Cold Chain Procedures
In the event of a foodborne illness outbreak, it is important to have tracebacks and recall procedures in place. We know that tracebacks cannot prevent foodborne illnesses from occurring but being able to review good records and quickly trace food back to its source can limit the public health and economic impacts of an outbreak.
Fresh produce processors should develop and implement systems to facilitate tracebacks and recalls in the event of a problem, fresh produce processors should test their systems regularly by conducting unannounced mock recalls.
Traceback typically begins with the retail source of the fresh produce thought to cause illness or injury and work back to a processing facility and field. Information from a traceback can often be used to aid in the prevention of future illness outbreaks. Recall procedures are developed and used by a fresh produce processor to withdraw product that is already in the marketplace. A processor should be able to track all products, as records such as the grower identification, production, and distribution records for a specific lot of fresh produce should be orderly, properly maintained, and easily retrievable in less than one hour.
It is a good procedure to periodically test the firm's ability to retrieve information from the records by conducting mock recalls. Locked coding packages by date code or other coding may facilitate the recovery of the product if a recall is needed. Production records and date codes help put the puzzle together to identify the source.
Documentation and Records
We recommend as a general practice that food processors maintain records sufficient to reflect important product information and practices. Such documentation can be helpful to the processor in several ways. First, such records help ensure consistency of processing operations and end-product quality and safety. They are more reliable than human memory, and they are a useful tool to identify operational areas where inconsistencies occur and further employee training may be needed. Second, maintaining adequate documentation and records of processing operations is important if a traceback investigation of a fresh produce product is ever needed. We recommend that records be retained at the processing plant for at least six months after the date that the products were prepared unless a longer retention time is required under relevant law or regulation. Records are most useful when they begin by including the date and time, name of the person(s) who completed the record, and the activity or production station being recorded.
Records that may be kept for most food processing operations include the following:
Water quality and supply records
Water treatment and monitoring records
Employee training records
Temperature control records
Equipment monitoring and maintenance records
Calibration records
Sanitation records
Product processing batch records
Corrective action records
Pest control records
Distribution records
Inspection records (e.g., incoming product, facility, production area)
Microbiological contamination records (e.g., food contact surfaces, equipment)
the identity of the product involved (i.e., an adequate description of the type of fruit or vegetable group affected, including brand name and specific variety, date of releasing the food, the lot or code number or other identifiers of the implicated product, the quantity and how the food is packaged);
the reason for the recall and the date and circumstances under which the product deficiency or possible deficiency was discovered;
an evaluation of the risk associated with the product;
the total amount of implicated product units processed and the time span of processing;
the total amount of product in inventory and the total amount of product distributed; the distribution information including the number of direct accounts and, where necessary, the identity of the direct accounts;
a copy of the firm's recall communication, if any has issued, or the proposed communication if none has issued; the proposed strategy for conducting the recall; and
the name and telephone number of the firm official who should be contacted concerning the recall
Traceback and Recall
Traceback is the process of tracking food items, such as fresh-cut produce, back to their source (growers, packers, processor, field and when harvested). The ability to identify the source of a product can serve as an important complement to food safety programs intended to prevent the occurrence of microbial contamination. The information gained from a traceback investigation may also be useful in limiting the impact of an outbreak of foodborne illness and in identifying and eliminating conditions that may have resulted in the fresh produce becoming contaminated. We recommend that fresh-cut processors establish and maintain written traceback procedures to respond to food safety hazard problems when they arise.
We also recommend that fresh-cut processors establish and maintain a current written contingency plan for use in initiating and carrying out a recall. Having procedures in place will enable the recall of any lot of product that may have been implicated in an outbreak or that tested positive for a pathogen and help provide detailed information to assist the investigation of any foodborne illness associated with the product. Recall procedures usually include the name of the contact persons responsible at all times; the roles and responsibilities for the coordination of a recall; the methods to identify (e.g., use of lot codes), locate, and control recalled products; requirements to investigate other possibly affected products which could subsequently be included in the recall; and procedures for monitoring the effectiveness of the recall.
Because a recall may extend to more than one lot of product, we recommend that processors develop a coding system to help identify incoming product sources, individual production lots and to whom each lot is distributed. Use of package and date codes can help link product packages with production times, equipment, and raw ingredient sources and may facilitate recovery of products during a recall.
Produce growers and packers, fresh-cut produce processors, and shippers are encouraged to work with their partners in growing, transporting, distributing, packing, and processing, and with retail sectors to develop technologies that allow identification of fresh-cut produce from the grower to your operation, to the retailer, and to the consumer.
What are the consequences of an outbreak that implicates a product?
Without records the whole product line is suspect, all of the production procedures are suspect. More questions are raised than can be answered, “is the pathogen limited to only one day, one week, or one month of production? is the source of the problem, incoming product, or employee practices? Has dirty equipment contaminated the product?"
If a production facility has accurate records of effective cleaning and sanitation of equipment, has well-trained employees, and pays consistent attention to GMPs, the facility will greatly reduce the likelihood of its products causing a foodborne illness outbreak.
This segment has focused on understanding the legal requirements and voluntary programs for fresh produce processors. To review, GMPs are the regulations that fresh produce processors should follow in producing food that is safe to consume.
Once GMPs are firmly established, prerequisite programs can be used to ensure that manufacturing and sanitation procedures are performed consistently. Prerequisite programs will reduce the chances of problems occurring and will assist both the fresh produce processor and the regulator in identifying and correcting problems if they do occur.
HACCP is a voluntary system that treats the production, processing, storage, distribution, and service of food as a continuous process. This process is broken down into its logical components and each step is evaluated. The premise is simple if each step of the process is carried out correctly the end product will be safe food.
Notifying Industry Authorities of a Recall
In the event of a firm-initiated recall, if a firm believes its product is adulterated or otherwise violates health standards, we request that the firm immediately notify the appropriate industry authorities whether that be the FDA, Australian Department of Agriculture and Water Resources, MAFF, EFSA etc and that the notification include:
The identity of the product involved (i.e., an adequate description of the type of fruit or vegetable group affected, including brand name and specific variety, date of releasing the food, the lot or code number or other identifier of the implicated product, the quantity and how the food is packaged);
The reason for the recall and the date and circumstances under which the product deficiency or possible deficiency was discovered;
An evaluation of the risk associated with the product;
The total amount of implicated product units processed and the time span of processing;
The total amount of product in inventory and the total amount of product distributed; the distribution information including the number of direct accounts and, where necessary, the identity of the direct accounts;
A copy of the firm's recall communication, if any has issued, or the proposed communication if none has issued; the proposed strategy for conducting the recall; and
The name and telephone number of the firm official who should be contacted concerning the recall
