a guide to traceability within the fish industry · the traceability projects discussed in bremen...

A Guide to Traceabilitywithin theFish Industry

Traceability book final version.qxd 28/04/2004 17:25

A Guide to Traceability within the Fish Industry

Preface

With the introduction of recent legislation by both the European Union and theUSA, traceability of products throughout the supply chain is now an important andmandatory aspect of company operations in what is a global market for fishery andseafood products.

Although many components of a traceability system are implemented within thefishing industry, as part of other management systems, it is essential that they areintegrated into a single management system in order to demonstrate an individualscompany has an effective operation and proves that it works.

In this publication, the requirements of traceability systems are presented, togetherwith examples from the supply chain of different methods available to ensureproduct traceability and a structured approach to developing the necessarydocumentation.

It is hoped that this guide will assist companies in understanding and implementingtraceability within the fisheries industry. The guide is a shared publication fromEurofish and the Swiss Import Promotion Programme (SIPPO).

EUROFISH SIPPO

Victor Hjort Markus Stern

Traceability book final version.qxd 28/04/2004 17:25 Page 1

The Humber Institute Food & Fisheries (HIFF)

The objective of this book is to provide a practical guide to establishingtraceability systems within the fish industry and to act as a source book for furtherinformation on the subject. This project is on-going and comments, questions andsuggestions on improving traceability would be welcomed.

The book is based on a series of practical project's on traceability led by theInstitute based in our own pilot plant or in real factories. Support has been receivedfrom the Learning Skill's Council in the UK (LSC) as their funding assisted in thecreation of the educational programmes to support the projects. Further the NewTechnology Institute funding enabled the pilot testing of a range of moderntechnology which enables traceability in a complex factory environment. Theproject outputs and a draft of the booklet were presented to the Bremen Fish Trademeeting attended by a large number of Government and Industry representativesinterested in working on resolving the traceability issues.

The traceability projects discussed in Bremen were developed in the Institute pilotplant (Food Dynamo) and are being transferred into working systems in localfactories. HIFF also leads the Centre of Excellence in Food Manufacturing (CoVE)- between the CoVE and NTI over 100 factory supervisors or managers will beinvolved in work-based projects this year.

This is the beginning of the traceability story, the forty people we have currentlyworking in a range of seafood traceability projects will continue to add to ourknowledge on what works in practical situations. We look forward to sharing theknowledge as we advance.


Contents

1. The significance of traceability to the fishing industry.............................1What is traceability?.................................................................................. 1The need for traceability.............................................................................3

2. Traceability; standards and legal requirements........................................5Codex Alimentarius Commission...............................................................5Tracefish....................................................................................................6EU legislation.............................................................................................7Non-EU legislation regarding product traceability......................................9Labelling requirements for fishery products.............................................11

3. Internal traceability systems......................................................................12Components of an internal traceability system.......................................12Product identification (ID) codes.............................................................12D a t a

management....................................................................................13Batch operations.....................................................................................15Continuous operations............................................................................15

Implementing traceability in the factory..........................................................16A. Analysis of current system......................................................................16B. Assessment of traceability in the factory................................................18C. Product recall procedure........................................................................20D. Documentation and records....................................................................22

4. Traceability systems in practice.................................................................23A. Paper-based traceability system............................................................24

Demonstrating traceability through the records....................................32Advantages and disadvantages of paper-based traceability....................33

B. Traceability using bar coding systems....................................................34Demonstrating traceability through the records.....................................40Advantages and disadvantages off using bar codes and scanners for traceability................................................................................................41

C. The use of modern technology in traceability...........................................42


Radio frequency identification (RFID) tags.............................................42Computer linked equipment.....................................................................44An integrated IT traceability system........................................................47Demonstrating traceability through the records.....................................49Discussion of traceability methods..........................................................50Advantages and disadvantages of technology-based approaches to traceability................................................................................................51

5. Traceability in the supply of fish................................................................52Aquaculture..............................................................................................52Marine capture.........................................................................................57

6. External traceability.....................................................................................59Tracing the product through the supply chain.........................................59Independent traceability systems...........................................................59Integrated traceability systems...............................................................60

7. Verification of traceability............................................................................61Planning and preparation.........................................................................62

8. Concluding remarks................................................................................66APPENDICES......................................................................................................67

Appendix 1......................................................................................................67Case study: demonstrating the importance of traceability......................67Chloramphenical in shrimp......................................................................67

Appendix 2......................................................................................................68The EAN-UCC coding system.................................................................68

Appendix 3......................................................................................................70Traceability system checklists..................................................................70

Appendix 4......................................................................................................75Technical contact details.........................................................................75

8. Bibliography..................................................................................................76Books/Papers...........................................................................................76Websites..................................................................................................78


Foreword

Food traceability, and in particular fish traceability, is today high on the agendas offish inspection services and the fisheries industries all around the world. By January2005 the food and fishery industry in the EU, and in third countries wanting to exportfood and fish products to the EU, must have implemented systems to comply withrequirements of Regulation (EU) No 178/ 2002 of the European Parliament and theCouncil of 28 January 2002.

Traceability in itself may be one of those broad concepts, like quality and quantity,for which philosophers have said that only working definitions could be attempted.Actually, as of today (April 2004) and after years of discussions, there is no officialFAO/WHO Codex Alimentarius Commission definition of “traceability”. It is evenlikely the final definition of the CAC would refer more to “product tracing” or “tracing”than to traceability. These issues, and ongoing discussions on the same subject,give a proper idea of the practical difficulties faced in this field.

Nevertheless, traceability systems are not foreign to the fishery industry, and anumber of methods and procedures at different levels of complexity but related totraceability, such as FIFO (First In First Out), are utilized in practice. However, notall the concepts, purpose and scopes, methodologies to achieve regulatorycompliance, etc. are clear enough, particularly with regard to fish and foodexporters in developing countries. The main questions may be put as follows:

• What it is traceability for my company? Need of a clear definition and scope of traceability.

• Which information should be available for tracing?

• Which methodology could my company utilize in practice to achieve compliance?

• How much would it cost my company?

In this context the “Guide to Traceability within the Fish Industry” is a timely andvery useful effort to answer in a simple, but effective way, most of the questionsdiscussed in the previous paragraph. Proposed tracing methods have beenpractically tested in the Grimsby College’s pilot plant (“Dynamo”) and are rathersimilar to methods already in use in many EU fish industries. Even though furtherdevelopment could be expected in the regulatory area of traceability/ tracing in thecoming years, surely this Guide will continue to be useful to all segments of thefishery industry chain and to fish inspection services, as well as to training andeducational institutions, for many years.

Hector M. LupinSenior Fishery Industry Officer (Quality Assurance)

Fish Utilization and Marketing ServiceFAO of the UN, Rome, Italy.


1. The Significance of traceability to the fishing industry

What is traceability?

Traceability is the ability to trace, followand identify UNIQUELY a product unitor batch through all stages ofproduction, processing and distribution.

It needs to show the path of that unit orbatch through all the intermediatesteps of the production flow and thesupply chain. The InternationalStandards Organization (ISO) definetraceability as:

"The ability to trace the history,application or location of that which isunder consideration.… whenconsidering products this can relate tothe origin of materials and parts, andthe processing history."

Another way of defining a traceabilitysystem is provided by Notermans S. &Beumer H. (Safety & Traceability ofAnimal feed in Food Authenticity &Traceability (2003)), who suggest thata traceability system has the followingcomponents.

Supplier traceability, ensures that thesource of all raw materials/ingredients can be identified from therecords and documentation.

Process traceability, ensures theability to identify all ingredients andprocess records for each individualproduct produced by the factory.

Customer traceability, ensures thatthe customers for all products can beidentified.

The overall system therefore enables

the trace-forward of product for thepurpose of product recall, theavailability of all processing recordsduring the investigation of an incidentand the trace-back of all raw materialsif this was identified as thesource/cause of the incidentnecessitating the product recall.

There are two categories of traceabilitythat are commonly discussed underthe same heading of traceability:

Internal traceability relating to thetraceability of product and theinformation relating to it, within thecompany or factory, and;

External traceability which relates toproduct information that a companyeither receives or provides to othermembers of the supply chain.

It should be noted that in both cases,traceability concerns only the ability totrace things, i.e. the specific productshould be able to be identified andlinked to the related records. This doesnot mean that all the informationshould be permanently visible by beingincluded on a product label. In manycases the amount of information thatrelates to a specific product and isrequired by the end user is too great tobe included on a label or bar code.

The information itself can be classifiedas either:

Product data which describes detailsof the product, raw material oringredient, e.g. weight, grade, species,Or

1


Transformation data, which list theID's of all raw materials and ingredientsor products and by-products producedfrom this batch.

The normal approach would be toidentify each lot/batch of fish with aunique identification code that can beused to identify the origin and be linkedto the records of other companies inthe supply chain from which the entireprocess history can be determined.

Although simple in theory, producttraceability is more complicated to putinto practice since:

The processing chain for even a simpleproduct such as fresh fish is oftencomplex, often involving variouscountries with different standards andlegal requirements.

Even within a single country the supplychain is often complex, with differencesin the routes products take fromharvesting to consumption. Thecomplexity derives from the wide rangeof fishing practices, species, finalproducts and the practices ofindividual companies involved.

Where fish are sourced from non-EUcountries the use of incompatible data-systems and accessibility to records indifferent languages may causeadditional problems.

A large amount of data is recorded byindividual companies for each product,however, not all this information isrelevant or useful to every company inthe processing chain.

For example, a fishing boat would keeprecords of exactly where, the amount ofeach species, and the time the fish

were caught. However the onlyinformation that is of interest to aprocessor would be the species,quality, location and date of capture ofthe fish.

Information is often lost during transferbetween links in the processing chain.

Fish landed at a market are oftenidentified only by the species and thedate of landing, the identity of thefishing boat, however, is often lost asthe ownership of the batch passes frommarket to purchasing agents beforereaching the processors or retailers,therefore information relating to thelocation, time and method of capture islost since it is not possible to trace backto the records of individual boats.

Mixing of individual batches of productcommonly occurs at points through outthe supply chain.

It is essential that when this occurs, theidentification of each batch is recordedand linked to the product identificationcode of the “mixed” consignment. Thisensures that, even if physicaltraceability of the individuallots/batches are lost the identities ofthe component batches within a mixedbatch are known and retained.

