ISO complicates traceability issue

Sir

Your article on traceability (Food Manufacture September 2004, p45) highlights that the objective is to allow the competent authority to identify the source and destination of any perceived contamination quickly. This could lead to product withdrawal if a serious hazard is detected.

For a small business it may be cheaper to withdraw all production rather than run an expensive scheme all the time. For a larger operator it may be cheaper to have a batch tracing system so only a small proportion of production needs to be withdrawn.

The law is slightly complicated by ISO standards. PrEN ISO 22000:2004, prepared by Technical Committee ISO/TC34, calls for a sophisticated tracing system. Thus any business wanting to comply with ISO 22000 would need to have full batch traceability.

The standard also calls for fully documented HACCP defined in the terms of Codex, which starts: "A food safety team shall be appointed ? shall have multi-disciplinary knowledge and experience." This sort of organisation is probably outside the scope of the mass of small businesses. The provisional standard is now out for discussion and comments should be sent to Technical Committee 34.

The Centrale für Coorganisation, the German standards organisation, reckons that a food business should have at least 50 employees before a batch traceability and e-business system is economically viable.

It is doing some research into systems and is looking for UK-based businesses that could profit from such developments. It is prepared to design and install a system free as part of its research. Anyone interested should contact Tim Bartram on +49 221 94714-419 or onegenz@ppt.qr​.

Bob Salmon

Food adviser

Forum of Private Business