Traceability – Simple Common Sense or an Industry Albatross?

By David L. Meeker, PhD, MBA
President, Animal Protein Producers Industry

The International Organization for Standardization (ISO), which develops voluntary international standards for products and services, defines traceability as the “ability to trace the history, application, or location of that which is under consideration.” The Economic Research Service (ERS) of the U.S. Department of Agriculture (USDA) adds detail to the ISO definition, saying the definition of traceability has to be broad because food is a complex product and traceability is a tool for achieving a number of different objectives. ERS explains that a system for tracking every input and process to satisfy every objective would be enormous and very costly so industries have developed varying amounts and kinds of traceability systems. Traceability systems can have certain breadth, depth, and precision depending on what they produce, how their processes work, and what they need to accomplish. The breadth is amount of information tracked, the depth is how far back information is collected, and the precision is how accurately the system can pinpoint a needed fact about a food, feed, or ingredient.

Traceability is the concept that you know where your ingredients come from and where your products go, and you keep records of the people and places involved. In its simplest form, traceability requires knowledge of the step in the chain immediately before and after your own plant. The breadth is rather narrow – sellers, buyers, transporters, and contact information. The depth is one step back and one step forward – so including your plant, it’s three steps. The precision should be high – these are not complicated records.

The rendering industry can do very well with the simplest form of traceability, and most of the industry follows the North American Rendering Industry Code of Practice, tracking the necessary information because it’s good business. Still, an understanding of the whys, hows, and motivations of others in the food sector may give you an idea of future pressures on the rendering industry. It may be useful to know more about the traceability concepts that various sectors of the food industry are supporting, opposing, arguing over, or presenting as the solution to all problems.

Traceability as a Prevention Tool

Traceability, voluntary or mandated, can accomplish a number of good things but regulation is often needed because the government needs to ensure that unsafe or falsely advertised foods can be quickly removed from the system. Someone may be intentionally cutting corners, selling inferior products at quality prices, or doing outright illegal things and traceability needs to be available to expose them. It’s important that what’s necessary (required by regulation) is not confused with or mixed with what is desired (accomplished by contract agreements and marketing). It’s necessary to trace the source of the rare accidental pesticide contamination of feed that kills or sickens large numbers of animals. It’s necessary for animal health monitoring and disease surveillance – such as the case of the12-year-old Texas cow that tested positive for bovine spongiform encephalopathy in June 2005 – to determine what a cow was fed and if other cows ate the same thing. (In that case, to date, prohibited proteins were neither found nor ruled out; the old records were inadequate for today’s needs. See “Newsline,” page 8.) Traceability could be used to identify, reduce, and eliminate pathogen contamination such as E. coli 0517:H7 throughout the marketing system. A tracing and recall system must be used to contain outbreaks of feed borne illness in animals or food borne illness in humans, but hopefully will not be needed to trace back the source of an intentional contamination of some sort in bioterrorism. If everyone in the animal production/feed/food chain does their part, traceability can be accomplished easily.

Using Traceability to Compete

Beyond the regulatory need for it, traceability can also be a competitive advantage. The movement, storage, and control of products across the supply chain costs money and needs to be done efficiently. Supply-side management includes traceability, and a good system can lower costs and increase competitiveness. Common electronic coding systems such as the bar code, and newer technologies such as radio-frequency identification systems, are being utilized to monitor product flow and to link suppliers and buyers. Wal-Mart tracks inventory changes so that when items are scanned at checkout, more items are ordered direct from the supplier. As the cost of technology decreases with volume sales, more firms across the food supply chain are developing and maintaining electronic tracking systems. Grocery store loyalty or club cards designed to track consumer sales and preferences to better compete can also provide targeted food recall information in case of an emergency. Firms can minimize the production and distribution of unsafe or poor quality products by using traceability systems to track product distribution and target recall activities. Such control can minimize the potential for negative publicity, liability, and amount of product recalled and destroyed.

Many buyers, including feed companies and livestock feeders on one end of the chain and restaurants and grocery stores on the other end, now require their suppliers to establish safety and quality traceability systems and to verify them through third-party certification. This is one reason the rendering industry developed the code of practice and the Animal Protein Producers Industry is offering education and third-party audits. The development of standards in various industries and growth of third-party certifying agents throughout the food industry is driving the need for verifiable traceability systems.

A trace back system can be very sophisticated. Some food producers’ traceability systems provide extremely specific information allowing them to trace a faulty product to the minute of production and determine whether other products from the same batch are also bad. In a farm-to-table example, a special-label value-added beef company uses identification and monitoring of individual animals from the cow/calf level through the slaughtering process. The system allows producers to get data back from the processors about the meat quality of their calves to be used in selection of herd bulls with the best feedlot and carcass performance. The feed used in such a system is also certified, as are the ingredients used to make the feed. This detailed private marketing system must utilize computerized records since thousands of small producers are involved. Internet access makes origin and tracing data available to authorized participants by a password protected area of a Web site database. The database centralizes information from many different sources, including information such as ear tag numbers or retinal scans, inherited attributes, tested characteristics, treatment during production and handling, and degree of identity preservation.