2


The need for traceability.

Globalization of the fish industry interms of sourcing raw materials,processing and marketing has resultedin demands for increased traceability ofproducts. This is due mainly to theincreased length of the supply chainproviding more opportunity for fisheryproducts to either lose quality or gainthe potential to cause harm to theconsumer. In order to ensure both thequality and safety of products, moreinformation concerning the sourcingand processing of the products needsto be communicated throughout thesupply chain and ultimately to theconsumer.

To ensure that this occurs, legislationhas been established which places theresponsibility of proving the productssafety and quality onto the producers,processors and retailers. This is oftenreferred to as demonstrating "DueDiligence”.

Recent incidents such as the BSE inthe UK beef industry, Chloramphenicalfrom contaminated seafood (Appendix1) being used in animal feed and mostrecently the introduction of potatoring-rot disease into the UK, havedemonstrated to both companies andthe consumers the inability to identifyand trace products through out thefood chain has a high cost.

The Competent Authorities in Europesee traceability as an integral part of acontrol system for maintaining foodsafety and consumer protection.

The UK Food Standard’s Agency hasidentified the following roles fortraceability in the food industry.

Food safety incidents: Product recallis simplified where both the source ofpotentially hazardous materials canbe rapidly identified and similarpotentially hazardous productsremoved from the supply chain. Theability to trace a product back to thesource of the hazard means thatcontrols can be established to prevent,or at least reduce, the likelihood of itre-occurring. Being able to identify allthe potentially harmful products willenable their recall and so minimise anyharm to consumers that couldnegatively affect the public opinionabout a specific product and result in areduction of sales.

Food residue surveillance programs:Product traceability facilitates theidentification of key points within thesupply chain at which product samplingis necessary to monitor residue levels(e.g. pesticide, antibiotic).

"It shall be a defence for the personcharged to prove that he took allreasonable precautions and exercisedall due diligence to avoid thecommission of the offence".

Or put another wayThere must be documented evidence ofa system that works. i.e. the proceduresemployed and the records collectedmust be available for review.

A food company is presumed guilty ofan offence until proved innocent bymeans of its documentation andevidence it verifies effective control.

3


Risk assessment from foodexposure: By linking information toprovide access to the entire history of aproduct from net to plate, the origins ofproducts or ingredients that may havefood safety implication can easily beidentified.

Prevention of fraud andenforcement of labelling claims:Traceability together with regularaudits of records can prevent fraud withrespect to product origin, species, etc.

Consumers are requesting greaterinformation related to products onwhich to base purchasing choices, formoral, ethical and religious reasons.Examples of information oftenrequested include; environmental andecological issues, GMO, ingredientsand nutritional data.

It is not only the consumers that arerequesting further information;processing companies and retailersoften require documented evidence tosupport marketing campaigns and topromote the sale of their products, inline with customer expectations.Examples of this would include"dolphin friendly tuna", "Caught from asustainable fishery", MSC accreditationor to denote the source for marketingpurposes e.g. Scottish Salmon.

There are therefore definite benefits fora company from implementingtraceability systems which include:

A company's obligations under EUlegislation are met. This of course onlyapplies to those companies whooperate within, or wish to export to, theEU markets.

Other links within the supply chain

require traceability, therefore byproviding this information with theproduct the potential market for theproduct is increased.

Consumer expectations aredemonstratably achieved. This canprovide added value to the productwhen the product origin is linked tospecific branded products or claimssuch as "Wild Scottish salmon".

Process control and factoryefficiency can be improved by:

• minimising losses during a productrecall to only the affected products.

• using product information linked toprocessing data to improve qualityand consistency by proactivelyreviewing records and identifyingimprovement opportunities.

To summarise, traceability is anintegrated concept in modernregulatory and management systemsgoverning not only food safety but alsoother issues such as consumerinformation.

Traceability is also an essential riskmanagement tool enabling individualmembers of the supply chain toidentify the source(s) of problemsquickly and rapidly disseminate thisinformation to affected parties, thusincreasing business efficiency.

4


2. Traceability: standards and legal requirements

There has always been a degree oftraceability within the food industry,with individual companies able toidentify both their suppliers andcustomers. In recent years howeverthe role of traceability in the control andsafety of food has been identified asrequiring greater transparency andregulation. This has been achieved bythe development of internationalstandards, industry guidelines andlegislation.

Codex AlimentariusCommissionThe Codex Alimentarius Commission(CAC), was formed under the jointsponsorship of the United Nation's,World Health Organisation (WHO) andFood & Agriculture Organisation (FAO)in 1962, to develop internationalstandards for food safety. The mainpurpose of the CAC is to protect thehealth of the consumer and ensure fairtrade practices by developingstandards based on sound scientificevidence. The World tradeOrganisation (WTO) has designatedCAC the organisation with theresponsibility for settling trade disputesrelating to food, specifically as theyrelate to the Codex standards ofApplication of Sanitary andPhytosanitary measures (SPS) and theAgreement on Technical Barriers toTrade (TBT).

As such the CAC produce guidelines tobe incorporated into regulations ofindividual countries, rather thanspecific legislative requirements.In terms of traceability the issue hasbeen discussed in various committeesand the following standards that relate

to product traceability have beendeveloped:General Standard for Pre-packagedFood (GSPPF).Sec. 4.5.1: The country of origin of thefood shall be declared if its omissionwould mislead or deceive theconsumer.Sec. 4.5.2: When a food undergoesprocessing in a second country whichchanges its nature, the country inwhich the processing is performedshall be considered to be the country oforigin for the purpose of labelling.

Guidelines for Generic OfficialCertificates Formats and theProduction and Issuance ofCertificates. CAC/GL 38-200116. The details of the product beingcertified should be clearly documentedon the certificate which should at leastcontain the following information.

• nature of the food;• name of the product;• quantity, in appropriate units;• lot identifier or date coding;• identity and, as appropriate thelocation of production establishment;• name and contact details ofimporter or consignee;• name and contact details ofexporter or consignor;• country of dispatch;• country of destination;

These details are not specific to foodbut constitute the normal fields ofinformation contained in any Bill ofLading for trade between twocountries.

5


There is currently an ongoing debatewithin CAC on the extent to whichtraceability should be made amandatory requirement in the foodindustry. Although much of thediscussion is based on the introductionof genetically modified organisms(GMO) and therefore only of minorconcern to seafood (e.g. use of GMOsin fish feed production). Theimplications and in many cases theregulations that have been introducedapply to the entire food industryincluding the fisheries sector.

On one side of the debate is theEuropean Union, whose position is thattraceability is an integral component offood safety control and as such its useshould be made mandatory for all foodsectors.

TraceFish

The TraceFish project was establishedunder an EU concerted action project(Q L K 1 - 2 0 0 0 - 0 0 1 6 4 ) . Voluntarystandards were agreed on for specificsectors. The specifications wereestablished by the group of Europeanbusiness and research organizations.The standards relate to the informationthat should be recorded at each stageof the supply chain in order to maintaintraceability. These standards detailed:

• required information for capturedfish distribution chains;

• required information for farmed fishdistribution chains;

• a technical specification for theelectronic encoding of data, based onthe EAN.UCC numbering system.

Each piece of information (data

element) that was to be collected wasprovided with a unique identity codeand categorised as either:

Shall; The information is necessary toensure product traceability e.g.processing establishment identity(name, address, registration numberetc).

Should; It is recommended that thisinformation is recorded, e.g. Producttemperature at reception. Thiscategory normally may not be criticalfor ensuring product traceability butprovides important links to processingrecords.

May; The information is not necessaryfor traceability however it may bebeneficial for the business to do so,e.g. names of fish quality, or foodsafety GMP schemes by whichprocessor is certified.

The key to this system is the labellingof each unit of goods traded with aunique identifier (ID) by the businessresponsible for producing ortransforming the product.

The term "transforming the product" isused to describe the assigning of anew ID whenever specific units aremixed i.e. mixing of individual batches,addition of ingredients etc.

Each company then relates all processdata to this unique identifier code all ofwhich is held on their own computerdatabase.

Since all information is encoded in thespecified format, when the source andhistory of a product needs to be tracedit is easily achieved since all theinformation throughout the supply

6


chain is in the same standardisedformat.

This also means that when necessary,the information is easily transferred toother databases via e-mail, for collationand analysis with data from other linksin the supply chain, by either thecompetent authority or independentauditors.

Full details of the Tracefish project andthe specifications are available on thewebsite: www.tracefish.org.

EU Legislation

Food legislation in the European Union(EU) and how it is implemented withinindividual member states can seemcomplicated and confusing. In generaldirectives are classed as eitherhorizontal or vertical; with "horizontal"legislation being applicable to ALL foodstuffs e.g. hygiene, additives, labellingrequirements etc, and vertical beingapplicable to specific food sectors,such as Fish, Meat, Dairy.

Current EU Legislation refers directlyand indirectly to traceability both forgeneral food and specifically fisheryproducts.

The most significant E.U. legislationrelating traceability is:

Council and European ParliamentRegulation (EC) No 178/2002 layingdown the general principles andrequirements of food law, establishingthe European Food Safety Authorityand laying down procedures in mattersof food safety. (O.J. L31 1Feb 2002).

A central component of this regulationis that in order to ensure the safety of

food the food production chain shouldbe treated as a continuum from primaryproduction to the consumer and thatthis includes production of animalfeeds.

Included in this regulation are;

Article 18: TraceabilityThis makes it compulsory for allsubstances intended or expected to beincorporated into food to be tracedback to the supplier and customers;and that systems are operated in orderto provide this information to thecompetent authority upon request. It isalso necessary that all food or animalfeed placed in the market beadequately labelled to facilitate itsidentification and traceability.

Article 19: outlining the responsibilitiesof food business operators.

Article 20: outlining the responsibilitiesof feed manufacturers

Articles 19 & 20 make theresponsibility of individual companiesto immediately:

withdraw product suspected of beingunfit for human consumption.

inform the competent authority ofsuch incidents and cooperate withthem to reduce or eliminate the riskassociated from a product.

Article 11: Requires that all food andfeed imported from third countriesexported to the EU meet therequirements of this regulation or atleast be equivalent.

