The mandatory requirement for a traceability system was introduced into our legal framework in the food industry in 2018 when R638 REGULATIONS GOVERNING GENERAL HYGIENE REQUIREMENTS FOR FOOD PREMISES, THE TRANSPORT OF FOOD AND RELATED MATTERS, a regulation under the FOODSTUFFS, COSMETICS AND DISINFECTANTS ACT, (ACT 54 of 1972, was promulgated in June.
Although this regulation had been in the legal pipeline, its promulgation was nudged along by the Listeriosis outbreak. While this was the world’s single largest outbreak of Listeriosis, it also highlighted dramatically the need for an effective traceability system. This requirement was emphasised recently with a similar scale recall of canned pilchards.
Recalls are not an uncommon activity. In fact, recent research reviewing recalls around the world by Soon et al. 2020, they showed that over the decade spanning 2008-2018, they are increasing.
Undeclared allergens remain the top culprit followed by food contaminated with biological hazards.
The legal pressure on food and beverage manufacturers to track and identify every single ingredient used in the manufacturing process; from receipt of initial ingredient, seed, foodstuff, animal – and its feed, additive or raw material; through the entire manufacturing process; to packaging and shipping the end product to the customer is an international trend. This coupled with customers demanding more visibility in their supply chains should be prompting South African manufacturers to seek out solutions. Our experience – there is very limited uptake for this essential system even after the new regulation has been enforceable for nearly a year.
Relying or waiting for external pressure and/or enforcement is not advisable. The costs associated with our policy and pilchard recalls would have covered the costs of an effective ERP system many times over and recall costs are not something you can budget for, or even survive as a business.
Yes, it can be a complex web to unravel but there are service providers like SYSPRO that can assist in breaking down a complex puzzle into manageable projects and working with you and your team to implement a workable effective system.
Working together we need to Identify elements required to ensure that the system encompasses the full traceability of the product. This means breaking it down into three components:
An ideal traceability system will encompass all three of these but it’s best to start somewhere and then build the system with the ideal end goal in mind. Of course, there may be challenges to navigate and our experience has shown us that there is not a one-size-fits-all approach as different sectors of the value chain will develop traceability systems that differ in scope. We do realise that in many global companies, communication regarding processes, legislation and production methods between regions is poor or non-existent. This means that the problems typically occur where there is no seamless interface between supplier, process and customer. The scope is critically important and becomes a commercial decision – the broader the definition of a batch, the greater the volume of product potentially recalled so you must think carefully about your existing practices – it may be easy to record a batch as a day’s production, but what will that cost you to bring back?
The objective of an effective traceability system - allow you to react quickly…when the urgency of a recall and the media are breathing down your neck.
Use our checklist to test your current systems:
If this quick assessment highlights some weaknesses in your current system, then you may be exposed to real business risk that your recall system could fail you when you need it most. Considering we are dealing with human health, this is probably not something you want to have on your conscience which is why as should be complying with the legal requirement for full traceability – it is just the right thing to do.
About the author
Deirdre Fryer is the Regional Product Manager for SYSPRO - Africa.
She has a focus on understanding customer requirements and driving product improvement