Here we will address one of the stated reasons for the passing of the Act. From the CFIA’s (Canadian Food Inspection Agency) summary of the Act:
“Strengthened food traceability: Current legislation does not require food manufacturers and other regulated parties to have traceability systems. The legislation provides the CFIA with strengthened authorities to develop regulations related to tracing and recalling food, and the appropriate tools to take action on potentially unsafe food commodities. This includes a prohibition against selling food commodities that have been recalled.”
Boy have we come a long way. Not so long ago, MS Word would tell me that “traceability” was not a word (back when we were talking about it as a neat feature of our SPC systems.) No longer! Now we offer complete systems for traceability, not just an extra feature of another solution.
The provisions of the USA Bio-terrorism Act of 2002, USA FSMA, and now Safe Foods for Canadians, all consider traceability to be a major concern. Not to mention that the big box companies have even more stringent requirements. Many food companies think they have it nailed, but there are serious holes and issues in most paper based systems. The first and foremost is of course the possibility of error, transcription, or illegibility.
If you manufacture your own products, under BTA you are allowed a maximum of 24 hours to produce a complete recall list with SKU # and location. If you co-pack, or ship to the Walmarts and Costcos of this world, you may have less than 4 hours.
In a paper world, production batch sheets are usually sorted by shift and placed in envelopes with supporting documentation. Although I have met people who swear they can do a mock recall in less than 4 hours purely on paper, I can’t conceive of how they can do so accurately and completely: It is easy to recall all of production lot 2012076, (it may all have shipped to the same big box warehouse!) but to recall all SKUs that contain or may contain liquid sugar 211093882 that entered the tank on May 15 2013, and the tank hasn’t been cleaned since then – that would be a neat trick.
Even worse: What do you do with this if the recall is for any product delivered by driver John Smith? Or all products of JS Company delivered between Jan 14 and Jan 19? And what if somebody dropped the batch sheets into a vat?
Canada isn’t there yet, but between the Safe Foods for Canadians Act, and the CFIA stepping up to provide regulations, I don’t think Canadian food processors have a very long window… and besides, it is just smart business, good manufacturing practice, good corporate citizenship, and limits exposure if you do need to do a recall. Lack of clear traceability by definition means that a recall can be orders of magnitude larger than it would be with contained traceability.