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Base Traceability System Changes on Risk

11 December 2009

UK - AMI Vice President of Food Safety and Inspection Services Scott Goltry told a joint Food and Drug Administration (FDA) and Food Safety and Inspection Service (FSIS) meeting that traceability is “a reactive, yet essential part of a food safety system,” but also cautioned that “enhancements to traceability systems must be based on risk and the success of meeting traceability objectives.”

The meeting aimed to stimulate discussion about enhancing the product tracing systems for food. Goltry outlined the key objectives of a traceability system, which are: 1) to help determine the cause of the foodborne outbreak; 2) to help determine the source of the contamination; and 3) to create the ability to remove specific illness-associated product from commerce without causing market disruption and while maintaining consumer and trading partner confidence.

Goltry explained that change to an existing traceability system is more difficult than developing a new trace system when one does not exist. He said that data and information systems that deal with product traceability are directly related to product availability, cost and production formulation systems and therefore a change to a tracing system could create an overhaul of the complete information system. “Duplicate traceability systems will do nothing but add cost and confusion to the food chain and should not be created,” Goltry noted.

Goltry also noted that current law requires meat and poultry products to bear an establishment number clearly visible on the label and that, although not required, production lot or code date information almost always is printed on the consumer package. Additionally, the Packers and Stockyard Act requires that records be maintained that can identify the supplier of livestock purchased.

Goltry said AMI supports the tracing system referred in the Public Meeting Notice as “one up/one down” tracing system. This type of tracing system would begin with livestock purchased and delivered to the manufacturing plant and include ability to trace the product through the supply chain by processors, distributors and retailer to the consumers. He also said that good recordkeeping by everyone in the chain is critical, emphasizing the importance good records by any company that processes ground beef.

In closing, Goltry noted that many AMI members produce animal feed ingredients and use FDA regulated products, such as seasonings and other ingredients in the production of hot dogs, sausages and deli meats. In that regard, AMI is mindful of the challenges of tracing these products, he said.

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