Congress renews calls for reform of food safety laws.

January 20th, 2009

As a result of the most recent Salmonella outbreak

As a result of the most recent Salmonella outbreak, there has been renewed activity from congress to reform food safety laws. The FDA?s lack of authority to order a recall of products versus asking companies to do so is just one example of the type of issues driving this activity.

This author does not necessarily agree that the government needs to be involved in regulating these issues because they generally tend to overreact, which can have a negative impact on the many individuals and companies associated with the traceability chain affected by this type of oversight.

Problematic to coming to a rapid determination of cause in these types of outbreaks is the lack of a traceable supplier and product database that all parties in the supply chain adhere to.

Traceability matrices can be easily established using a variety of tools including requirements management software, databases, spreadsheets etc.

A traceability matrix is created by associating requirements with the work products that satisfy them. Tests are associated with the requirements on which they are based and the product tested to meet the requirement.

Present food traceability standards call for one forward one back reporting. As such, let?s take a look at the first step in forming a traceability matrix as it applies to the most recent Salmonella outbreak. And, why one forward one back is a problem.

The following is a very simple example of ten possible traceable elements that could be associated with the most recent salmonella outbreak. Each individual element could contain a tree of it?s own that delays the FDA and other organizations from quick resolution.

1. Seed crop
2. Farm
3. Peanut Corporation of America
4. The Kellogg Company
5. Multiple Products
6. Multiple Wholesalers
7. Multiple Retailers
8. Multiple Consumers
9. Spread
10. Family & Friends

Let?s assume that the first person taken ill came from category ten, friends and family. This individual consumed a tainted product made with the peanut paste that contained Salmonella. Where was the product consumed? In fact, what product was it? Was it consumed at home, at school, at work or maybe at a friend?s house?

We can get to one back once we?ve determined the source of the actual illness. Then we can proceed to the next element of the matrix which could be multiple retailers who may have sourced the product from multiple distribution channels such as distributors, wholesalers, collective buyers etc.

This becomes a vicious cycle pretty quickly. It might be at this point that the government would call for a product recall. We?ve seen the negative impact that can have on the entire retail supply chain. A better action for congress would be to mandate that a data repository be developed that follows a product from seed crop in this example to the consumer.

There must be a grant out there somewhere for this type of effort.

As always we look forward to and appreciate your comments.

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