Do we really have adequate collaboration between rules based organizations such as the FDA
Do we really have adequate collaboration between rules based organizations such as the FDA, EPA, USDA, Consumers Union and the like?
This author spends many hours weekly if not daily researching supply chain issues that impact consumer safety, corporate earnings, the environment, productivity and other emerging conditions. One tool I use regularly is Google. In a recent search, I entered 10 + 2. The response I received was Search for documents containing the terms 10+2. Answer, 10 + 2 = 12, more about calculator. Obviously from a supply chain perspective this is not what I was looking for.
I only mention this to point out that in order to get to the answers one is looking for within a reasonable amount of time; one must have some idea where to look and what questions to ask. When we talk about product traceability within the supply chain, we have a similar issue. We do not ask the right questions or know where to go for the best answers in the shortest amount of time even if we have the right questions.
When addressing food born illness issues, the FDA advocates one forward one back traceability. Under current rules adopted under the Bioterrorism act of 2002 it is required that produce processors and distributors keep track of where food goes and comes from, but only one step forward and one step back in the supply chain. This means we know who bought it and we know who sold it. Obviously this is not adequate.
Let?s take a look at another agency and the controls they have in place. U.S. Customs and Border Protection are requiring additional data from U.S. importers and carriers to support 10 + 2. The Importer is required to submit 10 additional pieces of information which are: Manufacturer, Seller, Consolidator, Buyer and Ship to names and addresses, Container stuffing location, Importer and Consignee record numbers, Country of origin of goods and the Commodity Harmonized Tariff Schedule number. The Carrier will need to submit 2 additional data sets which are: Vessel Stowage Plan (or BAPLIE), and Container Status Messages.
The CPB or U.S. Customs and Border Protection needs to be congratulated on this level of traceability. It is however time for this type of data to be part of one data stream. When a food born illness such as the St. Paul salmonella outbreak occurs, ten plus two data linked to one forward one back data might just result in much quicker resolution to the outbreak and save our investigators days and months of expensive investigation time.
We appreciate and look forward to your comments.
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