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This information can be used to develop food safety and quality programs that meet the requirements of modern Regulatory, Customer and Industry Standards:
When considering the development, documentation, and implementation of Product Identification and Traceability within food safety and quality management systems, the following information should be considered to ensure effective outcomes:
The primary reason for having a functional traceability system in place is to ensure safe food and to aid in the removal of unsafe food from the marketplace. A logical and systematic form of product identification is integral in such a system. Such a program must allow traceback and trace forward of all finished products, ingredients, and other raw materials. This system must be validated and verified, to ensure it is effective.
All raw materials and finished products must be identifiable and traceable at all stages of the process from receipt to finished products, including process steps where process deviations such as work in progress and re-working occur.
A food business should have documented policies and procedures that detail how products are identified at all stages of the process including the following aspects:
For some products, the coding system requirements are legislated. For other products, your business may create its coding system. In either instance, you should document the definition of a lot for each product, how to interpret the lot number on each raw ingredient, how to interpret the lot number on each finished product, and how ingredient lot numbers are linked to the finished product lot numbers.
Where premixing or rework is used, document:
Limiting the use of rework to the same lot reduces traceability problems. If rework is used, a system should be devised to ensure that the ingredients of the rework can be traced to the finished product.
It is important to ensure that items identified as non-conforming, whether they be raw materials, work in progress, or finished products, are specifically covered within the Product Identification and Traceability procedures. It is common for a non-conforming product to be segregated from conforming products stock to ensure no mix-ups can occur. Non-conforming products are commonly labeled with brightly colored signage or labels to ensure they are easily identifiable. The control of non-conforming products is often linked to procedures for the hold and release of such products.
Depending on the type of food your customers are buying and the intended usage of the food, it may or may not require labeling. There is generally no requirement for items produced for consumption within a premise to be labeled with details of ingredients and usage details. Labeling requirements for specific products or product groups are defined with the applicable food standards legislation.
General labeling requirements for products for retail sale include:
Labeling aims to provide consumers with information that will ensure they can make an informed decision regarding their choice of food and to ensure its safety at the time of consumption providing it has been handled and used according to the nominated requirements.
It is important to ensure that labeling review activities are scheduled, conducted, and recorded on an ongoing basis to ensure labels are accurate and meet customer and regulatory requirements. The frequency for labeling review activities is often nominated to meet customer requirements, though annually is a common minimum frequency.
In instances where sub-contracted packaging or labeling activities are conducted, it is of utmost importance that the scope and purpose of interactions of such sub-contractors are documented, and agreed upon, both internally and by relevant customers.
It is generally not considered appropriate for food businesses to procure the services of a sub-contracted packaging or labeling supplier without the prior consent of the customer for whom they manufacture foodstuffs. Such customer approvals often include verification of satisfactory standards, including the confirmation of food-grade packaging status.
In instances where Identity Preserved products are handled by sub-contracted packaging or labeling suppliers, it is important to ensure that the integrity and genuine status of such foods are maintained. This is often facilitated through the establishment of assessment and testing routines between food businesses that may enter into sub-contracted packaging or labeling arrangements to ensure the status of Identity Preserved products is not compromised.
Regardless of whether product labeling and coding is pre-printed or applied as part of the packaging process, all forms of product identification and traceability must remain legible and indelible at all times.
Legibility checks are conducted to ensure that the print within the product labeling and coding can be read and understood by the anticipated consumer group. It is also important to consider that regulatory guidelines often specify requirements for defining the legibility of product labeling and coding.
Indelibility checks are conducted to ensure that the product labeling and coding are permanent and will not be removed through unwanted means. When considering the indelibility characteristics of product labeling and coding, it is important to consider circumstances through which such labeling or coding may become illegible. For example, if the exterior of a frozen product becomes frosted during transport, the excess moisture on the product exterior could potentially cause the product label or coding to become illegible. Environmental conditions, such as high humidity within the packaging and labeling area of the food business can also potentially impact the integrity of the applied labeling.
Product assessments should be inclusive of labeling and coding reviews to ensure ongoing compliance. Scheduled product labeling and coding verification activities should also confirm the capability to continuously apply legible and indelible labeling and coding. Where product coding is applied within the food business,
verification activities are commonly inclusive of a review of the inks being used, the ink application systems and printers, and the surfaces upon which the ink is applied. Other product coding methods, including laser etching and imprinting, may also be verified through a scheduled activity.
