Recently enacted federal food safety and food security laws have brought increased recordkeeping to most food companies, from producer to shipper to wholesaler. Some companies are viewing these new regulations as huge burdens, but new technology may help producers turn the mounds of data that need to be collected to meet governmental traceability regulations into added value and profitability for their product.
The Public Health Security and Bioterrorism Preparedness and Response Act of 2002, which became effective for most food companies last summer, requires them to maintain detailed records to facilitate traceback to the most immediate previous owner and track forward to the next immediate recipient. This one-step-back, one-step-forward law pertains to those who manufacture, process, pack, transport, distribute, receive, hold, or import food in the United States.
Farms and ranches of product origin are exempt, along with those providing food directly to consumers, like restaurants and retailers. However, vertically integrated companies lose their exemption for internal transfers of product if the receiving entity is under different legal ownership. For example, if the farming company is a separate legal entity from the trucking or packing entity, recordkeeping at the farm level is required when the product moves from one legal entity (the farm) to another legal entity (the trucking company), even though both are part of the same overall enterprise.
"Earlier industry interpretation was that it would be sufficient to keep a list of all customers and suppliers," said C. Richard Johnson of John Deere Agri Services, a new division of John Deere. Most companies thought they were already in compliance, he added.
However, Johnson said that in guidance documents issued to the industry last summer, the U.S. Food and Drug Administration makes it clear that minimal information and lists are not sufficient. Johnson, of Blackfoot, Idaho, spoke at InfoAg Northwest, a precision agriculture conference held at Kennewick, Washington. The conference was sponsored by Washington State University, Far West Agribusiness Association, Foundation for Agronomic Research, and the International Plant Nutrition Institute.
Johnson explained that the new reporting and recordkeeping rules require food facilities to "connect the dots" within 24 hours or face substantial penalties. Liability is the same for the brand owner as for the grower-packer-shipper who custom packs the brand.
"The problem with the recent spinach food-safety incident was that packers couldn’t document and connect all the dots," he said. "And because they couldn’t, all of the spinach processors had to shut down." He added that it’s not just regulators that want "track and trace" information. During a food-safety crisis, retailers and consumers also want fast access to information.
"In the near future, consumers will also want assurances that their food is safe, and they will want more information about its production and sustainability," Johnson said.
The tracking and documenting of what happens to a food product as it makes its way to the consumer generates mounds of data. Added to the data required for FDA are normal cultural data about the crop that are not required but are part of good management practices. For example, data collection for an orchard begins before trees are planted, by recording soil amendments, fumigation, and such. Records are kept on the trees planted, pesticide application dates, and harvest and field identification information. More records are generated when fruit is delivered to the packing house. And then there are all the packing house data.
"There is continuous tracking of all products and processes that is documented and linked to critical points throughout the food-production supply chain," he said. Some of these data are required for the new regulations, and some are not.
Connecting the dots
Progressive grower-packer-shippers are beginning to understand that as they upgrade their recordkeeping systems to meet the new regulations, they can combine the data with their cultural practice data and substantially improve production management, he said.
Are there benefits to be gained from all this information? Johnson thinks so.
He believes that traceability data, and cultural, financial, and tracking information can be used to improve product consistency, increase yields, lower per-unit costs, better manage logistics, and even justify brand claims. Much of the information is already being collected, but it typically is stored in different locations—the farmer has one set of records, the packing shed another, and the marketer yet another. Few of the data sets are linked to give a consolidated picture.
John Deere Agri Services, a new division that came together in 2005, with portions of the group previously operating as independent companies for nearly 25 years, has developed a way to link the different data systems together.
"Our first job is to understand the data the customer has, and they usually have quite a bit," Johnson said. "We then put together a consolidated dashboard system used to view the data. We help connect the dots, turning the data into information to provide the grower-packer-shipper with a consolidated view so they can make the best possible decision. We call this Decision Support."
Although each company uses different software to track data, the Deere group can typically create a dashboard within three to six weeks, he said. They can help track back to whatever farm practice a client is interested in. For example, product quality can be quickly tracked back to labor crews by identifying bins of picked fruit. "It helps integrate data from the growing, packing, and shipping of your product."
They can also provide an assessment to see if a company is meeting FDA recordkeeping requirements. "Our motto is ‘prescription without diagnosis equals malpractice.’" He noted that several hundred systems have been developed by Deere and its partners. Dashboards are customized for each client and can be local or Web-based or viewed by Web-capable cell phones, with appropriate security.