TRACEABILITY AND MOCK RECALLS

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Penn State University

Traceability

• Ability to track food through the food system back to their source and forward to the next destination

• DOES NOT prevent a foodborne outbreak

• CAN quickly identify the source of a product and speed an investigation

• CAN limit damage to the consumer

• CAN prevent damage to the innocent grower

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Two-way information flow

Trace-forward

Trace-back

Grower Packer Distribution

center Retailer

(Store, restaurant, hospital, etc.)

Consumer Field

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Product Recalls • Recalls are actions taken by a firm to remove a

product from the market.

• They may be conducted

– on your own initiative,

– By request of your buyer,

– by FDA request, or

– by FDA order under court order.

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How to make your products traceable • Keep records of

– name of the product, – the grower – the production area, – harvest dates (or group of dates), and – where it was sent.

• Use crop production records, farm maps, transportation bills, weight tickets, and storage records to provide documentation.

• Keep records for crops that are held in storage before packing

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How to make your products traceable

Step 1 - Map all production areas

Field 1

Field 2

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Step 2 – Label all produce containers with the date and location of harvest

Field #1

Field #2

Tomatoes

ABC Farms 1 Farm Road, Anytown, PA 16803 Grown in Pennsylvania TOTAL NET WT 16 oz (1 lb)

072411-2

072411-2 Means the tomatoes were harvested on July 24, 2011 from field #2

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Grower and shipper information passed on to next buyer

Tomatoes

ABC Farms 1 Farm Road, Anytown, PA 16803 Grown in Pennsylvania TOTAL NET WT 16 oz (1 lb)

072411-2

Fresh Tomatoes

Grower information

Shipper information

Box labels show grower and shipper information

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Step 3 - Include the harvest date and location on each invoice

Tomatoes

ABC Farms 1 Farm Road, Anytown, PA 16803 Grown in Pennsylvania TOTAL NET WT 16 oz (1 lb)

072411-2

ABC Farms

1 Farm Road, Anytown, PA 16803 Phone: 808-123-4567 Fax: 808-123-5678

BILL TO: SHIP TO:

ITEM DESCRIPTION QTY UNIT PRICE TOTAL

INVOICE

T-1 Tomatoes (072411-2) 15 bxs $2.00 $30.00

Other comments or instructions

Please include invoice number on your check.

Thank You for Your Business

SUBTOTAL $30.00 TAX RATE 4% S& H $ 0 TOTAL $31.20

XYX Distributors 123 Store Rd Othertown, PA 16810

Same

Date 7/25/11 Invoice # 123456 Customer ID XYZ-312

Invoice shows grower, product, field, harvest date, date shipped

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Step 4 – Establish procedures to deal with a problem and document them • Who is in charge of traceability?

• Who will be contacted?

– Make a buyers and suppliers list using invoices and your contact lists.

– Record contact information for

• State Health Department and/or Department of Agriculture

• Attorney contact information

• Newspapers, radio, TV

• Extension food safety educator

• Conduct a mock recall at least once per year. Penn State Extension 2012

Mock Recall Example . . .

• This is just one very simple example of how a mock recall might be conducted.

• Variations depend on the audit: unannounced mock recall, time limit after shipping, etc.

• Work with your auditing company and customers for specific instructions on how to conduct a mock recall.

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Notify buyer that a mock recall will be conducted 2 days from the

present time

Identify and record lot number to be shipped to participating buyer

Day 1

Day 2

Day 3

Contact buyer and request disposition of the previously identified product lot

number (e.g. how many sold/how many still at location)

Ship to buyer

Obtain written confirmation by fax or email

Mock Recall Flow Chart (example only)

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Mock Recall – Day 1

Grower: “Hello, this is John Smith from ABC Farms. Our GAP program requires us to conduct a mock recall at least once per year.“

Grower Buyer

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Mock Recall – Day 1

Grower: “Will you help us out by participating in this year’s mock recall? Remember, this is NOT a real recall notice.

We just want to see if our plan is working correctly.”

Buyer Grower

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Mock Recall – Day 1

Grower: We will make our usual shipment to your store tomorrow. The day after that, I will call you and ask how much of that shipment remains at your location.

Buyer Grower

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Mock Recall – Day 1

Buyer: “OK, we will expect to hear from you in 2 days.”

Buyer Grower

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Mock Recall – Day 2

The product is shipped by the grower

Grower

ABC Farms

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Mock Recall – Day 2

The product is received by the buyer

Buyer

ABC Farms

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Mock Recall – Day 3

Grower: Hello, this is John Smith from ABC Farms again. We shipped our product to your store yesterday.

Buyer Grower

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Mock Recall – Day 3

Grower: “Please tell me how many boxes you have already sold and how many boxes remain at your location”

Buyer Grower

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Mock Recall – Day 3

Grower: “The lot number labeled on the boxes was 123456XXX”

Buyer Grower

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Mock Recall – Day 3

Buyer: “OK, let me check my records”

Buyer Grower

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Mock Recall – Day 3

Buyer: “According to my records, we received 20 boxes with that lot number from you yesterday.”

Buyer Grower

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Mock Recall – Day 3

Buyer: “We have 8 boxes on site and we have sold 12 boxes.”

Buyer Grower

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Mock Recall – Day 3

Grower: “Thank you. Would you please fax or email this information to me for my records?”

Buyer Grower

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Mock Recall – Day 3

Buyer: “Yes, I will send that information to you.“

Buyer Grower

Make sure the buyer faxes or emails the report using their business letterhead

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Keep a record of the mock recall !

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Buyer Contact List

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Mock Recall Log

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