In a successful system, the extra profits from increased consumer prices or sales would help pay for activities far upstream such as tagging cattle. The “extras” in such a value-added system should not be confused with the basic requirements of an animal identification system needed to prevent anonymous animals and to detect the source of major problems or diseases. Legal requirements such as identification of the premise of origin and data to verify country-of-origin labeling would be part of the program, but the add-ons would be voluntary and customized for the particular marketing system.

Traceability can also be used to differentiate products and to add value by verifying certain production conditions desired by customers. Meat, milk, eggs, grain, soybeans, fats, or protein meals in the form of bulk commodities of the same product description don’t offer merits to differentiate one batch from another other than by price. The food industry is developing products and services specifically for the tastes and preferences of various segments of consumers. The United States produces about 300,000 different food products with about 10,000 new product introductions each year. Some product innovations involve characteristics that consumers cannot see but say they prefer. These can be credence attributes such as the amount of calcium in a glass of enriched orange juice or process attributes such as organic, free-range, dolphin-safe, earth-friendly, and fair trade. The market system for these types of products depends on verification that the products have the claimed attributes. This must be done through keeping records – traceability as evidence of value.


Misuse of Traceability

Traceability requirements are sometimes used as a way to block developments with enemies for reasons other than food safety or legitimate attributes. The European Union (EU) has tried to advance cumbersome traceability regulations through the Codex Alimentarius Commission, which sets international food standards and guidelines, to make it very expensive to implement crops enhanced through biotechnology. Traceability requirements supported by the EU would force companies to document the presence of biotechnology crops, but not other commodities, through each stage of production and distribution. While it looks like a good idea to facilitate the removal of a product from the market should it be later found to pose a risk and to monitor long-term for potential health or environmental effects, it is unnecessary. In the United States, biotechnology products do not have to be traced through production and distribution channels as long as they are proven to be substantially similar to products of conventional breeding. While segregation is appropriate if market driven for high-value products, such as fresh fruits and vegetables, imposing a traceability regimen on only the biotechnology portion of commodity products would add to the complexity and cost of the distribution system with no benefit. This would be costly for corn and soybeans because farmers would have to prevent pollen flow from biotechnology to non-biotechnology crops, ensure cleaning of equipment between harvesting and transporting biotechnology and regular crops, and test samples at each step. It would be so troublesome as to prevent the planting of the biotechnology crops in the first place, unless the economic advantages were large enough to pay for all the extra work.

Traceability Ownership

Most people in agriculture agree on the usefulness of the animal identification part of traceability, but argue whether it should be regulatory or voluntary. In many grocery stores now, bar coding is used to control inventory and track meat through stores as well as fruit and vegetables, beverages, and bakery goods. Canada’s agriculture is a bit more manageable in size, and Agriculture and Agri-Food Canada is funding a live swine tracking initiative. The U.S. swine industry has become very integrated in the last 20 years and can accomplish broad, deep, and precise traceability, while the cattle industry is working on it.

Many in the U.S. beef industry are concerned about the USDA National Animal Identification System because of their desire for privacy of data and the unsavory thought of having government in their business. As an alternative, the National Cattlemen’s Beef Association led the development of a private industry-supported animal identification database, believing that “a market-driven solution is quicker and better protected than a bureaucratic, government solution.” They enlisted technology consultant BearingPoint, Inc., and are working with companies including ViaTrace, Microsoft, and S&H Marketing. They say they will have their system in place three years ahead of the timetable for USDA’s system, adding that while federal and state animal health authorities will be able to access relevant parts of the database to trace back in the event of a disease outbreak or animal health-related incident, the data will remain the property of the individual and stored with a consortium to maintain confidentiality. It appears that since the industry wants this traceability system, it can be developed in less time than it takes USDA to respond to confidentiality concerns with their system.

Renderers have a stake in how the animal identification system is regulated and implemented. Separate regulations require renderers to keep track of farms where dead stock comes from, but early versions of animal identification requirements of producers included slaughter and other market channels and ignored fallen animals. The National Renderers Association (NRA) has worked to make sure the two regulations are coordinated so that information needed by and required of renderers is not lost by producers.

More Traceability in the Future?

Whether traceability used in the rendering industry remains simple depends on how much information it is intended to provide. Whether it is a common sense activity contributing to good business or an albatross depends on how much is regulated and for what reasons. As with all issues, the NRA encourages a science-based policy with regulation for only that which is necessary, while allowing the marketplace to develop and pay for add-ons important to various customers.


Tech Topics - October 2005 Render