Although the regulation came into forcein 2002, the articles relating to

7


traceability will not come into force untilJanuary 1st 2005. Other legislationconcerning traceability is:

Directive 2001/95/EC on generalproduct safety which requirescompanies to:

• have traceability back to point ofproduction

• have systems to recall unsafeproducts

• to notify competent authotities ofunsafe products

Traceability and product recallsystems are therefore a currentrequirement for all food products inthe E.U.

Other EU legislation, although notspecific to traceability and productrecall systems, regulate variouscomponents of such systems in thefisheries industry. The followingregulations are not an exhaustive listbut provide details of specific examplesthat are related to traceability.

Directive 93/43/EEC on the Hygieneof foodstuffs:

Details the obligations of foodbusinesses with respect to hygieneand introduces the requirement for allfood handlers to exercise duediligence.

Directive 91/493/EEC laying down thehealth conditions for the productionand the placing on the market of fisheryproducts, provides further regulationson hygiene specific for the fish industry.

Directive 89/396/EEC made it arequirement that all food products were

identified by a "lot" number, where a lotwas defined as

"a batch of sales units of a foodstuffproduced, manufactured or packagedunder practically the same conditions".

Where the food was pre-packed thismeans a label attached to thepackaging or in the case ofnon - pre - packed products byaccompanying documentation.

Directive 2003/89/EC amendingDirective 2000/13/EC as regardsindication of the ingredients present infoodstuffs, which must be implementedby Member States by 25 November2004 removes the earlier regulationthat exempts from labelling thosecompound ingredients constituting lessthan 25% of the final product andreplace it with mandatory labelling forALL compound ingredients and inparticular those food known to bepotential allergens, such as nuts andseafood.

Other E.U. legislation that applies tothe capture or production of fisheryproducts and contains points related totraceability includes;

Council Regulation (EEC) No2847/93 establishing a controlsystem applicable to the commonfisheries policy and CouncilRegulation (EC) No 2371/2002 on theconservation and sustainableexploitation of fisheries resourcesunder the Common Fisheries Policy

require that all vessels over 15 m (from1 January 2005) are monitored bysatellite and that member states keepcomputer records relating to vesselidentity, position and catch data.

8


An essential component of anytraceability system is the productlabelling. The legal requirements inCouncil Regulation (EC) No104/2000 on the common organisationof the markets in fishery andaquaculture products forms part of theCommon Fisheries Policy (CFP) withthe aim to:

Stabilise the markets in these productsand establish certain marking orlabelling requirements for fish sold tothe consumer. These state states thatcertain product categories includingfresh fish, are required to be labelledwith the:

• Species, common name and Latinname.

• Method of production caught at sea,inland water or farmed.

• Area of capture, FAO definedmarine / inland fishery areas or thecountry in which products areproduced by aquaculture.

Commission Regulation (EC) No2065/2001, laying down detailed rulesfor the application of CouncilRegulation (EC) No 104/2000 asregards informing consumers aboutfishery and aquaculture products.

Council Regulation (EEC) No2092/91 on organic production ofagricultural products and indicationsreferring thereto on agriculturalproducts and foodstuffs: this regulationgives the possibility to make nationalprovisions for organic aquacultureincluding traceability.EU legislation can be retrieved fromthe internet at the address:h t t p : / / e u r o p a . e u . i n t / e u r -lex/en/index.html

Non-EU legislation regardingproduct traceability

In Europe traceability is seen as anintegral component of the food safetylegislation however in the USA it isseen as a tool to be applied where it isappropriate to:

• meet specific food safety objectivese.g. product withdrawal.

• substantiate voluntary productclaims e.g. "organic".

The emphasis in the US is thereforethat traceability/trace-back should benot mandatory in the absence ofspecific food safety concerns (NFPA2001). This ongoing debate has still tobe resolved, however despite theapparent differences of opinionregarding traceability there is still arequirement to implement traceabilityin order to export to the US market.

The responsibility for ensuring seafoodproducts imported into the USA meetthe legal requirements fall to the Foodand Drug Administration.

Whilst verified HACCP systems are arequirement for importing seafood tothe US markets under the FDA rule 21CFR 123, "Procedures for the Safe andSanitary Processing and Importing ofFish and Fishery Products" there is nospecific requirement to implement aproduct traceability system. Howeveras part of a HACCP system there mustbe linkage between batches of product and processing records that can onlybe achieved by recording batchidentification codes onto processingrecords.

As part of recent legislation introduced

9


in order to enhance the security of thefood supply in response to threats fromterrorist attack, the US introducedthe Public Health Security andBioterrorism Preparedness andResponse Act of 2002 (PL107-188).

This act is divided into five sections, ofwhich Title III: Protecting Safety andSecurity of Food and Drug Supplyhas the most relevance to traceability.

This section has the followingprovisions.

Section 305 Registration of FoodFacilities - requires the owner,operator, or agent in charge of adomestic or foreign food processingfacility to register with the FDA no laterthan December 12, 2003.

Section 306 Establishment andMaintenance of Records - requiresthe creation and maintenance ofrecords needed to determine theimmediate previous sources and theimmediate subsequent recipients offood, (i.e., one up, one down). Suchrecords are to allow FDA to addresscredible threats of serious adversehealth consequences or death tohumans or animals.

This section is important since it makeit a requirement for companies whowish to export food to the US marketsto implement internal traceability oftheir products.

Section 307 Prior Notice of ImportedFood Shipments - requires that prior notice of food shipments be given toFDA. The notice must include;

• a description of the article /product

• the manufacturer and shipper

• the grower (if known)

• the country of origin

• the country from which the article isshipped

• the anticipated port of entry

The amount of notice requireddepends on the method oftransportation but should not exceed 5days and should be at least 8 hoursfrom time of arrival at the port of entry.

In addition to the legislation the FDAhas issued guidelines, that includecompany's ensuring;

• An effective product recall strategyis in operation.

• Incoming materials correspond tothe orders sent to specific suppliers.

• Suppliers of all materials including;packaging, ingredients, labels, etc.are known, preferably by means ifindependent audit.

• The coding and packaging ofincoming product should be known inadvance and authenticated uponreceipt.

• The location, storage and use of allmaterials should be "tracked"throughout their time in the factory.

• Final product "tracking", beconducted.

All of which rely on the food processorsoperating a system of traceability (or asit is known in the USA; "trace-back").

10


Labelling requirements for fishery products.

An essential element of a traceabilitysystem is correct labelling so thatinformation relating to the identity,composition and source of the productis clearly and easily transmitted to thenext link in the supply chain. In additionthere are a number of legalrequirements that must be met.

Under current legislation (EU CouncilRegulation - 104/2000.), the followinginformation must be displayed on thefinal packaging of fish products that areoffered for retail.

Fish species, both the commercial andcommon name.

Example of Pallet Label for fresh gutted salmon,

whether the fish is from a marineresource or aquaculture.

Area in which fish is caught or farmed.(FAO area or country of origin forfarmed and freshwater fish).

However during the bulk transfer ofmaterials through the supply chainadditional information is normallyrequired to be included on box andpallet labels, to ensure theidentification and traceability of specificunits of product is maintained.

11


3.Internal traceability systemsComponents of an internal traceability systemProduct identification (ID)codes

The key to a successful traceabilitysystem is the assigning of identificationcodes to specific (batches of) productsand then maintaining the integrity of theindividual batch together with itsinformation throughout its time withinthe factory. Maintaining the separationof batches can be achieved either inspace or time i.e. physical separationof product in separate containers orprocessing at different times in thesame location.

What is meant by a batch? i.e. whatamount of product should be treated asa uniquely identifiable trade unit(T-Unit). The EAN.UCC has defined atrade unit as;

Any item (product or service) uponwhich there is a need to retrievepredefined information and that may bepriced or ordered or invoiced at anypoint in the supply chain"..."thisdefinition covers raw materials throughto the end-user products and alsoincludes services, all of them havingpre-defined characteristics.

This will depend to a large extent onthe product involved, whilst it ispossible and often necessary toidentify whole tuna individually, thesame can not be said for shrimp. Somecommon sense rules should beapplied:

The trade unit should be the maximumamount of product that meets thefollowing requirements:

• Originates from the same source at the same time of harvesting.

• Has been processed at the same time and under the same conditions.

The actual code to be used todifferentiate individual T-Units willdepend on the company and thesystem of traceability to be used, but inmost cases the ID code should;

• be unique to specific product.

• be short enough to be easily readand written.

• convey sufficient information so asto link the specific product to therelevant records.

Example of table used to define a simple batch coding system.

12

The format for the Batch codes is : Supplier code/Reception code/Species codee.g. B/070603/Cdi.e. Cod supplied by Big Fish Co, on 7/6/03


In the simplest form of the code, eachbatch of raw material is assigned aunique 4 digit number which relates tothe purchasing records that provide afull description of the material. This hasan obvious drawback in that withoutaccess to the purchasing records,persons on the production floor can notdetermine any relevant details from thenumber.

An alternative would be to encodefurther details using an alpha-numericsubstitution code to provide details ofsupplier, capture date, species nameetc. Providing a key for the code issupplied then the information is easilyread (refer to diagram on previouspage).

This simple form of batch coding canbe further developed to includeadditional code attributes that relate toother product information. This,however, would make the resultingbatch code much longer and thereforemore complicated to write orunderstand.

This coding principle has been taken tothe logical limit in the use of bar codesand bar code scanners where the codeis converted to a sequence of verticallines of various thickness (bar code)that can be read by a laser scannerand converted by the scanner to aseries of numbers, each of which inturn relate to a computerised databaseof product descriptions. (Further detailson EAN standardisation are provided inAppendix 2).

The main principle in product coding isto ensure that the various sources ofinformation that are already being usedin factory operations are linked, so thatif necessary the history of the productwhilst in the factory can be established.

Methods by which records can belinked will depend on the typeoperations being carried out and therecords that are kept.

Data management

Traceability within a factory isp r i n c i p a l l y c o n c e r n e d w i t hmanagement of information.

When the product undergoes aprocessing operation e.g. filleting, thenthe information that is linked to thatproduct must undergo a paralleloperation if the product and theinformation are to remain linked.

There are several types of dataoperation that are used in typicalfactory operations, these are;

1. Transfer

This is the simplest of operations,where it is essential that product IDcodes are transferred with the productduring processing.

