I was at the National Fisheries Institute annual meeting this past week, where I learned a lot of new information regarding seafood. One of the critical topics at this meeting was the new FDA traceability rule. There seems to be a lot of confusion as to how to prepare for this rule and most importantly how transformation of the product impacts food safety. Is all transformation a critical impact to food safety? Not necessarily. There needs to be much more education and industry/regulatory connection for the totality of this traceability regulation before needed actions are taken.

With that said, we all understand the importance of this traceability for any associated outbreaks to quickly identify the link and be able to safely and scientifically take product out of the marketplace. Which brings me to my question: How is this traceability going to be conducted and enforced at retail and institutional establishments?

Restaurants and retail have usually been disregarded as part of the food chain, to the consumer. Actually, consumers are often disregarded, as well. Disregarded may be a bit harsh, but it is probably the most applicable word with how I am feeling today. We all realize that when there is a food safety issue, the processor is most often blamed. And added to this blame, if there is chicken consumed anywhere around an outbreak, the finger is pointed and industry is in the headlines. It may not be Salmonella and it may not be chicken, but our industry is usually blamed.

I was asked to be an expert witness for a court case once. It was related to a pathogen outbreak from chicken at a church. Boxes of chicken were purchased from a supplier and prepared at the church for a summer event. Several people became ill. Before I would agree to the case, I asked for all documentation from the church including (Serve-Safe) training, health department applications and ratings, food safety culture at the church, records on all that was prepared and how, cooking temperatures, sanitation, etc. There was silence on the other end of the line; there was no documentation of anything, per the lawyer. Well, as you can imagine, I was not a witness for the case. This was undoubtedly a lack of knowledge of handling raw product. Unfortunately, this is not uncommon.

Consumers, retailers, and institutional preparation are just as critical as processing of food. I used to track outbreak causes in my previous life, and there are many cases where contamination or improper cooking and cross contamination happen after the product leaves the plant. I am thankful that the FDA traceability rule is supposed to be included in the Food Code, but details as to “how” have not been worked out yet. Implementation from beginning to final product consumption is the only way that this process will consider what went wrong and why. Only then can we learn and improve.

Traceability should include final point of consumption

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