Traceability – finding where the product has been, where it is going, or where it is right now – is increasing in importance for the food industry for a number of reasons. Authentication – proving the product genuine or proving it fake – is also increasing in importance, especially when combined with traceability within the supply chain, which reduces the fraud opportunity. Together traceability and authentication provide transparency. When there is improved transparency the Food Safety, Food Defense, and Food Fraud risks can be minimized.
Traceability initiatives have different benefits for different objectives:
- Food Safety. There have been calls from agencies and industry for improving traceability of the food supply chain. This is reiterated and defined further in the Food Safety Modernization Act (FSMA) that was passed in January 2011 and is supported by draft rulemaking (how FDA will implement the law).
- Food Defense – Stolen Goods. The FDA has released a response to cargo theft that includes mandates for companies to be able to identify specific stock-keeping-units that have been stolen. If the company cannot identify the specific product that was stolen – and out of their control – then the company will need to recall all product in the smallest lot identifiable. For example, if three batches of products are in a load of stolen goods then all of those lots will need to be recalled. To my knowledge this has not been implemented…but it could.
- Food Defense – Attack for Harm. The attack on the supply chain, specifically adulterating food product with a contaminant that causes harm, is of special interest to FDA. The FDA Food Defense directives leverage the transparency provided by the other Food Safety related regulations.
- Food Fraud. Food Fraud is the deceptive use of food for economic gain which is based on the adulteration regulations in the Food, Drug & Cosmetics Act. Food Fraud is directly addressed in FSMA under Section 106 on “Intentional Adulteration.” The fraud opportunity is greatly reduced with increased transparency of ingredients moving through a long supply chain. As mentioned, the transparency is created by traceability and authentication.
The concept of food traceability contributing to Food Fraud prevention is something that I included in my public comments at an FDA public meeting back in 2009. My public comments were:
- Include food fraud considerations in the FDA traceability initiative as you include both food safety and food defense.
- Consider traceability programs integrated across all FDA regulated products including drug, medical device, food, cosmetics, and then all consumer products.
- It is my opinion that retailers and retail inventory management systems are a real key node, since this is the last transaction – scanning at checkout – before the product leaves the distribution system and is transferred to the consumer.
So, traceability is not a single magic-bullet to stop fraud, but it is a critical part of the Food Fraud prevention system. Traceability and authentication provide transparency within the supply chain which reduces the fraud opportunity. If you review my past blog posts you’ll see examples of how bad guys not only circumvent our protection systems, but in some cases, even use them against us. Whether it is more active tracking of lot numbers, or expanding to unit-level serialization, traceability has an important role in increasing transparency and in product protection. What you need to do is consider how a tactical program to track your products can become a strategic deterrence countermeasure. JWS.