Example: Filleting. Whole fish aretaken from a fish box labelled withthe batch ID-code; they are filletedand placed into a clean fish box. It isessential for traceability that the IDcode is also transferred to the newbox. (or in the case of bar codes boththe old and new boxes are scannedso as to link the product identity).

2. Addition

Where during processing additional

13


ingredient(s) are added to the product.In this situation since the ID-code is stillunique to the product, it is continued tobe used, although the processingrecords should identify the ID-Code ofthe ingredient(s) used.

Example: Brining operation. Thesame ID-code would be kept by thefish after this process step, althoughthe processing records would showthe ID-code of the salt used toproduce the brine (as well as brinestrength, time of processing etc.).

3. Joining

Where one process step combinesseveral Traceability-units (batches),each with a unique ID-Code. Here a new ID-code should beestablished for the new combinedT-unit and the records should clearlyindicate the ID-codes of all thecomponent T-units.

Example: A processor hasinsufficient raw material from onesource to fulfil an order. This wouldrequire that material with twodifferent ID-codes needs to becombined to provide one batch with anew unique ID-code with the recordsdemonstrating the ID-codes of theoriginal materials.

4. Splitting

Where one Traceable-unit (batch) issplit for use in different processes orproducts.

New ID-codes should be given to eachof the split units, although in practicethe new code may not be assigneduntil they have undergone the nextprocess step.

Example 1: Fish from the samesource are placed in chill storewaiting to be blast frozen as 3separate batches. Here the productin the chill store will all have thesame ID-code up to the point atwhich they are transferred into theblast freezer. It is the blast freezerrecords that should clearly identifythe ID-codes of the batch beingfrozen (A) and the new ID-codeassigned to the batch after freezing(Y). In addition it would be advisableto also record the time at which thefreezing started so that the time instorage can also be determined.

Example 2: Re-working of material.Materials that are reworked will haveprocessing histories that differ fromthe rest of the batch being processedand therefore will need to beassigned either different or modifiedID-codes to be used on allsubsequent processing records.

In addition to the data operationsdescribed the method of recording theinformation will depend on the processbeing conducted.

14


Batch operations:

Batch operations are where theprocessing is carried out on one lot orbatch at a time, (e.g. Blast Freezing,Smoking, Hand filleting etc).

Here the processing records providethe batch ID-code and the time/date atwhich the process was carried out, inaddition to other information relating tothe processing conditions that may berequired in terms of product safety orquality assurance.

Example: blast freezer not largeenough for all the same batch thenthe batch numbers should bemodified to take this into account.

Batch Code: 0406 B

Where the 0406 is the batch IDnumber and the B indicates it wasthe second batch to be frozen andtherefore relates to the second set oftemperature results.

Continuous operations:

In other operations such as automaticgutting/heading, tunnel freezing, metaldetection and storage (chill or frozen),processing records are often takencontinuously and often automatically.In order that a linkage is establishedwith a particular batch code, the dateand time that the particular batchstarted and finished the process shouldbe recorded separately, on for examplethe batch processing record.

It may sound strange that storage is acontinuous process, however, thetemperature is continuously beingmaintained throughout the storageperiod and as such the records shouldreflect this by linking the batch code to

Examples of processing records, forbatch (blast freezing) and continuous(chill store temperature) operations.

15


the time the product enters and leavesstorage.

A vital point to remember is that atraceability system does not requirethat all information relating to a specificbatch is provided on the product as alabel, only that it is possible to link thenecessary information. This is usuallyachieved by using unique individualbatch codes that can be linked to allother records.

In practice this can be achieved byeither modifying existing paper basedsystems or implementing a moretechnological approach relying on barcodes, Radio Frequency Identification(RFID) tags, scanners andcomputerised systems. These toolsand techniques are discussed further inChapter 4.

Implementing traceability inthe factory.

Since a company is required not only tooperate a traceability system, but alsoprovide evidence to demonstrate thatthis is the case, it is essential that thesystem is documented in a traceabilityplan.

In the majority of factories, elements ofa traceability system will already be inoperation as part of other companyprocedures such as purchasing,marketing, quality assurance etc. Thefirst step in establishing a documentedtraceability system is therefore toanalyse the current procedures andoperations to establish what elementsare already present and identifyingwhere any breaks in the transfer oftraceability information occur.

For clarity the term "operation" will beused to describe any activity that maybe carried out by a company as part ofits daily routine, this may includeprocess steps, management activities,purchasing sales etc.

A. Analysis of current system

In common with the development ofother documented systems within acompany's operations, the projectneeds to be effectively managed andkey steps in the developmentidentified. These would include:

Establish the management team: It isessential that the development of adocumented traceability system is ateam effort since it is unlikely that anyone person has the requiredknowledge and experience due to thediverse nature of the companyoperations that must be included in theproject.

Determine an operation flowdiagram: Of all operations that arecarried out from the purchasing rawmaterials to the dispatch of the finalproduct. It should include all the majorprocessing steps.

Identify Procedures in place: Usingthe operation flow diagram as the basisfor the investigation all documentedprocedures that relate to productinformation should be identified. Thismay include purchasing/accountancyprocedures, quality assurancemonitoring, batch coding proceduresetc.

Identify Records in place. It isnecessary to identify what records arekept and how these records are linkedto specific products and operations.

16


This information should be collated andwritten to provide documentation forthe traceability system.

The flow chart (left) indicates asimplified process flow diagram forprimary fish processing, typical paperbased records that are kept and notesof how the information can be usedwithin a traceability system.

The procedures and records shouldnot only include the name of thedocument but also a cross referenceas to its location within companydocumentation.

Alternatively the information collectedduring the analysis could be tabulatedas below.

Confirm on site. It is essential that allof the above information is confirmedto be taking place within thefactory/office.

Analysis of factory operation can either be recorded as a process flow diagram(above) or as a written record in a table (below). The table has the advantage inthat cross referencing to specific written procedures or records is easier toachieve.

17


B. Assessment of traceabilityin the factory

With the procedures and records forproduct information identified within thecompany, the next step is to assesswhether the current system will allowthe traceability of product informationthrough the company. Therecommended method of achieving thisis to use a decision tree and recordsheet to ensure that the analysis isboth systematically applied to alloperations and is fully documented, i.e.records of the system analysis areavailable to provide evidence of duediligence.

Starting with the first step on theprocess flow diagram the questions ofthe decision tree are asked for eachprocess step in sequence.

Question 1 identifies companyprocedures and records that arerelevant to traceability. If records arenot kept at this process step and arenecessary to ensure traceability thenthe procedure should be modified.

Question 2 identifies whether batchidentification codes are recorded so asto link process data with individualbatches.

Question 3 determines whether thebatch identification codes aretransferred with the product to the nextstep.

If the answer to any of the questions isno, then action is required to be takento modify the records or theprocedures, so as to maintaintraceability of product through thefactory.

Decision tree for determining the components of the traceability system inoperation and identifying of procedures that need modifying to ensure traceability

18


The answers to the decision treequestions should be recorded toprovide evidence of due diligence andlink records and procedures from othermanagement systems operated withinthe company to the traceability system.This use of cross referencingoperations, minimises the repetition ofsimilar procedures for differentpurposes e.g. by ensuring batch codesare recorded on processing recordsthat are kept as part of QualityAssurance or HACCP system. Theserecords and procedures are also a partof the traceability system.

Having carried out the assessment ofthe management systems already inoperation within the factory andidentified steps in the process wheretraceability is not kept, therelevant procedures can be modified toensure that traceability is maintained.

19

Trcability decision tree record


C. Product recall procedure

Of crucial importance in establishingtraceability system is the requirementto use the product information obtainedby the system to recall any product thatis found to have the potential to pose arisk to consumer safety. For this reasonit is essential that a company has aclearly defined product recallprocedure documented as part of theirtraceability system.

A recall procedure will be specific to anindividual company's operations andmanagement systems but shouldinclude the following 9 elements, basedon the procedure developed by theCanadian Food Inspection Agency:

1. Recall management teamThe identity and contact details of eachteam member and a substitute shouldbe listed together with theirresponsibilities with respect to therecall procedure. The team shouldinclude members of seniormanagement from all departments'involved (QA, sales, production etc),legal and media experts.

2. Complaint fileA formal procedure for recordingcomplaints and specificationnon -con fo rmance shou ld beestablished, in which the nature of thecomplaint is recorded together with theactions taken by the company toinvestigate the cause and preventreccurrence.

3. Recall contact listThe contact details of the persons andorganisations to be contacted in thecase of a product recall should be kepton file and regularly checked. The list would include;

Example of defined sequence of eventsfor product recall procedure. (CanadianFood Inspection Agency)

20


The competent authority; normally it isa legal requirement to inform theauthorities of an incident that warrantsa product recall.

Customers: In order to trace the foodthrough the supply chain, the next stepin the chain should be informed.

Suppliers: Should be informed of anyproduct found to be out of specificationso that they can take appropriateaction.

Media organisations: if product hasalready been sold it will be necessaryto inform the consumers of the productdetails and potential risk.

4. Tracing of products

This can be cross referenced todocumented traceability proceduresthat have been developed by thecompany.

5. Supply and distributionrecords

From the traceability records acompany should be able to determinewho supplied affected raw materialsand where products that included thesame batches of raw materials weredispatched to. The person responsiblefor compiling these lists should beidentified.

6. Recall procedures

As part of this procedure the differentlevels of response to degrees of nonconformance should be defined. Thismay range from re-imbursement orreplacement for poor quality to a fullproduct recall for an incident that posesa serious risk to consumer safety.

In the event of a product recall it isimportant that a clear sequence ofevents is established and followed.Each of the individual steps shouldhave a written procedure detailing whatis to be conducted, how and by whom.

7. Recalled product records

For the purposes of accounting,ensuring all affected products havebeen removed from the supply chainand measuring the effectiveness of therecall plan, records of recalled productshould be kept. This should includedetails of the product, the amountrecalled, the date of recall and ofproduct removal from the supply chainand details of what was done with theproduct i.e. method of disposal.

8. Recall effectivenessprocedures

It is good management practice to notonly have procedures in place toensure that the actions take place andare recorded, but that analysis of theevents also takes place so as to furtherimprove the system.

