Management of traceability information
There are several types of data management in a typical food operation or supply chain, for example, transfer, joining and splitting.
Transfer is the simplest of operations, where product identification is transferred with the product trough steps in a process or stages in a supply chain. That is where the traceability information is retained and identification is transferred between process steps or businesses in a supply chain.
Joining is where one process step or business combines several traceability units (e.g. raw materials from suppliers), each with a unique identification code and a new identification code is established for the joined material.
Splitting is where a traceability unit is split and used in the production of new traceability units, each with a new identity code, for example in different processes, products or customer destinations.
Efficient and accurate record keeping is essential to the successful application of traceability. Traceability records (paper-based and/or electronic computer-based) need to be kept in a way appropriate to the business, and need to be organised and retained in good condition to enable easy retrieval. The procedures used should meet the needs of the business and regulatory requirements.
Retention time and time for retrieval of data will also need to be appropriate. The length of time traceability records are retained will depend on the nature of the product, and any legal or commercial requirements.
Regulation 178/2002 does not set out a minimum retention time, although Regulation 931/2011 requires that records in respect of food of animal origin be kept available at least until it can be reasonably assumed that the food has been consumed. Commercial documents are usually retained for a period of 5 years for taxation purposes. This 5-year period may therefore meet the requirement of the Regulations. However, this rule would need to be adapted in some cases, for example, for perishable shorter shelf life products.
There is also a need for a business to determine a target time and mechanism of reaction for traceability data availability. The Regulations imply that there is a structured mechanism to deliver required information upon request. The target time will depend on may factors, however, this is likely to be measured in hours rather than days.