The mandatory requirement for a traceability system was introduced into our legal framework in the food industry in 2018 when R638 REGULATIONS GOVERNING GENERAL HYGIENE REQUIREMENTS FOR FOOD PREMISES, THE TRANSPORT OF FOOD AND RELATED MATTERS, a regulation under the FOODSTUFFS, COSMETICS AND DISINFECTANTS ACT, (ACT 54 of 1972, was promulgated in June.
Although this regulation had been in the legal pipeline, its promulgation was nudged along by the Listeriosis outbreak. While this was the world’s single largest outbreak of Listeriosis, it also highlighted dramatically the need for an effective traceability system. This requirement was emphasised recently with a similar scale recall of canned pilchards.
Recalls on the increase – worldwide
Recalls are not an uncommon activity. In fact, recent research reviewing recalls around the world by Soon et al. 2020, they showed that over the decade spanning 2008-2018, they are increasing.
Undeclared allergens remain the top culprit followed by food contaminated with biological hazards.
The important question is when will it be your food facility?
The legal pressure on food and beverage manufacturers to track and identify every single ingredient used in the manufacturing process; from receipt of initial ingredient, seed, foodstuff, animal – and its feed, additive or raw material; through the entire manufacturing process; to packaging and shipping the end product to the customer is an international trend. This coupled with customers demanding more visibility in their supply chains should be prompting South African manufacturers to seek out solutions. Our experience – there is very limited uptake for this essential system even after the new regulation has been enforceable for nearly a year.
What are some of the reasons for this concerning inertia in the market?
- The task appears overwhelming?
- There is no legal enforcement taking place?
- There is no pressure from the customer?
- There is a misconception that this will be a costly exercise?
Relying or waiting for external pressure and/or enforcement is not advisable. The costs associated with our policy and pilchard recalls would have covered the costs of an effective ERP system many times over and recall costs are not something you can budget for, or even survive as a business.
Yes, it can be a complex web to unravel but there are service providers like SYSPRO that can assist in breaking down a complex puzzle into manageable projects and working with you and your team to implement a workable effective system.
What needs to be put in place to be able to track the entire supply chain?
Working together we need to Identify elements required to ensure that the system encompasses the full traceability of the product. This means breaking it down into three components:
- Supplier Traceability – Evaluate the scope required to incorporate traceability of suppliers and their products entering the organization.
- Process Traceability – Evaluate the scope required to incorporate traceability of products through the organization (whether new products are produced or not).
- Customer Traceability – Evaluate the scope required to incorporate traceability of products to the immediate customer.
An ideal traceability system will encompass all three of these but it’s best to start somewhere and then build the system with the ideal end goal in mind. Of course, there may be challenges to navigate and our experience has shown us that there is not a one-size-fits-all approach as different sectors of the value chain will develop traceability systems that differ in scope. We do realise that in many global companies, communication regarding processes, legislation and production methods between regions is poor or non-existent. This means that the problems typically occur where there is no seamless interface between supplier, process and customer. The scope is critically important and becomes a commercial decision – the broader the definition of a batch, the greater the volume of product potentially recalled so you must think carefully about your existing practices – it may be easy to record a batch as a day’s production, but what will that cost you to bring back?
The objective of an effective traceability system - allow you to react quickly…when the urgency of a recall and the media are breathing down your neck.
Use our checklist to test your current systems:
- Can you define ALL your suppliers and control purchasing from them to ensure only approved vendors supply approved products?
- Can you control and monitor changes to your products to ensure you know if ingredients were replaced for some reason such as out of stock?
- Can you control the stock in your warehouses, FIFO, what is on hold for quality inspections and what is nonconforming and may not be used? Does your system physically prevent the issue of this stock?
- Can you track which batch number of an ingredient is used in a batch of your product and when that ingredient was received and released for use?
- Can you trace a batch of product sold to a customer, including sales orders and batches still in the warehouse? Can you match this to suppliers and orders?
- Can you quarantine affected product and prevent it from being shipped?
- Does your current system allow you to rapidly contact all customers and inform them of the recall and keep records of this vital communication?
- Can your system give you reports of the status of the recall so you can keep track of the progress and report to the regulators on the effectiveness of the recall?
- Does your system allow you to practice mock recalls and keep of record of these for continuous improvement management?
- Does your system allow you to track and monitor customer complaints for trends thus allowing you to trigger a recall proactively rather than waiting for a crisis?
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If this quick assessment highlights some weaknesses in your current system, then you may be exposed to real business risk that your recall system could fail you when you need it most. Considering we are dealing with human health, this is probably not something you want to have on your conscience which is why as should be complying with the legal requirement for full traceability – it is just the right thing to do.
About the author
Deirdre Fryer is the Regional Product Manager for SYSPRO - Africa.
She has a focus on understanding customer requirements and driving product improvement
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