9. Testing the recall plan

If a product recall is required, it is toolate to discover that the system doesn'twork. For this reason it is important thatthe recall procedure is regularly tested.This may form part of the traceabilityverification procedure as described inChapter 7 or may be conducted on amore regular basis.

A simple test would be to select a batchidentification code that you know hasreached the retailer and thenimplement the product recallprocedure. This would have the

21


advantage of not only testing theprocedures but also providing thepersonnel with experience and trainingin their individual roles.

Records of the test, problems identifiedand corrective actions undertaken toresolve them should be kept.

D. Documentation andrecords

Although a traceability system is likelyto involve components of numerousother management systems alreadyestablished by a company, it isrecommended that the companyshould also develop separate policiesand procedures that are specific totraceability.

These would form the traceability planand would include the followingsections:

• Statement of traceability policy,detailing the company's commitmentto ensure traceability.

• Process flow diagram or table.

• System analysis record sheet, thisprovides a summary of theprocedures employed and crossreferences to complementarymanagement systems.

• Product recall procedure.

In addition to these written proceduresthat form the traceability plan, recordsshould be maintained of the followingpoints;

Traceability audits conducted either bythe company themselves or by outsideorganisations e.g. competent authority,

customers etc.

Problems encountered, non-conformances and corrective actions.

Modifications to the system due to:

• installation of new equipment/procedures;

• corrective actions;

• customer requests.

22


4. Traceability systems in practice

The key factors to successfullyimplementing a traceability systemwithin the food processing sector are:

• Obtaining details of raw materialsand ingredients from the suppliers.

• Identifying individual batches byproduct coding, throughout the timethat they are within the factory.

• Maintaining batch separationthroughout the processing andstorage.

• Linking batch codes to productionrecords e.g. frying, freezing or chillstorage.

• Of the various different methods bywhich traceability can be achievedthe following are provided asexamples;

• Paper-based traceability

• Bar code/scanner systems

The principles that are illustrated inthese examples, however, can be usedfor the development of traceabilitysystems using either a moretechnological approach (See section Cof this chapter) or a combination ofmethods to ensure the transfer andrecording of data for the purpose oftraceability.

The given example is based on theprimary processing of fish andproduction of frozen fillets in an SMEprocessing facility in Grimsby, UK. Aflow diagram of the processing steps isprovided on the left.

Generic process flow diagram fortraceability systems.

23


A. Paper-based traceability system.

All fish processors, irrespective of sizewill have some form of purchasing,factory order processing, sales andinvoicing systems. In smallercompanies these systems usually relyon the completion, storage and reviewof paper based records by employees.Traceability of the product can beachieved by linking these individualsystems and implementing someadditional procedures during theprocessing and monitoring of theproduct in the factory.

Receiving fish at the factory

Having placed an order with hissupplier, whether it is a fishing vessel,sales agent at auction or primaryprocessor, the purchaser on receipt ofthe fish will receive a delivery/consignment note which he will sign asproof of delivery. This note will giveinformation as to the origin of the fishand will have its own number, orreference to a purchase order numberor buy number. Any of these numbersmay be used as the unique number intracing the product through theprocess.

Alternatively the purchaser maygenerate his own unique batch numberbut this must link back to the originatingdocumentation e.g. purchase order,delivery note or buy number. In thiscase the batch number informationmust be passed onto the supervisor atraw material reception so that theproduct can be correctly identified andlabelled as it arrives at the factory. Raw material intake tickets colour coded

by day of arrival e.g. Monday - pinkTuesday - white etc.

Ordering procedures should linkinformation relating to suppliers andraw materials to batch identificationcodes.

24


Raw material intake

On receiving the fish the supervisorenters his name and the date on theintake record and completes the rawmaterial intake record by noting thefollowing details as provided bydocumentation from the supplier and orthe purchasing department.

Date purchased: this is the date onwhich the order was placed with thesupplier and provides a link with thepurchasing records.

Supplier: this can be the vessel, agentor a primary processor

Species: e.g. cod, haddock, plaice

Quantity: the number of containers orunits and the weight in each

Grade: will typically be by weight rangein kilos or large, medium or small andwill describe the form whole, gutted orheaded and gutted

Port Landed: the original port.

Vessel: The name of the fishing vessel

Catch location: normally the FAOfishing area. (refer to map on page 57)

Date of catch

Buy number: this can be buy numberfrom auction , purchase order number,delivery note number

Batch number: this is the uniquenumber which will follow the productthrough the process. It can either bethe same as the buy number (i.e.derived from the supplier).

Or a unique number that is generatedwithin the factory.

25


Intake ticket

On completion of the raw materialintake record, the supervisor will makeout the intake ticket which will beattached to each pallet in theconsignment.

He will also make out an intake ticket,which is a different colour for each dayof the week. This provides easy visualidentification of stock in stores orprocessing, as well as identifying theproduct batch identification code.

Processors will often use their ownproduct code system to simplify therecording of product information.

The code will refer to the species,weight grade, form (whole, gutted etc.)and whether fresh, chilled or frozen.

Description; species name, qualitygrade and form (whole/gutted,fresh/frozen).

Source; vessel name, agent orsupplier.

Quantity; the number of units byweight on this pallet.

Batch No. as per intake document.

Date of intakeTime of intake

Ticket No. The total intake quantity asstated on the intake document mayequate to several pallets, so the ticketnumber will be e.g. box 1 of from batchof 10 boxes.

The fish will now move into chill storeuntil needed in the factory.

Placing of intake tickets on each batchof raw material as they arrive at thefactory.

26


Grading

When taken from the intake chill storeto the grading station the supervisorwill remove the box and retain theintake ticket from the pallet and enterthe information from the ticket onto thequality assurance records for incomingmaterials. The information vital tomaintaining traceability that needs tobe recorded is:

Time; the time the fish arrives at thegrading station.

Batch code; this is the same batchcode that appears on the intake ticket.

Species; e.g. haddock.Weight in; the number of units timesthe weight of each unit on the pallet.

Quality grade; as the fish is graded, inthis case to large, medium, small andwaste. Each grade is placed into aclean fish box which is labelled with abatch ID label (left).

Weight out; the weight of each gradeof fish from the original batch isdetermined and recorded.

Examples of batchID labels (above)and quality recordsheets (right), usedduring grading offish.

Grading of fish using establishedcriteria e.g. Torry grading scheme orQuality index method (QIM).

27


Filleting

The filleting supervisor on receiving thegraded whole fish will complete thedocumentation using the informationfrom the batch code ticket. He will alsorecord the weight of fish received andthe output weight of the filletsproduced; from this the yield can becalculated.

The supervisor will retain the batchcode tickets from the graded whole fishand put a new batch code ticket intoeach unit.

This ticket will be the same colour andcontain the same information but willhave the product described as haddockfillets.

The fillets are then graded, and againthe processing records will becompleted and the batch codeidentification procedure repeated.

The batch code identification ticket willcontain the detail of the species, filletgrade, and will be the same colour asthe batch ID ticket so as to continue toindicate the day of arrival at the factory.

Information on batch ID labels used tocomplete filleting records.

The completion of new batch ID labelsmay be necessary since more than onebatch of material may be used to fulfil aconsignment.

28


Freezing

Fish fillets from the in processing chillstore or directly from the filleting lineare transferred to trays and placed onracks to be placed in the blast freezer.

Individual trays or racks will then belabelled with the batch identificationlabel.

It is recommended that the labels betied to the rack and so can not beblown away during blast freezing.

During the loading, the blast freezerprocessing records will be completedand include,

The product ID (batch) codes ofproducts to be frozen.

The time and temperature at the startof the freezing cycle.

Temperatures readings during thefreezing cycle.

The time and temperature at the end ofthe freezing cycle.

Upon completion of the freezing cycle,the fillets will be removed from thetrays, glazed by dipping individualfillets into cold potable water and then

Batch ID labels used to identify fishwithin the blast freezer need to besecurely attached.

Information from batch ID label used tocomplete processing records

29


placed into clean fish boxes with anappropriate batch identification label.The fish are then transferred tosubsequent packaging and storagesteps.

Bulk packaging

Where frozen fillets are placed into topolythene lined card board boxes forbulk storage until final packaging ofproduct is conducted.

Each box would be labelled either witha final product label or a hand writtenlabel containing the essential productinformation, from which all otherdetails are determined by referencingthe processing records.

Final product packaging

At the packing stage the batch codewill be entered into the label printeralong with the full product descriptionthat will appear on the label, normallybelow the production date.

As each pallet is completed a palletlabel is produced and this again willcontain the full product detail and batchcode.

All product packaging retail packs, bulkboxes containers etc. need to beappropriately labelled with the identity(batch codes) product they contain..

30


Summary of an example paper based traceability system

31


Demonstrating traceabilitythrough the records.

In order to trace information relating toa specific product in a paper basedtraceability system it is necessary tofirstly identify the "batch identity code"of the final product, which should beclearly indicated on the product label.

Using the batch identity code,individual processing records are thenconsulted to determine the processhistory. This can be time consumingsince processing records are usuallystored in date order and a particularproduct may have been within thefactory for more than one day.

The number of processing recordseven in a relatively simple processmeans that finding the informationmanually can be a time consumingtask.

This would be made more complex ifthe final product was composed of rawmaterial from more than one sourcewhere at some point within the records,the linking of the two original batchcodes would be recorded and processsteps that occurred before the mixingof batches would need to be identifiedthus doubling the number of records tobe reviewed.

A method that could be employed tosimplify the process of tracinginformation in a paper based system isto record all process information on asingle record for each batch. This"batch processing" record would followthe product around the factory as it isprocessed. Where batches are mixedthe appropriate record sheets would bejoined, together with a new recordsheet, containing the new batch

Process, purchase, sales and batchprocessing records linked by means ofbatch identification codes.

identification code and all subsequentprocessing records. The advantage tosuch a system is that productinformation is available in a singlerecord, which is ordered according tothe final product identification code.There is, however, a problem in thatprocessing records are used for otherpurposes besides traceability, e.g.HACCP, yields, equipmentperformance etc. where records arerequired to be ordered by time/date,meaning that the information needs tobe recorded twice, therefore doublingthe amount of time completing recordswithin the factory.

