would, ideally, lead rapidly to other
farms, potentially affected lots and back
up the supply chain to all receivers. With
rare exceptions, this may be a significant
challenge today.
In contrast to the desire to execute
such a rapid identification of common
inputs or proximity, a frequently expressed concern is that such rapid traceability data-sharing technologies will
result in the arbitrary and capricious removal of all products even remotely or
tangentially connected with an implicated lot. Due to the often highly perishable nature of produce, it is likely
that insufficient time would be available
to determine whether the concern
about co-contamination is substantiated.
Industry Needs for Traceability
Systems
Traceability systems may be designed
to include varying levels and approaches
to improving breadth, depth and precision. A longstanding function of traceability has been to differentiate one
supplier from another by providing their
buyers and prospective buyers the assurances of a detailed and well-imple-mented program. Exactly how much
breadth, the degree of information regarding the product’s production attributes, is needed in a particular timeframe
is a matter of debate. In general, the consensus is that the first flood of information should be well controlled and
limited by design to surgically isolate
one potential source from all others. In
the heat of a crisis, such as an outbreak
investigation, it is easy to overload the
investigators with too much information.
Delving into additional layers, such as a
common seed lot or specific harvest
equipment, would only come later, once
the legs of the trace-back have been confirmed to a reasonable degree.
Depth of traceability is related to the
logic of requiring one step back, one
step forward at each point in the supply
chain; this point is illustrated by the
ability of the FDA, for example, to laboriously walk back, one leg at a time,
along a marketing channel for peppers
that led to specific farms in Mexico that
were reported to have supplied the original samples with a genetic match to the
case isolates of S. Saintpaul. 11 Additional
genetically matched strains were obtained from environmental samples and
pepper samples at a regionally related
farm. In some long-existing traceability
systems as described above, the carton-associated lot codes would have allowed
that step to occur in one giant leap,
right back to the farm block. The availability of individual consumer units in
domestic refrigerators, though not generally the case, was instrumental in facilitating the rapid trace-back of implicated
bagged spinach to a processor and a narrow group of farm sources in 2006.10
One objective of the PTI would be to
bring that degree of depth identification
transfer of implicated product to all sectors. A significant but manageable barrier to a one-step concept are those
commodities, such as mature green
tomatoes, that may be commingled at
various points from initial packing to repack operations.
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