Traceability - A Double-Edged Sword

Chris Moran, Executive Director, Grain Growers of Canada

When you buy a car, there is a lot of paperwork involving your name and the car's unique model number. Likewise, when you buy an appliance, there is at least the option for you to register that product with the company, in case it breaks down. When you fill your grocery cart with food, though, there is no way to identify its origin. While it is pretty unlikely that a box of cereal will have an acute failure that could wreak as much havoc as faulty brakes would, from time to time, food manufacturers working with public health agencies issue food recalls. In my memory, these seem to occur mostly during barbecue season.

The prevailing concept which allows any of these consumer product recalls is the concept of "traceability". In its simplest definition, traceability is the ability to follow a product back to its source. This is a hotly debated concept in food policy these days, and there are some very good reasons why this apparently benign concept is getting so much attention.

Traceability allows risk managers to pinpoint the source of the food, but it is also important to know where that food might have gone, especially if there is a hazard with a product. With a raw food product, this is relatively straightforward as the food is consumed directly as sold, but the situation becomes more complicated when dealing with processed foods, which might serve as inputs to other foods, and which might be distributed to other food processors (restaurants, smaller food processors etc.) for use in their operations. Recalling foods is no simple task: think about the number of times that you may have brought some food on a plane from one city to another, or have bought something and left it in your cupboard for several months before using it. A quick survey of my own pantry includes two examples of both of these: an unopened jar of mustard that I purchased in Paris two years ago and a jar of some sort of pesto that I received from someone visiting Rome. I would have no idea if there was a food recall on these products, but thankfully, these are low-risk foods and evidently, I didn't eat them!

Although systems like Hazard Analysis at Critical Control Points (HACCP) are implemented to prevent food-borne hazards from entering the public food supply, from time to time, lapses occur. So traceability acts as a sort of safety net, to catch the rare hazard that might slip through. Traceability uses lot numbers and tracking numbers as a control. This is not a new concept for large manufacturing operations, but the practice has become more common in the past few years, especially since the International Standards Organization (the ISO) developed a standard on traceability. Companies striving to maintain a given level of ISO certification would need to adopt traceability systems. It's important to note that the ISO work is done by industry - rather than government officials, and the use of their standards is voluntary.

However, in addition to the ISO work, the international food safety standards organization, the Codex Alimentarius Commission, has been working on the issue of traceability. The Codex work is done by government officials. Both the work of the ISO and the Codex Alimentarius can be adopted by governments as regulations, and under the WTO Agreements, if a country uses these standards as the basis for a regulation, it is likely that the regulation would be WTOconsistent, and not subject to a successful challenge or dispute by a trading partner.

Traceability requirements are being pushed further back on the food chain, meaning that there are cost implications for primary producers. Farmers already keep lots of records. Most farmers keep track of large purchases, farm inputs and certified seed to protect themselves. However, increasingly, governments are implementing regulations which would require traceability systems to extend to the farm level, too. While there are legitimate reasons to require traceability systems, such as consumer safety, there is also the possibility that traceability can be abused. The use of governmentregulated traceability is being used in some countries to underpin discriminatory practices, such as labelling for GMOs.

This is a complicated issue: on the one hand, traceability is a means to ensure consumer protection but on the other, it can be applied in ways that discriminate against Canadian products. No one would ever suggest that keeping records to ensure the safety of the food supply is unreasonable, but it's important that traceability requirements not become so onerous that they pose additional costs to the producer, and that they end up ultimately being used against producers! For example, tests can detect pesticide residues or determine if an unprocessed product is derived from GM corn. With highly refined products, it's impossible to tell whether the corn was genetically modified. A traceability record would clearly state this information, though, and may affect a processor's purchasing decision, depending on their market's destination. This is, therefore, a very important concept in the GM debate!

Several countries are using traceability systems to circumvent the WTO requirement that regulations for labelling be based on product characteristics, rather than on their method of production. The Cartagena protocol on Biosafety requires documentation to accompany commodity shipments, and this documentation, which is intended to be used by environmental risk managers, could be used by to trigger labelling requirements.

So far, the Canadian government has not implemented regulations requiring on-farm traceability systems like some of our trading partners (the ED, for example, has traceability requirements from "gate to plate" or "farm to fork") but the APF does have provisions to use traceability as one means to brand Canada. However, there is a huge difference between governments using traceability as a backstop for food safety systems, and using it to ensure that producers and manufacturers provide the ever-expanding list of information that some consumers are demanding.

Branding is about creating an association between a brand and its positive qualities. Canadian food is in a class of its own for safety and quality and this is what should be branded. .. not the many technical details involved in producing this food.

Traceability is a good management practice, but we must not allow it to be abused.

For more information on the Codex Alimentarius Commission, go to www.codexalimentarius.net. For more information on the ISO, go to www.iso.org. I can be reached at cmoran@ggc-pgc.ca