32


Advantages and disadvantages of paper-based traceability

DisadvantagesAdvantages

Based on existing quality assurance/stock control documentation systems.

Inexpensive to implement

Flexible in terms of the processingsystems to which it can be applied.

Compared with other traceabilitymethods such as bar coding andintegrated IT Systems

Manually intensive, with respect towriting and collating of records.

Reliant on correct proceduraloperations being carried out, i.e. maybe unreliable in the factory due tooperator error.

Trace-back of information is timeconsuming and difficult for paperbased records. This is especially truewhere the process operations involvemore than one raw material/ingredient.

Records not easily reviewed,especially from different parts of thefactory operations; therefore onlylimited strategic use ofrecords/information can be made.

33


B. Traceability using barcoding systems

Bar codes can be used not only to labeland identify the product during allstages of processing, but alsoindividual pieces of equipment. Theuse of bar codes rely on the use ofhand held scanners for reading barcodes and inputting additional data,printers for re-labelling and acoordinated computer system tomanage the information.

The major difference between barcodes and a paper based system iswith respect to data management. Apaper based system relies ontransferring the batch ID code with theproduct throughout the process. Bar-codes, scanners and a computer data-base allows the individual batch to belinked (in the data-base) to eachprocess, fish box or record each ofwhich are themselves identified by anunique bar code.

The system can be implemented tovarious levels, from only readinginformation on incoming raw materialsand labelling of final product with allother records being paper based, to afully integrated, traceability system forall factory operations. An intermediatesystem is provided as an example.The individual scanners are pre-programmed to request the relevantinformation to be inputted by means ofeither;

• the key pad,

• selection from drop down menus,

• by scanning a bar code. Hand held bar code scanner andexample of menu driven data inputscreen.

34


Each process step that has beenidentified as requiring a data input islisted on the main menu. Wheninformation is entered the scannerstransfer it to a central data base eitherby means of a base station or wirelesscommunication (infra red or radiofrequency).

At the same time any additions tomenus or modifications to the systemcan be downloaded to the scanner.

Receiving fish at the factory

The purchaser on receipt of the fish willeither find that each box of product isalready labelled with a bar codeencoding the origin of the fish and theother information that is required toensure traceability or that theinformation is provided as a writtenrecord. In the first case, provided thatthe bar codes are compatible with thesystem operated in the factory, theneach box will be scanned upon entry tothe factory.

Alternatively the information asoutlined in the paper-based system asbeing necessary for traceability needsto be input into the central databaseand appropriate bar code labels printedand placed on each box as it enters thefactory.

On entering the factory and beingscanned the time and date will beautomatically recorded and linked tothe batch code (encoded in thebarcode) on the database. At this pointadditional information may be enteredinto the system by means of thekeypad on the hand held scanner.

Such information may include the boxnumber, net weight, temperature orany other information that is required

Additional information can be enteredinto the scanner using the key-pad(above).

Fish box labels with productinformation both written and in barcode (above).

Product information input to acomputer by using a handheld scanner(below).

35


with respect to either traceability orproduct quality.

If the consignment is placed in thereception chill store the boxes shouldagain be scanned together with the barcode for the chill store (see generalprocedures).

Grading

When taken from the intake chill storeto the grading station the supervisorwill scan the barcode of the processingarea and on each box as well as enterthe product information such as qualitygrade weight etc. into the handheldscanner unit.

Where fresh clean boxes are used,labels with appropriate barcodes areprinted and applied to the boxes toensure traceability.

Process steps (general)

All process areas, including chillstorage, are assigned a uniqueidentifying barcode. This enables theproduct to be easily associated with aparticular process step or storage areaat the specific time by simply scanningboth the product bar code and theprocess area bar code.

For example, as each box is placed inthe chill store at any point duringprocessing, it is scanned together withthe chill store identifying code and thetime of entry is automatically recorded.If the same procedure is conductedupon removal from the chill store, notonly is it possible to determined theprocessing history of the batch but alsohave a real time assessment of stocklevels in storage or processingthroughput in the factory.

Each location at which a processingoperation occurs is identified by aunique bar code.

To link specific batch to a processingoperation both the location and box barcodes are scanned.

36


It is recommended that bar codes andscanners should be used inconjunction with paper-based records.

Glazing

Upon completion of the freezing cycle,the fillets will be removed from thetrays, glazed by dipping individualfillets into cold potable water andplaced into clean fish boxes with anappropriate batch identification label.They are then transferred tosubsequent packaging and storagesteps.

Bulk packaging

Where frozen fillets are placed intopolythene lined card board boxes forbulk storage until final packaging ofproduct is conducted. Each box wouldbe labelled with a final product labelcontaining the essential productinformation (see chapter 3) togetherwith a final product bar code, fromwhich all other details can bedetermined by scanning the bar codeand referencing the central data base.

Final product packaging

At the packing stage the bar code ofthe fish box (or freezer rack) will bescanned and a label containing thefinal product bar code and otherproduct details will automatically beprinted.

As each pallet is completed a palletlabel is produced and this again willcontain the full product detail and barcode.

Further quality control checks (egverification of metal detector operation)can be conducted on the packagingline by scanning the location bar codeand using the drop down menus.

Boxes of frozen fillets are scanned asthey are packed. The databasecombines the information relating tothe batch identity, with the weights ofindividual boxes and prints out labelwith the appropriate bar code.

Storage

As each pallet of packaged productenters the cold store the pallet label barcode is scanned, and entered into thedata base. This could enable acomputerised stock control system tobe implemented within the factory.

37


Filleting

Each filleter will receive a bar codedbox of fish from the supervisor who willscan in the box and identify the filletereither by scanning in an identifying barcode or entering an identification codeinto the scanner.

Grading

The fillets are then graded and againthe process records will be completed.In addition the bar code of the originalbox & the batch code procedureis thenrepeated by scanning or inputting data.

Freezing

Fish fillets from the in processing chillstore or directly from the filleting lineare transferred to trays and placed onracks to be placed in the blast freezer.

As the boxes are unloaded the barcode on the box is scanned and linkedwithin the data base to the individuallybar coded trays or racks that are alsoscanned.

During the loading, the bar codeidentifying the blast freezer will bescanned together with the bar code ofthe racks to identify which racks werefrozen in which blast freezer at whichtime. The records of the freezingprocess may be paper based as in thepaper system previously described.The paper records can be linked to thecomputer records providing the time,date and freezer identity are includedboth in the database and the records.Alternatively if there is an automatedtemperature logging device installed,the temperature profile of the freezingcycle can be automatically linked to theappropriate batch codes within thedata base.

Each time product is transferred to aclean fish box or in this case a freezingrack the bar codes of both the old andnew container need to be scanned.

Each filleter (above) will be provided aunique code on a form (below) so thatthe supervisor can scan the boxes andfilleter ID, to record the rate and qualityof work for each person.

38


Frozen fish fillets processing flow diagram and traceabilityoperations using hand held scanners

39


Demonstrating traceabilitythrough the records

The software that enables the bar codescanner to download data to the centraldata-base has a variety ofsupplementary functions that areshown in the screen shots (right).These are accessed via a main menu(Fig A) where the informationnecessary to produce the menu systemon which the scanner operates isinputted into the system (yellowhighlight). This information includes theraw materials, the details of thesuppliers/agents, types of rawmaterials, and of course the identifyingbar codes for individual boxes,containers, equipment (freezer) andprocessing steps (filleting, cold storageetc.) (Fig B).

The software's main function is tocollate and organise the data toproduce a variety of different reports(pink highlight).

The outputs of thereports (Fig C) can bemodified to suit therequirements of thecompany, but theinformation they presentessentially identifies theproduct batch code tothe time and date thatthe batch arrives at aspecific process step(e.g. reception orfreezing), as identifiedby the identity of the barcode for the specific boxthe product is in.

40

A

B

C

D

Screen shots of scanner tracibilty software. Refer totext for explanation.


This makes reference to the paperbased records much easier since boththey and the batch code are linked bythe time and date. The software is alsoable to organise the information withinthe database to provide a traceabilityreport for any product selected by datetype, a supplier, or batch code of rawmaterial (i.e. traceability from intake todispatch). The information can also beobtained by entering either the finalproduct code and customer identity(finished goods to intake) i.e. trace

back. The selection process isconducted on a simple menu screen(Fig D).

The advantage is that these reports areobtainable as soon as the data istransferred to the database. A paper-based system would require a personto review the records and manuallytrace the batch codes through therecords for each of the situationsdescribed.

Advantages and disadvantages of using bar codes andscanners for traceability

41


C. The use of modern technology in traceability

During the last decade there has beenhuge developments in the design andimplementation of InformationTechnology (IT) systems. Thetechnological innovations andtechniques developed for otherpurposes are increasingly being usedwithin the fishery sector for themanagement of key activities e.g.accounts, process management,quality assurance etc. They can alsobe used to manage and collect,information necessary to ensureproduct traceability.

Central to the use of IT is the use ofcomputers within the factory. Moreimportantly their connection to form anintranet within the company allows forthe rapid communication ofinformation.

The use of e-mail and the World WideWeb make the transmission ofinformation between suppliers andcustomers easier and quicker. Theinformation should be formatted tofacilitate integration into the company'sdata-base.

In both cases the information needs tobe stored on a central database whichis normally designed to meet therequirements of each individualcompany or system. This provides avariety of tools with which theinformation can be collated andanalysed to give the necessary reportsand records.

There have been several technologicalinnovations that have beensuccessfully used in maintainingtraceability of fishery products.

Radio frequencyidentification (RFID) tags

RFID technology has been extensivelyused in non-food products to providereal-time automatic productidentification and as such is anestablished technology that has anextensive range of uses.

RFID systems use radio waves ofspecific frequencies to read, and/ormodify data stored in electronic circuitsor a micro-chip that is usually encasedin durable plastic to form a "tag". TheRFID system consist of 3 components,The transceiver which transmits energy(in the form of radio waves) via anantenna, which when it encounters anRF tag, results in the tag emitting aradio signal that can be picked up bythe transceiver and decoded to revealthe information contained in the tag.The transceivers can be incorporatedinto various types of equipmentranging from portals (doorways);handheld scanners similar to the barcode scanners; specific pieces ofequipment e.g. weighing scales andhave even been built into the glove ofthe person who handles fish boxes.

