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    FOOD SUPPLY CHAIN:SAFETY NORMSS

    Background

    Food safety has long been recognized as a mandatory requirement in the production and

    marketing of foods. Traditional approaches to food safety management have relied upon endproduct sampling and laboratory testing. Detailed procedures were developed to set

    specifications for foods in regard to chemical and microbiological levels, and also levels of

    physical contamination. Such specifications were originally derived from knowledge of Good

    Manufacturing Practice (GMP) requirements and more recently from detailed risk assessments

    which determined the likelihood of hazards presenting a risk to public health and safety. Food

    product specifications and end product testing have traditionally formed the primary basis for

    regulatory oversight of food safety. In some areas this is still the case today. A major

    change in approach arose when it was demonstrated that hazard identification and control

    could be used to manage food safety across the entire agri-food supply chain, rather than at

    some endpoint. This approach led to the adoption of the now well accepted Hazard Analysisand Critical Control Point (HACCP) system which emphasized preventative approaches.

    Whereas the initial research relating to food product hazard control was undertaken several

    decades ago, the impetus for its adoption in the food sector became very significant in the 1990s.

    A second area of development is the concept of hurdle technology where a series of food

    safety measures are used, sometimes in steps, to gain synergy in the interaction and

    effectiveness of several food safety measures. The correct application of a series of hurdles can

    achieve the same product safety as a single food safety measure such as a kill step. Continuing

    research underpinning food safety management has provided a number of new approaches,

    and tools, which have strengthened risk assessment capability, and allowed a clearer delineation

    between risk assessment and risk management. This has enabled a transition from end product

    specification and testing to a focus on establishing new measures of food safety such as Food

    Safety Objectives and associated metrics (ICMSF 2002). This allows the food industry greater

    flexibility when examining approaches to food safety management.

    Keeping food safe: A growing global challenge

    Keeping food safe as it moves through the supply chain is a significant challenge. Perishables

    such as produce, meat, fish, milk and more can change hands ten to twenty times before reachingthe consumer. This fact alone presents many opportunities along the supply chain for accidental

    or malicious mishandling that can lead to contamination or spoilage. And a host of new issues

    and trends, from the globalization of the supply chain to the type of foods that are imported,

    takes the challenge of protecting the safety of the food in the supply chain to new heights.

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    Changes in consumption trends

    Todays busy consumers often rank convenience over price a trend that can translate into

    increased opportunities for food contamination. For example, many consumers today would

    prefer to purchase a bag of prepared ready-to-eat lettuce instead of a head of lettuce that must be

    prepared. As a result, bacteria in a tainted head of lettuce that may have only affected one family

    in the past might now end up in multiple of bags of lettuce, potentially causing foodborne illness

    in hundreds of people.

    Another challenge in the food chain: increased government regulations

    In response to growing food safety issues, new government regulations have been developed to

    help protect food as it travels through the supply chain. While these regulations do improve

    consumer safety, they also translate into a substantial increase in recordkeeping requirements for

    companies throughout the food supply chain. For example, federal regulations in the U.S such as

    The Federal Public health security and bioterrorism Preparedness and Response act of 2002

    (enacted after September 11, 2001) and the U.S. FDA Good

    Manufacturing Practice Regulations as well as the EU food laws defined by the European

    commission (EC) now require the collection and maintenance of detailed specific information as

    food moves through the supply chain. In order to remain profitable, enterprises in the food

    industry need to accurately and cost-effectively collect, filter and react to this massive amount of

    information a task at which RFID excels.

    RFID A critical new link in the food supply chain

    RFID can help improve the efficiency and safety of the food supply chain by enabling the

    collection of the vast amount of data required to ensure the safety of food as it moves through

    either the national or international food supply chain. Passive RFID tags provide cost-effective

    tracking and traceability as food moves through the supply chain, while temperature-sensing and

    data logging RFID tags capture information about the conditions the food is subjected to on the

    journey from field to fork.

    With RFID, food is tracked from the moment it is picked in the field. RFID tags are applied to

    collection bins, and when a bin is full, an RFID-enabled mobile computer is utilized to read the

    tag. The unique identifier associated with the bin is captured the date and time are automatically

    recorded, and any other additional information needed to enable full traceability back to the

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    origin of the product is entered, such as the pickers name and the picking location. The

    automation of the data collection process protects the integrity of the data set, and encourages

    the capture of a richer set of information due to the simplicity of data input. And when combined

    with a locationing technology such as GPS, RFID can automatically record the exact location in

    the field where the produce was picked, allowing growers to pinpoint the source of contaminated

    produce quickly and more cost-effectively protecting the health of consumers as well as the

    business.

