A combination of the legislation and the Sudan 1 case raises the question of what steps have been taken, if any, by suppliers in improving the ability to trace food ingredients in the supply chain and whether it will take another high profile case to invoke further changes.
Sudan 1 highlighted the ambiguity of the EU General Food Law Regulation’s ‘on demand’ element. The legislation stipulated that food companies must be able to identify where they got their products from and who they sold them to. This is referred to as “one up, one down” traceability. No pressure was enforced on the time it had to take. Whilst the Food Law Regulation provides a framework for firms to work with, the real changes within the industry are not being driven by legislation. Instead, suppliers and large retailers are driving this process by their own need to achieve higher standards, plant efficiencies and maintain customer confidence.
Progress is uneven across the food and beverage industry. Organisations taking steps towards reducing the time it takes to trace and recall a product face a series of barriers. While most large UK organisations have traceability systems in place, there are many using non-UK suppliers, often from outside the EU.
Preventing contamination of any food stuff is a complex task. There are barriers which UK firms face in meeting the EU General Food Law Regulation. Managing processes in the supply chain is multi-faceted. Many manufacturers will use alternative or new suppliers ad-hoc to meet demand or when faced with shortcomings from existing suppliers. Manufacturers often struggle to make all the necessary checks as to the provenance of the suppliers’ products. Internal traceability systems should be developed to control food products entering and leaving the supply chain. Internal traceability of ingredients can reduce costs and limit damage through more targeted and quicker recalls. Most organisations using an integrated software system with traceability functionality can reduce the time it takes to carry out a mock recall from days or weeks to just hours.
If producers link traceability and enterprise resource planning (ERP) systems to the process control systems on the factory floor, faulty products entering the supply chain can be stopped immediately before they enter the production process. Equally important is access to live information. Customer and consumer confidence can be lost quickly if suppliers are not able to react instantly to food quality or safety issues and yet the food and beverage industry at large still lacks the ability to monitor and record data in real time.
This makes it hard for manufacturers to have genuine control over their processes and effectively manage recalls. Several systems exist enabling manufacturers to not only comply with legislation, but also to meet and exceed retailer demands, and to go even further in improving the speed and accuracy of traceability throughout the supply chain. However, will it take another case similar to Sudan 1 to enforce stricter changes and to speed up adoption of such systems. Some manufacturers have implemented traceability processes already, if only to comply with legislation. This low level of adoption means many will have the basic processes to enable them to be legally compliant and no more.
National and European laws tend to be passed in response to events rather than in anticipation of future events or demand. Stricter regulation is unlikely to be passed unless there is industry consensus that it is required or another public crisis occurs within the supply chain. Companies who have not made significant progress must work towards having four key objectives: minimising product safety risks by reducing manufacturing variability; improving traceability throughout the supply chain by linking the ERP system and establishing it as an operational system of record for the whole enterprise ( a customer’s traceability times was reduced from a day to 15 minutes); establishing and implementing an executive-led, cross-functional management programme; and suppliers must collaborate with customers, partners and regional agencies.
Companies involved in the food supply chain must move towards a business model where they can produce records immediately ‘on demand’. If they do not, they will not stay in business, irrespective of the law. Routes are being taken but it is progressive.
Steve Baxter is managing director of Ross Systems UK.
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