One of the difficulties in doing traceback in the tomato segment is the role of repackers. There has been much talk about the role of these firms as a kind of “black box” in which product enters as a thoroughbred with clear traceable pedigree and leaves a kind of mongrel with parentage difficult or impossible to trace.
There is a certain element of truth here — it is certainly far easier to track product if it stays in one state and is sold directly from shipper to retailer or foodservice operator. And it is probably true that the trade’s traceability initiative, which we discussed both here and here, should pay attention to this link in the chain as it is equivalent to a “critical control point” on where traceability can fail.
However, it is nothing new or particularly different. The best way to think about repackers and the repacking process is the way we think about fresh-cut processors and the processing process.
Early in this Salmonella Saintpaul/Tomato situation, we ran a letter under the title Pundit’s Mailbag — Look At Lot Size from “Banana Jim” aka James D. Still, the founder of Thermal Tech, who made the point well:
“…the real issue, I think, is one of ‘lot size management’ … With the spinach outbreak, the lot size was the entire industry…”
This reminded us of an interview we ran with Michael McCartney, who is now with Naturipe. In the interview, which we entitled, Getting A Better Grasp on Traceability, Michael emphasized the importance of physical separation to traceability:
“You can’t do traceability if you don’t have a unique product identity already established.
Once product arrives, how do you separate each lot or bin or farm? The only way to do this is to create a time gap. If three farmers supplying the same product each have a unique identity, all bets are off once the food processor dumps the product in bins and it’s all blended together. It can happen like this now. If there isn’t a gap between your produce and mine, we lose our identity. We lose our ability to trace back. If an inquiry comes in, we have to look at a three-farm recall instead of a single farm, and what comes before and what comes after.”
In other words, if a processor simply had its lines running forever and kept dumping raw product into the process, it can have perfect “traceability” in the sense of perfect records but exceedingly large recalls.
To limit the scope of recalls, the processor has to have a system for A) Knowing precisely which farm’s product wound up in each bag, and B) A sanitation process that ensures a figurative “brick wall” between different lots. In other words, a process so that if lot 2 is confirmed to have E. coli 0157:H7 or Salmonella Saintpaul, you don’t have to recall lot 1 or lot 3.
There are two key things to note here:
First, the word “lot” is often used in the industry with a meaning that is different from what the word means in a food safety sense. Often the lot is an arbitrary number, say every thousand boxes. This may be adequate for commercial purposes, but we are really looking, in a food safety sense, for lots that share common characteristics.
Second, there is not a “correct” or “incorrect” lot size. If traceability were the only value, we would ask a processor to sanitize his line, process the romaine that came from one plant on one row of one field of one farm and then re-sanitize before doing the next plant. This would, of course, be too expensive and, since we value both traceability and providing fresh food at a reasonable price, we understand that processers can’t practically provide that level of traceability.
Can the processor do just a row? Just a field? Just a farm? Do they need to combine the production of two farms? This is a business decision, but we need to recognize that the smaller a meaningful “lot” we can use, the more likely we can minimize the extent of a future recall.
The way to think of a tomato repacker is as a fresh-cut processor without all the cutting. The repacker brings in tomatoes from many places and sends out a “new product,” which could be seen as a boxed tomato “blend” and the issues are similar to those with a processor.
The base of traceability is keeping records of what came in and what goes out — almost all repackers do this already.
The next step is having more detailed records and business practices designed to reduce the size of any recall. In this case, the repacker needs to identify what “inputs” or source material may be associated with a given lot or shipment sold to a customer. Here many repackers could do a much better job. It means opening a repacking line, assigning dedicated product to it and having the inventory controls to make sure nothing is inadvertently added to that line.
Finally we have to look at sanitation. All major fresh-cut processors are deeply conscious that they are food processing plants, not produce packing sheds. Not all tomato repackers have that culture. Unfortunately this means that for anything that might be spread from product to product or via some leakage from a product, it becomes impossible to get a start and finish date. There is no way to be certain that contamination, if it existed, had to stop at this point.
The effect of all this is that if a restaurant chain bought from only one source — call him Tomato Repacker A — what starts out as a simple traceback can become a complicated one. That one repacker may have bought over the outbreak period from 20 packers, each of whom at various times over the outbreak period received product from 10 different farms. Thus one repacker as a supplier can easily mean 200 farms to investigate.
- Many of the repackers need a new consciousness about their role in the traceability system and should look hard at their operations to see how they can limit the scope of traceback in the future.
- Buyers need to question their vendors as to their ability to limit the scope of any recall through record-keeping and business practices in combo.
- The industry has to pay attention to traceability in terms of limitation of lot size and limitation of the number of source materials in a lot.
All should be reminded that most of the “solutions” to traceability don’t work on the hard stuff. As long as a grower/shipper is selling its own grown and packed product to Wal-Mart, traceability is really not that hard. It is when things change hands many times, get resorted or processed that the traceability gets tough.