In response to the events of September 11th 2001, the
Public Health Security and Bioterrorism Preparedness
and Response Act of 2002 (The Bioterrorism Act), was
passed and signed into law June 12, 2002.
Title III of this act, and specifically SEC. 306.
MAINTENANCE AND INSPECTION OF RECORDS
FOR FOODS most directly impacts manufacturers.
This section requires records be kept for the
immediate previous source and subsequent recipient
of food products.
This may sound simple, but that depends on what you
are doing in your plant. For example a facility makes
10 products from 10 ingredients. With existing
systems, could you tell how much of ingredient 2 went
into product 4 at 2:30 am last week? Was the
ingredient 2 in the feed tank one lot or were several
lots from the supplier mixed?
This is the concept of product genealogy. Product
genealogy follows the types and amounts of
materials that make up a product. This tracking can
tell you which of your products are suspect and just as
importantly which are not. Both time and cost are
reduced when a focused investigation is assisted by
good record keeping.
These records must be maintained for a set period
based on the shelf life of the product. The more
difficult requirement is that records must be made
available within 24 hours of an official request. This
time requirement almost guarantees a need for
automation.
While I would love everyone to automate everything, in
reality a compromise must be struck between the
ease
of retrieving the information and the cost. The right
balance is going to be different depending on the
number
of products, raw materials, suppliers, and consumers.
As a consumer, I am happy to know someone is
keeping track of this information. It is nice to think that
if the system works, I can find out about contaminated
food as quickly as possible. At the same time, I work
in the manufacturing world and I understand what a
tangled web a supply chain can be.
