Traceability may have rocketed up the agenda in the months following ‘horsegate’, but the legal requirement for traceability from European food businesses dates back to the General Food Law, which appeared in 2008.
“The regulation establishes the basic definition and the requirement in industry for one step back and one step forward, making traceability an essential part of what we do today,” says Neil Griffiths, chief executive of brand protection specialist SVA, which helps big retailers to establish effective product management policies using its modular eVision portfolio.
“Provided everybody does their job, at some point we ought to be able to muddle through and trace products through the supply chain.” Yet, Griffiths says many businesses have actually had to go much further: “Bigger businesses have to demonstrate ‘reasonableness’ in what they do. If a big retailer is just saying they’re supplied by ‘X’, it isn’t really very reasonable.”
What’s more, evolving legislation across Europe is currently adding to the pressure for improved traceability. The implementation of the Food Information for Consumers Regulation last month is a good example, where issues such as declaring allergens and country of origin labelling are having an impact. “These are hugely complex issues. You need a pretty detailed understanding of what’s in your products, right down to very minor ingredients, and that’s before you even look at potential cross-contamination or adulteration,” says Griffiths.
Traceability (Return to top)
In theory, traceability is one of the tools that should help to ensure that only safe food with the correct labels ends up in the shops. In the real world there will always be a need to respond when things go wrong. So, for example, if people start falling ill, public health authorities must be able to trace rapidly where any contamination problem came from and accurately pinpoint any risky products already making their way through the supply chain. The alternative is a damaging and expensive mass recall. "If traceability fails here, you have to fall back on mass product recalls, which is worse for businesses and consumer confidence," he adds.
While the systems providing traceability through some links in the supply chain are extremely robust (more below), horsemeat and other issues have shown that the ideal of truly transparent ‘farm-to-fork’ traceability is still some way off, particularly when it comes to mitigating the risk of criminal adulteration.
The recent government-commissioned report on food fraud by Professor Christopher Elliott made a whole raft of recommendations that will require action from both the government and industry. However, some observers doubt whether Elliott's proposals regarding unannounced food safety audits and the use of mass balance and accountancy checks will be effective at spotting food fraud.
Sherlock Holmes (Return to top)
“Trying to detect food fraud through food safety audits using food technologists is destined to be unsuccessful and is like expecting parking wardens to catch [Sherlock Holmes villain] Moriarty,” claims Stuart Shotton, food integrity director at FoodChain Europe, part of the Global ID Group. “Food safety auditors are experienced food safety professionals; you need experienced fraud and enforcement investigators to identify food fraud instances. Food Safety Audits, unannounced or not, are usually carried out at the retailer’s manufacturer site and these are the actual people being defrauded, not those generally responsible for the fraud.”
Notably, the forthcoming British Retail Consortium (BRC) Global Standard on Food Safety, Issue seven, includes new measures on fraud vulnerability analysis. The British Standards Institution has also just revised its Publicly Available Specification on malicious tampering (PAS 96) to introduce a threat assessment critical control points (TACCP) risk management methodology for mitigating fraud and even terrorist threats.
Meanwhile, specialists are gearing up to provide tools to help manufacturers and retailers evaluate the vulnerability of their supply chains to fraud.
For example, FoodChain Europe is introducing a new service called VAPOR (vulnerability assessment portal), which Shotton says goes beyond the BRC requirements on assessing vulnerability to deliver an all-round vulnerability score for raw materials and suppliers.
“It gives an overall picture of how well-protected your business is from commercially motivated adulteration,” he says. “It’s a different way of looking at things. It applies principles similar to HACCP [hazard analysis critical control points] – identifies potential threats and how to minimise them.”
Shotton stresses that anti-fraud measures require a different approach from traditional food safety audits. The aim is to identify and eliminate both intrinsic vulnerabilities (such as lax purchasing policies, IT security or questionable gift policies and extrinsic vulnerabilities (such as the price of certain raw materials shooting up and increasing the motivation for criminals to substitute alternatives).
Technical fix (Return to top)
Technology is no silver bullet when it comes to tackling traceability and food fraud, but the rise of Cloud computing and web-based services has undoubtedly been transforming what's possible in terms of supply chain visibility.
Muddy Boots provides audit and compliance software for the supply chain and its latest supplier approval platform is based in the Cloud. “Five years ago deploying a platform for supplier approval would have been very different,” says business development director Jeff Goulding. A web-based system opens up the opportunity to include more detailed compliance information about everyone in the supply chain.
“So they might be obliged to upload compliance information to the trader or organisation they’re supplying but what you’re inadvertently doing is creating a chain. The person at the top provided he has the right permissions now has transparency right the way down, so can check information such as the sustainability profile of each grower and their ethical trading record, etc.”
Closer integration (Return to top)
Goulding and other observers believe the transparency delivered by greater integration will be the key to even greater security. So, for example, rather than uploading details of a supplier’s compliance certificates into the system, the aim might be for a supplier approval platform to link directly into the databases of the relevant certification bodies.
Muddy Boots has agreed just such a deal with GlobalGAP, which certifies fruit and veg farmers around the world. “You can type in the supplier’s GlobalGAP number and create a link so you haven’t got to enter any of the details. Instead it takes you to the GlobalGAP database where the original information is held,” says Goulding.
The ultimate aim is to secure similar deals with other certification bodies, such as the BRC, LEAF (Linking Environment And Farming), Tesco Nurture and so on. Most observers agree that this could reduce the opportunity for false or erroneous certification, as well as saving time and effort. However, extending integration between platforms to include other auditing and certification bodies is not going to be easy.
What’s more, SVA’s Griffiths points out that maintaining different information in different databases could create silos that make it trickier to get an overall picture of the supply network, even if the databases could be linked. He argues instead that it would be preferable to be able to pull information into one coherent system. But that presents still greater practical obstacles, even if agreement could be reached in principle.
“Integration is the way forward, but the big issue is going to be gaining that sort of agreement,” confirms FoodChain’s Shotton. “It’s going to take a push and it might be that it needs a legislative push.” He estimates that we could start to see new legal requirements arising from the Elliott review in as little as six months.
Precision is necessary in any food supply chain recalls (Return to top)
Achieving total precision in product recalls is a high priority, and today’s logistics specialists use accurate tracking to trace goods as they pass through their systems whether finished products or raw ingredients.
For example, Partner Logistics has a network of frozen food warehouses in the UK and Belgium, as well as across the company’s home in the Netherlands. The company provides logistics services to the likes of Dawn Foods and Birds Eye and uses GS1 barcodes and serial shipping container codes to guarantee rapid traceability and recall down to pallet level.
“If there’s an issue with an ice cream there’s a batch number on the wrapper that can be used to identify the store where the consumer bought the product, the production facility where it was made and the logistics company that handled it, so we can trace all the pallets that contain products from that batch,” says Frank Baijens, business manager.
He notes that the typical timeframe allowed for the logistics firm to say what passed through its part of the supply chain during a product recall event is just four hours.
“In our part of the supply chain we deal with full pallets, and that makes it much easier than in some other supply chain stations,” he says.