Presentation regarding Produce Traceability as presented to FDA & FSIS on December 9 & 10, 2009 in Washington, D.C.

1. United States Department of Agriculture
Food Safety and Inspection Service
Traceback Investigations in Meat
and Poultry Plants
Kenneth E. Petersen, DVM, MPH
Assistant Ad i i t t
A i t t Administrator
Office of Field Operations
USDA/FSIS

2. United States Department of Agriculture
Food Safety and Inspection Service
Enforcement, Investigations,
and A l i Offi
d Analysis Officer Summary
S
1. The primary objective of the EIAO when gathering
traceforward and traceback information in-plant, is to
in plant
determine the scope of products implicated by the
foodborne illness investigation.
2.
2 They d
Th determine if microbiological separation exists i
i i bi l i l i i in
order to define the scope of impacted product.
3. Assess sanitation and HACCP records.
4. The EIAO’s observations and summary will help the
Epi lead investigator and recall committee to determine
the extent of implicated product
product.

3. United States Department of Agriculture
Food Safety and Inspection Service
Traceforward
Product from a
federally-inspected Est. EIAO sent to
EIAO Conducts an initial meeting
implicated the Est. to
with Est. management to explain
gather
May be a spec c type
ay specific ype the situation and request required
traceforward documentation
of product or a specific information
production date
EIAO summarizers the information
EIAO reviews documentation for the FDIB lead investigator.
and observes the process to look
p
for any potential areas of cross This i f
Thi information is often used by the
ti i ft d b th
contamination Recall Committee to determine the
scope of a recall.

4. United States Department of Agriculture
Food Safety and Inspection Service
Records Requirements
• 21 USC 642, 9 CFR 320, 9 CFR 417 – Records,
Registration, and Reports
g , p
– Shall keep such records as will fully and correctly disclose all
transactions involved in their business
– Records have to be kept and made available for review
– Specific information is required on the bill of sale (e.g., the
product, the buyer, the seller, net weights number of containers)
– Records of specific processes are required (e g shippers
(e.g.
certificates, canning records, records of Advanced Meat
Recovery/bone separation machinery)
– Specified retention periods

5. United States Department of Agriculture
Food Safety and Inspection Service
Typical Records Reviewed
1. Production Logs 3. HACCP/SSOP/
– Grinding Logs Prerequisite program
P i it
– Cooking Logs records
– Slaughter Data
g – Letters of Guarantee
2. Inventory Records – Certificates of Analysis
– Receiving Logs – Sampling Results
– Bill of L di
f Lading – CCP Records
– Invoices – Maintenance Records
– Labels

6. United States Department of Agriculture
Food Safety and Inspection Service
Information Gaps
• Traceback and Traceforward
– P
Poor documentation on use of source materials and product fl
d t ti f t i l d d t flow
through the production system on a given day
– Non-specific lotting or identification of separate lots
– No records supporting the microbiological separation of products
– These inadequacies typically lead to expanding the scope of
implicated product
• Distribution
– Firms provide Customer Lists rather than Consignee Lists