    The RFID advantage: improving food safety and supply chain efficiency

    In the food supply chain, consumer safety and enterprise profitability are both dependent upon

    how rapidly product can move from the field, pasture and sea to the grocers shelves as well

    as visibility into how the product was handled along the way. RFID improves both.

    Food safety improvements

    Superior visibility into the movement of products through the supply chain provides the real time

    granular data required to make better business decisions that increase the safety of the food

    supply at every junction in the supply chain:

    Visibility into harvest times and product temperature condition enables FeFo (First to

    expire, First out) inventory management, helping product move more rapidly from field

    to fork as well as reducing the opportunity for spoilage, foodborne illness and loss of

    product.

    Distributors and grocers now have visibility into the length of time a product has been

    traveling through the supply chain, condition during transit and remaining shelf life.

    More volatile perishables can be processed first, accuracy of best by date stamps is

    increased; and distributors and grocers can recognize and refuse any product where

    quality may have been compromised s again improving food safety and quality.

    Visibility into the whereabouts of contaminated product enables manufacturers,distributors and local grocers to issue more narrow recalls recalls that are focused on

    the specific lots that are potentially tainted rather than a broad recall of a specific class of

    item. as a result, tainted food can be quickly identified and removed regardless of where

    it may be in the supply chain, reducing the opportunity for inadvertent consumption and

    the resulting food-related illnesses and improving the success rate of recalls.

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    More reliable data The ability to automatically collect data by reading an RFID tag

    helps to error proof data collection. And the improved accuracy of the data in yoursystem helps increase product safety.

    brand protection RFID can help enterprises in the food supply chain prevent brand

    damage by providing the information needed to instantly spot and contain incidents

    before they can impact sales and brand value. The impact of outbreaks and the effect on

    the food industry as a whole cannot be underestimated. In response to recent recalls, 38

    percent of consumers stopped buying certain food products in 2007 a 400 percent

    increase over the 9 percent in 2006. of the 38 percent: 71 percent avoided spinach, 16

    percent avoided lettuce, 9 percent avoided bagged salads and 8 percent avoided beef. FID

    can help enterprises prevent and mitigate incidents, reducing the potential negative

    impact on brand equity and sales.

    Reduction in liability The ability to rapidly identify and remove potentially tainted

    food items from the supply chain minimizes the opportunity for foodborne illness and

    the associated liabilities.

    Supply chain efficiency improvements

    The same information that helps protect food as it moves through the supply chain also increases

    the efficiency of the supply chain, protecting profitability through:

    Loss protection The ability to move perishables through the supply chain as quickly as

    possible helps maximize product shelf life and prevent shrink due to spoilage.

    Productivity improvements The automated data capture eliminates the need for

    workers to capture information on paper forms, which in turn increases throughput

    existing staff can now process more product per day.

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    Substantial reduction in the cost of recalls Real-time visibility into the exact

    whereabouts of any contaminated product enables a targeted recall effort that can beexecuted at a fraction of the time and cost associated with a traditional widespread recall.

    Cost-effective regulatory compliance complying with new government regulations can

    be a costly endeavor. Through automated collection of regulatory data and more, RFID

    enables businesses to easily comply with new regulations without a substantial impact on

    margins.

    DEVELOPMENT OF NEW APPROACHES TO SUPPLY CHAIN MANAGEMENT

    Examples of recent developments in food preservation technology are

    High pressure processing,

    Food irradiation,

    Pulsed electric fields and pulsed light.

    These new technologies enable manufacturers to provide innovative products as well as meet

    food safety objectives.

    High Pressure Processing: refers to high pressure used for food preservation. "Pressed inside

    a vessel exerting 70,000 pounds per square inch or more, food can be processed so that it retainsits fresh appearance, flavor, texture and nutrients while slowing spoilage by killing E.

    coli, Salmonella and Listeria pathogens (but not Clostridium botulinum). "Using hydrostatic

    pressure, water is pumped into a sturdy closeable steel vessel. Foods of any shape or size are

    equally squeezed around its surface area without crushing the food particles. It's effective on

    most moist foods, such as fruits, vegetables, sauces and ready-to-eat meats. It can even shell

    whole uncooked lobster.The high pressure cycle takes no longer than six minutes, compared to

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    traditional high-temperature processing that takes an hour or longer, without causing chemical

    changes that degrade food quality."It is successful in improving flavor retention and sensory

    quality in a range of foods, for example fruit juices, fruit and vegetable purees, processed meat

    products, and seafood. The technology is successful also in controlling microbial levels in

    many situations, and it provides a good example of equivalence to traditional high temperature

    heat treatment.

