Food Recalls and Traceability: When Someone Else’s Problem Becomes Yours

By now, most are well aware of the implementation of the Food Safety Modernization Act, or FSMA. The most sweeping change in food regulations in more than 70 years, FSMA aims to prevent food borne illness rather than reacting to it. This differs from the policies of the past which focused on responding to contaminated food recalls rather than focusing on how to keep those problems from happening in the first place. Much of FSMA concentrates on assessing risk-based hazards, establishing preventative controls, and quite a bit of documentation. You must document identified hazards, why you’ve identified them, how you plan to control them, and that you’ve actually done it.

Looking Forward & Back
A subset of this documentation process revolves around traceability. Traceability involves keeping track of where ingredients came from, what products they went into and where those products were shipped. Often times a food processor will find a problem themselves and track down the products in question or issue a recall if needed. However, an issue could be found farther upstream, posing a severe problem to users of that ingredient downstream if documentation and traceability steps are not in place. Your products could be the subject of a recall through no fault of your own. Merely using a contaminated ingredient could throw your business into a tailspin. The ability to track all of your ingredients at least one step forward and one step back is absolutely critical. Documenting the lot and batch number of each and every ingredient will make the recall process significantly easier for all parties involved. You could do everything right and still find yourself knee deep in a massive recall.

A Real Life Example
Much media attention has surrounded the major flour recall beginning in late 2015.  The E. Coli outbreak, which began with General Mills flour, has since spread to eight SKU’s of Gold Medal flour, Wondra flour, Signature Kitchens flour, Krusteaz Blueberry pancake mix, and most recently, two flavors of Betty Crocker cake mix.  As of July 8, 2016 approximately 30 million pounds of product has been recalled.

Tracking Product is Easier Than You Think
Imagine the difficulty in locating a product which you distributed in June and produced in March with ingredients you acquired in December. Confusing right? While tracking this may seem impossible, it would be quite manageable with proper and adequate documentation. Knowing exactly what went into every batch, where it came from and eventually where it was sent would make any recall faster and more efficient, even if you didn’t do anything wrong.

Preparation is Key
So what’s the take away and what can today’s food processors do? First and foremost, get to know your suppliers and trust them. Did anyone do anything wrong in the flour recall of 2015? No. General Mills is one of the worlds most trusted and recognized companies, but things happen. Companies must put policies and processes in place to cover themselves. Document everything coming in and going out of your facilities. For larger processors an Enterprise Resource Planning (ERP) system may be required. ERP systems are great for handling HACCP protocol, traceability, quality assurance, quality management, and document management. While these systems can be costly and not for everyone, larger companies can surely benefit from their all-encompassing features which can prove their worth in the unlikely event of a recall.

Smaller companies who cannot afford such an expensive piece of software must be more aware of their processes. They must be more diligent when recording ingredients going into their products and where products are being distributed. Resources like those through the Michigan Manufacturing Technology Center assist small to medium size food processors get up to speed with FSMA regulations and how to be prepared for the unthinkable. You don’t want someone else’s problem to be your problem.

Contact the Michigan Manufacturing Technology Center
The Michigan Manufacturing Technology Center offers more than 25 years of manufacturing assistance in top and bottom-line improvements for food processors. Our Food Processing
Professionals are ANSI Certified in Food Safety through NSF to exceed your operational needs without compromising food safety. To speak to one of our experts, call 888.414.6682.


Since 1991, the Michigan Manufacturing Technology Center has assisted Michigan’s small and medium-sized businesses to successfully compete and grow. Through personalized services fitted to meet the needs of clients, we develop more effective business leaders, drive product and process innovation, promote company-wide operational excellence and foster creative strategies for business growth and greater profitability. Find us at www.mmtc.org.