There are two types of RFID tags,

Active: which has the ability to transmittheir information by using an internalpower supply.

Passive: which rely on the transceiverto provide power in the form of radiowaves in order to transmit theirinformation to the transceiver. Beingcheaper and not needing a powersource it is this type that is most

42


commonly used for productidentification.

RFID tags vary in the amount of datathat they can encode and store. Thesimplest (and cheapest) tags, storeonly a unique identification number thatcan be linked in a data base to thedetails of a specific product. Others canencode much more product relatedinformation, in a similar format to thatused by bar-codes (see Appendix 2).

RFID tags can be attached to fishboxes, freezing racks etc. and are used

to carry the traceability information in aformat that can be read automaticallyand at a distance. The advantage tothis method is that the box needs onlyto be placed on a scale or passedthrough a detector for the identificationinformation to be automaticallydetermined and only additionalinformation added e.g. quality grades,weight etc. This can be achieved byinputting the data via drop down menuson a touch screen interface.

Network of equipment linked by wire and radio transceiver enable the linking ofprocess information with specific product identities, location and time with a

central computer database.

43


Computer linked equipment

The linking of specific processingequipment to a computer network hasbecome increasingly common placesince it:• Reduces the need to manually

record process information, hence reducing the possibility of error and improves the productivity of the employee.

• Provides continuous monitoring of aprocess, therefore making it possibleto correct any deviations before they become critical.

• Records are easily stored on a central database for collation and analysis as required.

• The technology is now relatively cheap in relation to the equipment itself.

Whilst most computer-linked pieces ofequipment are used to gather processrelated information for purposes ofQuality assurance, e.g. temperaturemonitoring of cold and chill stores,some systems have been developedto also have a role in producttraceability.

An example system has beendeveloped by Scanvaegt Ltd. (seebelow) in which a range of equipmentincluding office workstations, productbalances, label printers and hand heldscanners have all been linked into asingle integrated data managementssystem. Such systems use specialisedequipment that are specificallydesigned to record and transferinformation to the central database.

A wide range of processing equipment is now produced, that can be linkedto computer databases for automatic recording of processing records.

44


An example of this approach is therange of weighing scales (Traceway)developed by Nesco Ltd. for use withinthe fish processing chain. They notonly weigh the product and record theinformation on a central database butalso enable additional information to beadded to that database. Thisinformation can relate to the origin ofthe fish and/or other processinformation such as quality grades etc.

This additional information can beadded to the central database byvarious methods, including:

Touch screen technology: allows theoperator to select and enterinformation from a series of drop downmenus by simply touching an iconvisible on the screen. The data to beincluded can include supplier details,product information such as species,fresh/frozen, quality grades,temperature, and batch code.

Nesco's Traceway touch screen datainput system on a weighing scale atreception (above). The operator is ableto select information from a series ofdrop down menus (below) by simplytouching the screen on the selecteditem.

45

Screen A provides options to link asupplier to a specific consignment.

Screen B gives a reading of the weightwhilst allowing for selection of eithertare weights or several boxes from thesame batch to be measured.

Screen C provides summary of allinformation entered for a specificbatch. Since this information is held ona central database a report can beeasily printed

A

B

C


Barcode scanner; can read theproduct information on a product labeland transfer it automatically to thedatabase along with the product weightand time/date.

RFID Transceiver; automaticallyreads the information contained in theRFID tag and transfers this informationto the database.

The advantage to traceability is thatonce the information is entered ontothe database, the additionalinformation can be linked to the producteither within the database or byupdating the information carried by thatparticular box of product by eitherprinting a new Batch IdentificationLabel (with bar code) or updating the

data on the RFID tag.

In an integrated IT traceability systemthe batch identification code is notnecessarily physically attached to theproduct. Like the bar code system,batch ID is retained within thedatabase and its progress through thefactory is monitored by the equipmentlinked to the database which inputs tothe database what was processed andadditional to process related data.

It is recommended that product islabelled with identifying information inthe form of product labels so that theprocess workers can also identify theproduct.

Diagram of product and information flow through the process with the use of anintegrated IT approach to traceability.

46


An integrated IT traceabilitysystem

Using the example of primaryprocessing previously used todemonstrate how traceability isimplemented in a factory; the followingcomponents were installed to provide asimple integrated IT Traceabilitysystem based on RFID technology:

• Internet connection.

• Computer data-base andmonitoring software.

• Temperature monitoring systemlinked to the computer.

• Computer linked weighing scalesat reception and packaging.

Wall mounted RFID transceiverslocated at entrance/exit, to the factory,chill store, blast freezer cold store andstart of the packaging line (1, 3, 5, 6 & 7).

Hand held RFID transceivers for use atgrading and filleting stations (2 & 4).

Receiving fish at the factoryInformation relating to the identity,quantity and source of raw materialsare entered into the central databaseeither by a factory worker or directlyfrom the electronic transfer of the datavia the internet.

On arriving at the factory the fish areidentified either by the RFID tags onthe boxes, bar coded labels oraccompanying documentation.

Where RFID tags are not present thefish can either be transferred to boxeswith RFID tags attached or a plasticlabel containing a RFID tag placed inthe box to identify the batch.

The advantage of initially using such alabel is that product information canalso be written on it with a water proofmarker pen so that process workers

Example floor plan for fish processing with position of RFID transceiversand integrated scales identified.

47


can easily identify the product. It alsomeans that the label can be transferredwith the product from one box toanother therefore reducing the numberof RFID tags that are required.

The raw materials then enter thefactory and the time and date isautomatically logged by transceiver 1.Each box is then weighed and thedetails of the raw material are checkedand linked to the RFID tag usingcomputer linked weighing scales.

If the consignment is placed in thereception chill store the RFID tag willbe automatically logged as it enters orleaves the chill store (transceiver 3).

Grading

In order to grade a box of fish the QAsupervisor will scan the RFID tag with ahand held scanner, grade the fish andenter the results into the data base viathe scanner.

Process steps (general)

When the fish are transferred to aclean box any process step then usingthe batch identification code encodedin the RFID tag is erased from the oldbox and transferred to the new boxusing the hand held transceiver.Alternatively the RFID containing boxlabel is simply transferred to the newbox.

Filleting

As each box is removed from the chillstore to the filleting area the time &date is automatically logged. At thefilleting station the box is scannedusing a handheld scanner (4) and theidentity of the filleter, the weight and

quality assessment of the fillets isentered by means of a drop downmenus on the transceiver screen.

Alternatively, an additional set ofcomputer linked scales could beintroduced at this point to automaticallyrecord the weight of the whole fish andfillets, whilst the identity of the filleter issimilarly entered via drop-down menuson a touch screen.

Freezing

The fish fillets are transferred tofreezing racks containing RFID tagsand the product identification codesare transferred using handheldtransceivers. The time and date thatthe racks and fillets enter and leave theblast chiller are automatically recordedas is the temperature, which isautomatically monitored throughout thefreezing cycle.

It should be noted that if producttemperatures are required then the useof a temperature probe inserted intothe product will be required.

There is a minor problem in that mostRFID tags currently in used are onlycertified to work down to -30°C and assuch may suffer data loss or damage at-40°C commonly used in blast freezing.To overcome this problem the hand-held transceivers can be used to inputboth the identity of the freezing rack aparticular product is placed on and thestart time of the freezing cycle,therefore avoiding the need to placethe RFID tags into the blast freezer.

As frozen product is removed from theblast freezer and placed into clean fishboxes the Product identificationnumber is transferred to the new box.

48


Packaging

As RFID tagged boxes of final productare placed on the packaging line theproduct identity is automaticallytransmitted to the database which iflinked to a suitable printer and productordering software can automaticallyprint out the required product label,containing product information and barcodes.

Storage

As packaged products are placed on apallet for storage and transport, theidentity of the pallet can be determinedether from an integral RFID tag or bymeans of a pallet label containing aRFID tag. This will update the databaseupon entry or exit to the cold store (6)and on leaving the factory (1).

Demonstrating traceabilitythrough the records

The major advantage of using a fullyintegrated system is that all productand process information is linked on acentral data-base, and as such thecollation and analysis of the largeamounts of data generated by a fullyintegrated system is conducted in realtime by the relevant data-basesoftware programmes.

Each database system will differ in itsoperation. However an example fromthe Scanvaegt Multiflex 3000 Sqlsoftware system is used todemonstrate the principles ofproducing traceability reports with afully integrated IT Traceability system.

Example screen shot fromScanvaegt Multiflex 3000 SQLsoftware, showing traceabilityreports.

49


Using this system to obtain producttraceability information means theidentity of the product to be traced isentered into the report manager page.

The information can be requested interms of the supplier, customer, date ofintake, processing or dispatch, or thebatch identification number.

The specific report that is required isthen simply selected from the mainmenu on the left hand side of thescreen. The resulting report can thenbe printed out or sent via e-mail toother offices.

Since such integrated systems canprovide real-time information as to thelocation of product within the factory itis possible to present a systematiclayout of the factory and identify whichbatches are being processed atindividual steps or in storage, at anyspecific time. This allows the efficientmanagement of the factory andprocess to meet required orders for theproduct.

Discussion of traceabilitymethods

The examples of traceability systemsdiscussed have shown how traceabilitycan be achieved in the primaryproduction of fish using either paperbased records or a bar code/scannersystem combined with computerisedcentral database.

It is, however, more likely that within afactory a combination of differentmethods would be employed to ensureproduct traceability and the linking ofspecific batches to processing records.

Providing that the integration of newtechnologies or methods into anexisting traceability system is carefullymanaged the benefits of atechnological approach can beprovided in a stepwise development ofthe system, with minimal capitalexpenditure.

An example would be the use of apaper-based system during processingbut using barcode scanners to recordthe reception of raw materials andcontrol of packaged product i.e. thoseparts of the process where barcodes

50

Screen shots from software used in anintergrated IT approach to traceabilityshowing how the progress of productthrough the factory (top) and howproduct orders are being completed(bottom), in real time using batchidentification via RFID tags.


are already on the product either aspart of the supplier documentation orfinal product labelling.

This could be achieved with thepurchase of only one or two scanners,depending on the size of the factory,and appropriate software. The benefitscould be significant in terms ofreducing the amount of supplierinformation that needs to be enteredinto the company records and stock

Advantages and disadvantages of technology-basedapproaches to traceability

control of the final product.