The effectiveness of the Product Identification and Traceability systems are often verified through a scheduled Mock Recall activity as part of the Product Recall and Product Withdrawal systems:
If your food business supplies foodstuffs manufactured to a customer’s specifications, it is important to consider any specific Product Identification and Traceability Development requirements in relation to their items.
Document: A document provides guidance and/or direction for performing work, making decisions, or rendering judgments that affect the safety or quality of the products or services that customers receive.
Documented policies, procedures, work instructions, and schedules form the basis of any food safety and quality management system. The following documentation formats may be considered to ensure ongoing compliance with specified requirements for Product Identification and Traceability:
If your food business supplies foodstuffs manufactured to a customer’s specifications, it is important to consider any specific Product Identification and Traceability Documentation requirements in relation to their items.
You may wish to visit the Product Identification and Traceability Templates section of haccp.com for examples of Product Identification and Traceability documentation, record, and resource formats commonly applied within food safety and quality systems.
Implementation: Implementation is the application of documented food safety and quality system elements into the actual business operation.
The implementation of Product Identification and Traceability within any food business requires genuine commitment from senior management, staff, and visitors to ensure the nominated goals of implementation are achievable on an ongoing basis. It is a step that requires significant planning and consideration of general and specific food business circumstances to ensure the outcomes of Product Identification and Traceability do not negatively impact the safety and quality of the food items dispatched from the business.
Implementation of Product Identification and Traceability must include a clear definition of responsibilities and authorities for all levels of participation by senior management, staff, and visitors to the site.
When implementing Product Identification and Traceability within a food safety and quality system, you may wish to consider the following requirements before completion:
To successfully implement the defined policy, the policy should be kept as simple as possible and the appropriate staff should be given training against the policy. Over-complex policies tend not to be successful through staff missing the finer details. Posting relevant signage in relevant areas with appropriate identification information can be a useful tool. An example of this could be:
For the policies to be implemented properly, management must consider the allocation of resources for the staff to perform the appropriate functions. For example, a bakery may allocate all yellow trays as empty trays for direct contact with the floor only and all red trays to be stacked on top of the yellow trays may contain the product. This type of system only works if there are enough trays of each color, so that staff does not end up using incorrect colored trays for an incorrect purpose and creating a risk of cross-contamination.
If your food business supplies foodstuffs manufactured to a customer’s specifications, it is important to consider any specific Product Identification and Traceability Implementation requirements in relation to their items.
Monitoring: Monitoring is the act of reviewing and confirming measurable parameters of a defined process or product status.
Monitoring requirements within food industry sectors are generally identified against limits of acceptability defined within HACCP plans, implementation procedures, and work instructions. Monitoring usually includes some element of record-keeping, which may be maintained manually or through digital systems. It is important to consider that advancements in technology have spawned many systems and processes which are self-monitored and or self-adjusted when variances are identified. Regardless of the system used; The goal of any monitoring activity is to provide sufficient evidence that any limit of acceptability has been met.
Traditional Product Identification and Traceability monitoring requirements include manual recording and the application of corrective actions when the results of monitoring are found to be outside acceptable limits. Corrective Actions should also generally be strongly linked to the monitoring process where applied to ensure full traceability of the applied actions.
Common monitoring activities and record formats may apply to Product Identification and Traceability:
Records may or may not be kept for monitoring product identification and traceability policies. More commonly, the policies are physically monitored every day by the supervising staff to ensure they are correctly implemented, and then verified as part of a GMP audit or review on a weekly or monthly basis.
If your food business supplies foodstuffs manufactured to a customer’s specifications, it is important to consider any specific Product Identification and Traceability Monitoring requirements in relation to their items.
You may wish to visit the Product Identification and Traceability Templates section of haccp.com for examples of Product Identification and Traceability documentation, record, and resource formats commonly applied within food safety and quality systems.
Corrective Action: Corrective action is mandatory action to be taken when a deviation to the Quality System occurs, particularly to a Critical Control Point.
Preventative Action: At any step in the process where a hazard has been identified, preventative action must be put into place to prevent re-occurrence.
