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
Getting Started with Building the Infrastructure
Hopefully in our first January blog, we convinced you of the importance of establishing an infrastructure within your operation to support a safe food culture. So, how does one go about doing this? Well, like any major project, break it into small bites. In our opinion, having a written guide for employees that documents expectations related to food safety basics of employee health and hygiene, temperature controls, and cleaning and sanitizing is the first step. Having this documentation serves as a reference for training and helps fulfill the mission of most foodservice operators which is to serve safe, quality food.
Food Safety Resolutions for the New Year
Finally, 2020 is in our rearview mirror and we can all turn the page to 2021! Resolutions for the new year might be more of the same from prior years (lose weight, exercise more, less screen time, etc.) OR you may have identified new practices to implement in your operation. If the latter, likely goals included some practices related to food safety – especially given the turmoil of 2020 and heightened concern by customers. It is our philosophy that attention to safe food handling practices is a win-win for any operation because of the direct relationship between food safety and food quality, which in turn leads to customer satisfaction. This past year has also demonstrated that attention to safety can affect the bottom line. Thus, the topic of our first SafeBites webinar for 2021 is on the topic of the return on investment of food safety, it is scheduled for January 20, so register now and please plan to attend.
To Toss or Not to Toss? That is the question.
Our first blog for the month emphasized the basic safe food practices needed to keep you and your guests healthy (and happy!), especially during these times of COVID. The impact of foodborne illness can range from an uncomfortable few days to hospitalization or death. Foodborne illness IS preventable and the steps taken to keep food safe also maintain quality of food, and ultimately profitability. Think of attention to food safety as part of quality control and a win-win business strategy. Knowledge about food safety can be helpful when controlling costs as making wise decisions when determining the fate of unserved food can affect the bottom line.
Holiday Food Safety Controls
In case you have not noticed - the holidays are here! We have seen store decorations up since mid-September and early bird deals advertised for several weeks, stretching the typical Black Friday deals throughout the month as retailers strive to ensure market share, while following increasingly stringent mandates for physical distancing