    Food Irradiation is the process of exposing food to ionizing radiation to

    destroy microorganisms, bacteria, viruses, or insects that might be present in the food. Further

    applications include sprout inhibition, delay of ripening, increase of juice yield, and

    improvement of re-hydration. Irradiation is a more general term of deliberate exposure ofmaterials to radiation to achieve a technical goal (in this context "ionizing radiation" is implied).

    As such it is also used on non-food items, such as medical hardware, plastics, tubes for gas-

    pipelines, hoses for floor-heating, shrink-foils for food packaging, automobile parts, wires and

    cables (isolation), tires, and even gemstones. Compared to the amount of food irradiated, the

    volume of those every-day applications is huge but not noticed by the consume .It shas the

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    capacity to play an important role in food safety management, but consumer acceptance has been

    until recently quite low in some countries.

    Gamma Irradiator for food processing

    Electron Beam Irradiator for food processing

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    Application

    On the basis of the dose of radiation the application is generally divided into three main

    categories as detailed under:

    Low Dose Applications (up to 1 kGy)

    Sprout inhibition in bulbs and tubers 0.03-0.15 kGy

    Delay in fruit ripening 0.25-0.75 kGy

    Insect disinfestations including quarantine treatment and elimination of food borne

    parasites 0.07-1.00 kGy

    Medium Dose Applications (1 kGy to 10 kGy)

    Reduction of spoilage microbes to prolong shelf-life of meat, poultry and sea foods under

    refrigeration 1.503.00 kGy

    Reduction of pathogenic microbes in fresh and frozen meat, poultry and sea foods 3.00

    7.00 kGy

    Reducing the number of microorganisms in spices to improve hygienic quality 10.00 kGy

    High Dose Applications (above 10 kGy)

    Sterilization of packaged meat, poultry and their products which are shelf stable without

    refrigeration. 25.00-70.00 kGy

    Sterilization of Hospital diets 25.00-70.00 kGy

    Product improvement as increased juice yield or improved re-hydration

    It is important to note that these doses are above those currently permitted for these food items

    by the FDA and other regulators around the world. The Codex Alimentarius Standard on

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    Irradiated Food does not specify any upper dose limit .NASA is authorized to sterilize frozen

    meat forastronauts at doses of 44 kGy as a notable exception. Irradiation treatments are also

    sometimes classified as radappertization, radicidation and radurizatio.

    Pulsed electric fields and pulsed light:

    Two new technologies for use in the food industry are described. The first method discussed usesintense pulse of light. This pulsed light (Pure Bright) process uses short duration flashes of broad

    spectrum "white" light to kill all exposed microorganisms, including vegetative bacteria,

    microbial and fungal spores, viruses, and protozoan oocysts. Each pulse, or flash, of light lasts

    only a few hundred millionths of a second (i.e., a few hundred microseconds). The intensity of

    each flash of light is about 20,000 times the intensity of sunlight at the earth's surface. Theflashes are typically applied at a rate of about one to tens of flashes per second. For most

    applications, a few flashes applied in a fraction of a second provide an effective treatment. Highmicrobial kill can be achieved, for example, on the surfaces of packaging materials, on

    packaging and processing equipment, foods, and medical devices as well as on many other

    surfaces. In addition, some bulk materials such as water and air that allow penetration of the lightcan be sterilized. The results of tests to measure the effects of pulsed light on Salmonella

    enteritiditis on eggs are presented. The second method discussed uses multiple, short duration,

    high intensity electric field pulses to kill vegetative microorganisms in pumpable products. This

    pulsed electric field (or Cool Pure) process can be applied at modest temperatures at which noappreciable thermal damage occurs and the original taste, color, texture, and functionality of

    products can be retained.

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    High pressure processing of consumer packages

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    A bulk processing line for high-pressure treatment of foods contained in bulk

    packages. The contents are later transferred into retail packages.

