Petfood traceability!

By Arnold Dijkstra

alphasure@gmx.net

Like any other food and feed production company, petfood producers are faced with increasing legislation on petfood traceability and labeling. Together with increasing complexity of the forth bringing chains and webs, and time pressure, this poses a challenge for the food and feed industry. What, why, how and when are discussed.

What are we talking about?

ISO 8402 defines tracing as "the ability to collect the history, use or localization of an entity by means of recorded identifications" According to the EC Regulation 178/2002, the so called General Food Law, traceability means "the ability to trace and follow a food, feed, food-producing animal or substance intended to be, or expected to be incorporated into a food or feed, hrough all stages of production, processing and distribution". Both definitions unfortunately allows multiple interpretation! Firstly traceability is often mixed with tracking & tracing. The last words are not clearly defined, resulting in confusion. Most consistent is the use of traceability and differentiation between upwards and downwards traceability; figure 1 illustrates the difference. Secondly the definitions don't involve the factor time. We should however differentiate between real-time traceability and historical traceability. Real-time traceability means the knowledge of the place and attributes of any object at any time, while historical traceability is directed to retrospective analyses. Finally the definition doesn't imply the (minimum) size of lots that a "substance intended to be, or expected to be incorporated into a food or feed" of . traceability therefore is a container-concept, free for (any?) interpretation and therefore great difficulty to handle at the (inter) national trade and production.

Why traceability?

Despite the questions, traceability seems nowadays one of the major issues regading petfood(and food and feed) safety and quality. This is however obvious when we consider the sever food crisis that faced the food and feed industry.

The BSE crisis started in 1985 and still continues (Pets International Magazine 13-2, March 2001), the dioxine crisis (1999), Foot & Mouth disease (Pets International Magazine 13-4, Jume 2001), SARS (PETS International 15-4-June 2003), avian influenza (2004), other viruses, and more to come!

But not only crisis are the driving force behind traceability regulations. Some other raisons are

•the fear of bio terrorism, in particular in the USA;

•the ability to protect the consumer through the effective recall or withdrawal of problem products from the market;

•the need to assure the customer of specific content, quality or other product attributes (for example "organic" or "GMO free");

•the requirements needed to gain or maintain market access (either domestic or international);

•the requirements needed to gain or maintain market access (either domestic or international);

•the need to protect animal health and control contagious livestock diseases.

So the need to incorporate traceability seems evident, the question is however how?

How?

This is probably one of the major challenges ahead of us. Most (pet) food industries are not only part of a chain from fat to cat, but are a tiny piece of a world wide food – and feed web with complex flows of ingredients, by-products and so on. In order to be effective, a whole web solution is necessary and implies transparency and extensive international cooperation. In practice this means simple systems to (uniquely!) code any ingredient and product, using world-standard systems. Fortunately numerous traceability systems are currently available around the globe, like the EAN128 code (Serial Shipping Container code – SCC ) for any individual logistic unit, comprising information on constituents, batch numbers, keeping date, sender and recipient. New systems are to be developed, like the Reduced Space Symbology, Composite symbologies and the advanced RFID (Radio Frequency identification) technique. Despite this technological progress, questions remain.

As elucidated before, systems will operate or be hampered If lot-sizes are not or ill defined.

Traceability can be accomplished at the end product user (consumer) unit/item level, at the case level, at the lot/batch level or a combination of all. Typically, the more specific the traceability becomes, complexity and implementation lag increases (figure 2). Therefore, while desirable from the risk management point of view, unit traceability for all products may prove too costly and complex to be a viable choice for all product categories. And what about the problem of "not quantified mixing of ingredients" (carry-over), I particular a problem of "not quantified mixing of ingredients" (carry-over), I particular a problem with unwanted incorporation of genetically modified ingredients (GMO) or allergenic substances. Not to mention products that are sold unpacked on marketplaces, food stores and pet shops. How can we ever trace composed meals at restaurants or in your dogs feeding bowl?

Finally the lynch pin of any traceability initiative is the rules developed to ensure the accurate and timely transfer of data vital to a traceability system's integrity. Commonly referred to as business (or process) rules, they define the who, what and when of the system. Failure to enforce the rules will undermine the credibility of system.

When?

This is quite simple: as soon as possible! The industry should act proactive, not only because they have to, but also because traceability systems are beneficial and may save money, reputation and more. However (as usual) most companies react no second earlier than required (repressive approach). For many (fresh) products rules for traceability and labeling have already been laid down in regulations, like EU regulation 1774/2002 on health rules concerning animal by-products not intended for human consumption. From a legislative point of view petfood follows feed regulation, but both petfood and feed regulations "approach" human food legislation. For food, the European General Food Law will be enforced on January 1th 2004. from this date onwards European companies shall be able to trace any ingredient "one step down" (downstream traceability) and to track released products "one step up" (upstream traceability) within 4 hours. In the USA the Bio terrorism act of 2002 requires record keeping from any company releasing products on their market. On a global scale the global food safety initiative (GFS) will also incorporate traceability and labeling rules.

Conclusion

Global food and feed problems, world-wide trade and complex food & feed webs are leading towards more control on the flow of any food and feed item. The ability to trace any substance at any stage of production, processing and distribution will be a obligation for anyone involved. Technical solutions are available, but success depends on personnel supplying the systems with information. This involves a change in mentality and responsibility for anyone involved!

PETS International Magazine ISSUE 4,2004