Corrective Action and Preventative Action are implemented to ensure that any identified non-conformance issues are documented, investigated, and rectified within appropriate time frames.
Corrective action is any action applied to regain control over a product, process, policy, or procedure that has been identified as being non-conforming outside nominated limits of acceptability.
Preventative action is any action applied to prevent any identified non-conformance from reoccurring.
The outcomes of corrective and preventative actions should result in regained process control after effective application. Specified corrective actions are commonly linked to the HACCP Plans and the food business certification process.
Below are Corrective Action and Preventative Action examples which may be associated with Product Identification and Traceability related non-conformance:
If your food business supplies foodstuffs manufactured to a customer’s specifications, it is important to consider any specific Product Identification and Traceability Corrective Action requirements in relation to their items.
You may wish to visit the Corrective Action and Preventative Action section of haccp.com for examples of best practice applications for this food safety and quality system element.
Verification: The act of reviewing, inspecting, testing, checking, auditing, or otherwise establishing and documenting whether items, processes, services, or documents conform to specified requirements.
Verification is the detailed review of all food safety and quality system elements to confirm that they are effectively developed, documented, implemented, monitored, and reviewed. All food safety and quality system elements, including documented policies, procedures, training, HACCP plans and their operational applications must be verified on an ongoing scheduled basis. The verification process commonly includes a defined schedule for which verification activities are required, how often they are conducted, who is responsible, and detailed documented procedures for each nominated verification activity.
The general goal of an established verification process is to ensure any systemic non-conformance issues are identified and rectified within an appropriate time frame. When non-conformance issues are identified through the verification process, Corrective Actions and Preventative Actions should be implemented to ensure they do not impact the effectiveness of the food safety and quality system.
The following examples of verification activities may apply to Product Identification and Traceability:
Verification that the policy works should be done in two parts:
If your food business supplies foodstuffs manufactured to a customer’s specifications, it is important to consider any specific Product Identification and Traceability Verification requirements in relation to their items.
You may wish to visit the Verification Activities section of haccp.com for examples of best practice applications for this food safety and quality system element.
Validation: The process of gathering evidence to provide a scientific basis for the documented act of demonstrating that a procedure, process, and activity will consistently lead to the expected results. It often includes the qualification of systems and equipment.
Validation is the provision of evidence to support the limits of control or acceptability for food safety or quality parameters nominated within systemic elements. Limits of control or acceptability are commonly included within documented food safety and quality systems elements such as procedures, HACCP plans, and specifications.
Common sources of validation include regulatory and legislative standards, finished product specifications and customer requirements, industry codes of practice and guidelines, verified and validated research, historical product and process control outcomes, and analytical testing.
The general goal of an established validation process is to ensure any systemic non-conformance issues are identified and rectified within an appropriate time frame. When non-conformance issues are identified through the verification process, Corrective Actions and Preventative Actions should be implemented to ensure they do not impact the effectiveness of the food safety and quality system.
Validation activities are commonly defined within the verification schedules and procedures of established food safety and quality management systems.
The following examples may apply to validation of the limits of control or acceptability for Product Identification and Traceability:
If your food business supplies foodstuffs manufactured to a customer’s specifications, it is important to consider any specific Product Identification and Traceability Validation requirements in relation to their items.
You may wish to visit the Validation Activities section of haccp.com for examples of best practice applications for this food safety and quality system element.
Skills and Knowledge: Skills and knowledge are attributes of human interactions commonly linked to competency within any specific job-related task.
Training and competency requirements for Product Identification and Traceability must be ongoing, including regularly scheduled reviews to ensure the effectiveness of training and competency outcomes.
Team members who have defined responsibilities regarding Product Identification and Traceability should have knowledge including:
Team members who have defined responsibilities regarding Product Identification and Traceability should have skills including:
Team members who have defined responsibilities regarding Product Identification and Traceability should have access to resources including:
If your food business supplies foodstuffs manufactured to a customer’s specifications, it is important to consider any specific Product Identification and Traceability Training, Competency, and Resources requirements in relation to their items.
You may wish to visit the Training, Competency, and Resources section of haccp.com for examples of best practice applications for this food safety and quality system element.
haccp.com was created to support food businesses and food industry professionals in achieving and maintaining the stringent requirements of food industry compliance.