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    A high pressure processing system for pumpable foods

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    NOTE: Advances in predictive microbiology have also contributed significantly to food safety

    management (McMeekin et al., 1993). Predictive microbiology, where the effects of food

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    formulation, processing conditions, packaging, and storage on the survival and growth of

    microorganisms in foods can be measured and assessed, has enhanced the potential to apply

    equivalence assessments in food safety management. ComBase is a database where data and

    predictive tools on microbial responses to food environments are freely available via web-based

    software. The database contains information about how microorganisms respond to different

    food properties and environments.

    REVOLUTION IN INTERNATIONAL FOOD SAFETY STANDARDS

    The food supply chain on which we all rely extends farther and goes deeper than ever before. For

    example, a piece of fruit grown in Africa can be on grocery store shelves in Europe within 24hours of harvest. Coffee from Asia wends its way to shops across Europe. Lamb from New

    Zealand is enjoyed across the UK and North America. With such a far-reaching supply chain in

    place, carrying such an essential product as food, having the proper security and safety measures

    in place is vital. A robust, independently verified food management system could make a real

    difference by improving a food organization's flexibility, readiness and ultimate viability in the

    face of an ever-changing risk environment. This is particularly true when set against the

    backdrop of current economic pressures, when there is a temptation to cut corners. Under the

    circumstances, the need for food safety has never been greater. And yet, to this day, there has not

    been a unified, internationally accepted food safety management solution in place to do the job.

    Good progress has been made by the industry to date. It was concern over potential risks in the

    food supply chain that prompted the creation of a number of early food safety sector initiatives

    and standards, including HACCP and the BRC and IFS retailer driven food manufacturing

    standards along with Euro GAP for the pre-farm gate sector. But it was not until the publication

    of international food safety management system standard ISO 22000 in 2005 that there was a

    single standard covering the entire food supply chain.

    Adoption of ISO 22000 throughout all sectors of the industry has been relatively poor. In

    particular, in the highly influential food manufacturing sector, it quickly became apparent that

    ISO 22000 had limitations. From a technical perspective, the requirements on prerequisiteprogrammes (PRPs) were not deemed to be specific enough to meet stakeholder needs.

    Another limitation revolved around the position of the internationally recognized organization,

    the Global Food Safety Initiative (GFSI). Without the appropriate PRPs and scheme ownership,

    ISO 22000 could not be benchmarked by the GFSI and given the same approval as other

    standards.

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    "The food safety landscape is very straight-forward," says Steve Mould, worldwide quality

    management systems manager at Kraft Foods. "Food safety standards need to be recognized by

    the GFSI but ISO 22000 could not on its own. ISO 22000 gives lists of PRP topics to consider,

    but because it covers the whole of the food industry, it does not include PRPs for each step:

    otherwise it would need to be the size of an encyclopedia. Something else was needed to fill the

    gap and give ISO 22000 the support that was needed.

    BRC Global Standard for Food Safety

    The BRC (British Retail Consortium) Global Standard for Food Safety was created to ensure

    supplier compliance and secure retailers ability to guarantee the quality and safety of the food

    products they sell. Today it is used worldwide as a framework for any business (retailers and

    processors) to assist the production of safe food and the selection of reliable suppliers.

    The BRC Global Standard for Food Safety is one of the operational tools most frequently used

    for due diligence and supplier approval. It helps companies to select and qualify their suppliers.

    Thus, the system reduces the overall costs of the supply chain management and increases the

    level of safety for customers, suppliers, and consumers. Regarded as a ticket-to-trade, thestandard is also a great opportunity to demonstrate your companys commitment to food safety,

    quality, and legality, and to work on continual improvement.

    What is the standard?

    The main retailers in the United Kingdom were concerned about food safety because of their

    direct responsibility in case of an incident. To take control of the situation, retailers require that

    all food suppliers be certified to a specialized standard to ensure that they comply with quality

    and safety demands, and legal requirements. After the first issue in 1998 the standard wasregularly improved, involving international stakeholders in the supply chain. Today it is a global

    tool based on the most recent and updated food safety standards and methodologies. The

    requirements in the standard are related to the quality management system and the HACCP

    system, supported by detailed prerequisite programmes, that is a set of GMP (Good

    Manufacturing Practice), GLP (Good Laboratory Practice) and GHP (Good Hygiene Practice)

    requirements.

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    The BRC Global Standard for Food Safety enables the Organization to:

    Provide evidence of commitment, and, in case of a food safety incident, legal defense in

    the frame of the due diligence concept.

    Build and operate a management system capable of helping you to better meet

    food quality/safety requirements and legal compliance, with specific reference to the

    legislation applicable in the countries where the finished product is consumed.

    Provide a tool for food safety performance improvement and the means to monitor and

    measure food safety performance effectively

    Facilitate reductions in product waste, product reworking, and product recall.

    Certification to BRC Global Standard for Food Safety also supports efficient supply

    chain management by reducing second party audits and increasing your overall supply

    chains reliability.

    TRACEABILITY IN FOOD SUPPLY CHAIN:FOR ENSURING SAFETY

    What Is Traceability?

    ISO (International Organization for Standardization), which develops voluntary

    international standards for products and services, defines traceability as the abilityto trace the history, application, or location of that which is under consideration.

    This definition is quite broad. It does not specify a standard measurement for that

    which is under consideration (a grain of wheat or a truckload), a standard location

    size (field, farm, or county), a list of processes that must be identified (pesticide

    applications or animal welfare), or a standard identification technology (pen and

    paper or computer). It does not specify that a hamburger be traceable to the cow or

    that the wheat in a loaf of bread be traceable to the field. It does not specify which

    type of system is necessary for preserving the identity of tofu-quality soybeans;

    controlling the quality of grain used in a particular cereal; or guaranteeing correct

    payments to farmers for different grades of apples.

    The definition of traceability is necessarily broad because food is a complex product

    and traceability is a tool for achieving a number of different objectives. As a result,

    no traceability system is complete. Even a hypothetical system for tracking beefin

    which consumers scan their packet of beef at the checkout counter and access the

    animals date and location of birth, lineage, vaccination records, and use of

    mammalian protein supplementsis incomplete. This system does not provide

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    traceability with respect to bacterial control in the barn, use of genetically

    engineered feed, or animal welfare attributes like hours at pasture and play time.

    A system for tracking every input and process to satisfy every objective would be

    enormous and very costly. Consequently, firms across the U.S. food supply systemhave developed varying amounts and kinds of traceability. Firms determine the

    necessary breadth, depth, andprecision of their traceability systems depending on

    characteristics of their production process and their traceability objectives.

    Breadth describes the amount of information collected. A recordkeeping

    system cataloging all of a foods attributes would be enormous, unnecessary,

    and expensive. Take, for example, a cup of coffee. The beans could come

    from any number of countries; be grown with numerous pesticides or just a

    few; be grown on huge corporate organic farms or small family-runconventional farms; be harvested by children or by machines; be stored in

    hygienic or pest-infested facilities; and be decaffeinated using a chemical

    solvent or hot water. Few, if any, producers or consumers would be interested

    in all this information. The breadth of most traceability systems would

    exclude some of these attributes.

    Depth is how far back

    or forward the system

    tracks the relevant

    information. For

    example, a traceabilitysystem for

    decaffeinated coffee

    would extend back only

    to the processing

    stage. A traceability

    system for fair-trade

    coffee would extend

    only to information on

    price and terms of trade between coffee growers and processors. A

    traceability system for fair wages would extend to harvest; for shade grown,to cultivation; and for no genetically engineered, to the bean or seed. For

    food safety, the depth of the traceability system depends on where hazards

    and remedies can enter the food production chain. For some health hazards,

    such as Bovine Spongiform Encephalopathy (BSE, or mad cow disease),

    ensuring food safety requires establishing safety measures at the farm. For

    other health hazards, such as foodborne pathogens, firms may need to

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    establish a number of critical control points along the entire production and

    distribution chain.

    Precision reflects the degree of assurance with which the tracing system can

    pinpoint a particular food products movement or characteristics. In some

    cases, the objectives of the system will dictate a precise system, while for

    other objectives a less precise system will suffice. In bulk grain markets, for

    example, a less precise system of traceability from the elevator back to a

    handful of farms is usually sufficient because the elevator serves as a key

    quality control point for the grain supply chain. Elevators clean and sort

    deliveries by variety and quality, such as protein level. Elevators then blend

    shipments to achieve a homogeneous quality and to meet sanitation and

    quality standards. Once blended, only the new grading information is relevantthere is no need to track the grain back to the farm to control for quality

    problems. Strict tracking and segregation by farm would thwart the ability of

    elevators to mix shipments for homogeneous product.

    What Does It Do?

    Firms have three primary objectives in using traceability systems: improve supply

    management; facilitate trace back for food safety and quality; and differentiate and

    market foods with subtle or undetectable quality attributes. The benefits associated

    with these objectives include lower cost distribution systems, reduced recall

    expenses, and expanded sales of products with attributes that are difficult to

    discern. In every case, the benefits of traceability translate into larger net revenues

    for the firm. These benefits are driving the widespread development of traceability

    systems across the U.S. food supply chain.

    Traceability to improve supply management

    Industry analysts calculate that during 2000, American companies spent $1.6 trillion

    on supply-related activities, including the movement, storage, and control of

    products across the supply chain. The ability to reduce these costs often marks the

    difference between successful and failed firms. In the food industry, where margins

    are thin, supply management, including traceability, is an increasingly important

    area of competition. A firms traceability system is key to finding the most efficient

    ways to produce, assemble, warehouse, and distribute products.

    Electronic coding systems, from the granddaddy barcode system to cutting-edge

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    technologies like radio-frequency identification systems, are helping to streamline

    the U.S. food supply system. As technological innovation drives down the cost of

    these devices, more firms across the food supply chain are using electronic tracking

    systems. In some cases, buyers manage these systems to monitor internal supply

    flow. In others, firms establish systems that link suppliers and buyers, allowing them

    to automate reordering. Retailers such as Wal-Mart have created proprietarysupply-chain information systems, which they require their suppliers to adopt.

    Inventory-to-sales ratios are further evidence that U.S. companies are embracing

    new logistic systems to better control inventory flow. The ratio of private inventories

    to final sales of domestic business has fallen by half since the end of WWII. The

    same trend can be observed in many sectors of the domestic food industry,

    including natural, processed, and imitation cheese; cereal breakfast foods; and soft

    drinks and carbonated waters. In each case, the inventory-to-sales ratio fell, with

    the largest decline in the cereal sector, where the ratio fell from over 8 percent in

    1958 to 3-4 percent in the early 1990s. This downward trend in inventories reflects

    growing efficiencies in supply management in the U.S. food industry, including

    traceability systems. This trend is expected to continue as food manufacturers

    continue to adopt technologies already in use in other industries.

    Traceability for safety and quality control

    Traceability systems help firms isolate the source and extent of safety or quality

    control problems. This helps reduce the production and distribution of unsafe orpoor-quality products, which in turn reduces the potential for bad publicity, liability,

    and recalls. The better and more precise the tracing system, the faster a producer

    can identify and resolve food safety or quality problems. One surveyed milk

    processor uniquely codes each item to identify time of production, line of

    production, place of production, and sequence. With such specific information, the

    processor can trace faulty product to the minute of production and determine

    whether other products from the same batch are also defective.

    Many buyers, including many restaurants and some grocery stores, now require

    their suppliers to establish traceability systems and to verify, often through third-

    party certification, that such systems work. The growth of third-party standards and

    certifying agencies is helping push the whole food industrynot just those firms

    that employ third-party auditorstoward documented, verifiable traceability

    systems.

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    Traceability to market and differentiate foods

    The U.S. food industry is a powerhouse producer of homogeneous bulk

    commodities such as wheat, corn, soybeans, and meats. Increasingly, the industryis tailoring goods and services to the tastes and preferences of various groups of

    consumers. Consumers easily spot some of these new attributesgreen ketchup is

    hard to miss. However, other innovations involve credence attributes,

    characteristics that consumers cannot discern even after consuming the product.

    Consumers cannot, for example, taste or otherwise distinguish between

    conventional corn oil and oil made from genetically engineered (GE) corn.

    Credence attributes can describe content or process characteristics of the product.

    Content attributes affect the physical properties of a product, although they canbe difficult for consumers to perceive. For example, consumers are unable to

    determine the amount of isoflavones in a glass of soymilk or the amount of calcium

    in a glass of enriched orange juice by drinking these beverages.

    Process attributes do not affect final product content but refer to characteristics

    of the production process. Process attributes include country of origin, free-range,

    dolphin-safe, shade-grown, earth-friendly, and fair-trade. In general, neither

    consumers nor specialized testing equipment can detect process attributes.

    Traceability is an indispensable part of any market for process credence

    attributesor content attributes that are difficult or costly to measure. The only way

    to verify the existence of these attributes is through recordkeeping that establishes

    their creation and preservation. For example, tuna caught with dolphin-safe nets

    can only be distinguished from tuna caught using other methods through a

    recordkeeping system that ties the dolphin-safe tuna to an observer on the boat

    from which the tuna was caught. Without traceability as evidence of value, no

    viable market could exist for dolphin-safe tuna, fair-trade coffee, non-biotech corn

    oil, or any other process credence attribute.