Although the differences between themethods of establishing traceability areminor when used in a simple processsuch as filleting and freezing fish, thebenefits of using a more automatedsystem become more apparent whereprocessing involves more complexoperations such as the manufacture ofbreaded fish product.

51

Advantages

Flexibility: The system can becustomised to user's specific needs. Thetypes of equipment, scanning systems,data-base software etc can be adapted tomeet individual companies requirementsdata input easy and menu led, minimisingerrors.

Compatible with hand held scanningsystems and paper systems.

Provides detailed managementinformation from central data base.

Starting with a simple yield controlsystem it can be developed into a FullFactory order process system, providingfull traceability across all factoryoperations.

Incorporates recipe management systemproviding full traceability of allingredients, yield control and stockmanagement information.

Real time availability of records.

Data from database is easily transferablethroughout the supply chain.

Disadvantages

Primary function is as a management toolto capture processing data, withtraceability as a consequence of thesystem rather than the primary designreason.

Requires capital expenditure forequipment.

This should be evaluated againstpotential cost savings in material, labourand other resources.

Relies on either ID tags/labels throughoutprocess or Bar code scanning anadditional capital cost.


5. Traceability in the supply of fish

Aquaculture

The rapid development of aquacultureproducts in the market and perceivedrisks through uncontrolled feed andmedicine demands increased safetyand traceability control. The greatestexpansion has been in developingcountries with the result thatinternational trade in aquacultureproduction has seen increaseddemand for traceability. Whilst ensuringproduct safety has been the primaryconcern of the regulatory bodies, trade,environmental and quality issues arealso seen as vital. This has resulted ina wide range of legislation, industryguidelines and international standardsbeing developed for the industry.Although traceability is not necessarilyspecifically mentioned all matters thatrelate to safety, quality and trade relyon the ability to identify and trace theproduct.

In the proceeding chapters, theprinciples and practical aspects ofapplying traceability to the fishprocessing sector were discussed.

The same principles and methods canalso be applied to the production of fishin the aqua/mari-culture sector of thefish industry.

The wide range of seafood /freshwaterproducts that are now being culturedtogether with the diverse nature ofproduction methods, mean that onlythe principle components of traceabilitysystem are within the scope of thispublication.

Generic Process Flow chart foraquaculture of fish on whichtraceability system is discussed.

52


Supply of juvenile stock

The source of the juvenile fish, fry oreggs should be recorded, whether thisis from a commercial supplier, in-househatchery or from the wild.

At the start of the production chain it isimportant that the species identityshould be determined. Industry shoulduse the correct scientific, rather thanthe local, name.

It is recommended that the health ofthe stock be confirmed by a veterinaryexamination and certification.

Where the stocks are being suppliedfrom a commercial source thisinformation should accompany theconsignment together with the batchidentification code of the supplier. If thisis not the case then it is theaquaculture company's responsibilityto ensure that this information iscollected and recorded.

Transportation

The consignment of stock will beaccompanied during transport to theaquaculture facility by documentationfrom the supplier.

Reception at the aquaculturefacility

At reception at the aquaculture facilityall documentation should be checkedand together with the time and date ofarrival entered into the farm records. Abatch code should be also assigned tolink the suppliers batch code(s) withthat used at the farm. The batch codeused within the farm (and for finalproduct) may relate to stock of the

Individual tanks, ponds and cagesshould be uniquely identified so thatfish batches can be traced throughouttheir lifecycle.

53


same species from more than onesource/supplier if this is the situationthen all the supplier batch codesshould be recorded. It should be notedthat the records can be either paper-based or entered onto a central data-base, using keyboard, barcodescanners or other IT methods.

Stocking in specific tanks,ponds or cagesIn many cases stock arriving at a fishfarm will be first placed into tanks toprovide them the opportunity to recoverfrom transportation and acclimatise tolocal conditions. As with any transfer ofstock from one tank/pond/cage toanother the identity of the stock in aspecific location should always berecorded. This means that everytank/pond or cage should have its' ownidentity code that can be linked to aspecific stock batch code in therecords.

Additionally the identity of the stock(Batch code, species/common name)and production information should bewritten so as to be easily available forworkers to check and refer to whilstrecording farm operations.

Feed

Of critical importance in ensuringproduct safety in aquaculture is thenature and composition of the feedused, particularly with carnivorousspecies whose feed will be derivedfrom other marine resources. Theamount and timing of feeding the stockis also seen as critical in ensuring thatthe growth efficiency is maximised.Therefore traceability of both thesource of the feed used and thefeeding records for each specific batchare essential. As is obtaining feed from

All records should be linked to thebatch ID code of the fish and thespecific tank/cage identity.

54

Monitoring of the environmentalconditions and amounts of feedsupplied to the fish are necessarythroughout the growth of the fish bothin tanks (above) and in cages (below).


reputable suppliers who haveimplemented their own QA andtraceability systems, to ensure that thefish-feed meets the requiredspecifications and is not contaminatedwith chemicals that potentially couldresult in safety (or quality) incidents.

Each consignment of fish-feed willhave its own batch code which shouldbe recorded at reception, whereappropriate stock control proceduresshould be conducted during feedstorage. At the time of feeding thebatch code and amount of feed givento each tank, pond or cage should berecorded and linked to the stock batchcode.

Application of medicinaldrugs

Equal in importance to the traceabilityof feed and feeding records, is that ofproviding documented evidence of theapplication of medicinal drugs to thestock. This is because certain drugsincluding antibiotics such asChloramphenical. Whilst available andwidely used in some productioncountries these are banned in manyimporting countries including the EU.

Other drugs, although permitted foruse, require that the stock be held for a"withdrawal period" to ensure that thedrug is fully metabolised and thatresidues are not present in the finalproduct. In both cases it is essentialthat the nature and source of the drugsused and storage conditions berecorded.

In a wide number of cases antibioticsare administered in the feed, so it isessential that such medicated feed isclearly identifiable, stored separately

Storage of fish feed needs to be tightlycontrolled with good stock rotation andpest control procedures in operation.All products should be clearly labelledand traceability back to specificsupplier batch codes should bemaintained.

55


and used only where its use is bothapproved and necessary.

Harvest/Dispatch

The time/date and conditions ofharvesting each batch of stock shouldbe recorded, and the product labelledin accordance with the regulationsdetailed in Chapter 2 (LabellingRequirements), before beingtransported to the packing/processingfacility that would conduct traceabilityas described in Chapter 3.

The overall objective of a traceabilitysystem in an aquaculture facility istherefore to be able to provide adocumented history of each batch ofstock, from the time it arrives, to thetime it is harvested. The records shouldshow what, when and how much feedor medicinal drugs were provided andhold the information by which these"ingredients" can be traced back to thesuppliers records.

Additional records will also be linked tothe stock batch code to allow theefficient control of productivity, qualityand safety assurance systems.

The methods by which traceability canbe implemented within the aquaculturesector are the same as for theprocessing industry. It is likely thatmost records will be paper-basedalthough these may be transferred to acomputer database for ease of accessin producing reports. The use oftechnological solutions such asintegrated weighing scales, bar codelabels and scanners may providebenefits in the storage and dispensingof medicinal drugs and feed. Thebenefits of using such a systeminclude:

Harvesting records should include thebatch identification code of the fish, thetime, date.

56


• Reducing the likelihood of humanerror.

• Real time access to currentinformation relating to specific stock.

Marine capture

Each box of fish that is landed shouldhave the following informationassociated with it.

Identity of the boat: In the majority ofcountries fishing is now limited tolicensed vessels, each with anidentification number.

Date of capture: This is vital since itprovides the time at which spoilagestarts to occur. Ideally the time oflanding and the length of time thenets/lines were deployed would also beincluded but this is rarely the case insmaller boats.

Location of capture: Although theexact coordinates are often available itis usually only necessary to identify theFAO area, e.g. Area 27, NE Atlantic:

Area 51, Indian Ocean, etc.), althoughfor marketing purposes more specificterms may be used e.g. North SeaCod.

Species identification; both thecommon and scientific name arerequired.

Net weight; of fish in eachbox/container.

Batch codes; may be applied tospecific batches of fish on board thefishing vessel to facilitate the control ofinternal quality assurance systems.They are not compulsory provided thatthe information accompanies the fish.

In many cases this data is routinelyrecorded as part of the legalrequirements of fishing vessels. It is,however, essential that the informationis passed onto the next link in theprocess chain with the product,whether this be the market or aprocessor.

Map of FAO Areas for fishery activities for use in identifying the location of marineharvest.

57


In many countries where artisanalfishing predominates, althoughindividual vessels may be registered,the on board recording of catch data isvery unlikely due to lack of time andresources available to a 2-4 personcrew on a small boat. Many catchesare also landed on beaches andtransported directly to the processor ormarket place by road. This is often thepoint at which traceability is lost, sinceone truck may mix and transport thedaily catch of more than one boats. Insuch circumstances it is theagent/collector or the processingfactory who should take responsibilityfor recording the identity of the boat,and other information listed asnecessary for traceability.

Where an agent/collector is buyingfrom various boats that are landingproduct on a beach, then the fishshould be placed in fish boxes andidentified with labels as to the date andtime of landing, the vessel identity andthe beach or location of landing.

In industrialised EU fisheries, thecapture and landing of fish is a highlyregulated process. Significant amountsof information are collected that can beused not only to provide traceability ofthe fish but also provide accurate dataon the location, conditions e.g.weather, sea temperature, length oftime nets were deployed, depth of trawletc. This information, although of greatcommercial value to the fishermen, isof lesser significance to producttraceability.

The collection of all this data has beenfacilitated by the integration of IT toboth the control of such vessels usingsatellite navigation systems, electroniccontrol of machinery and equipment

and the recording of fish capture datain terms of species and weights.

The identification of individualcontainers has been helped furtherwith the development of weighingscales that are not effected by themotion of the boat at sea, and have theoption of entering additionalinformation e.g species quality grades,by means of a touch screen, Thelocation, time and date of capture aretransferred from a central data systemon board ship. This system developedby NESCO Ltd and demonstrated inthe Tracefish project can be used toprint the batch data on a box labelcontaining a bar code or transmitted toan RFID tag embedded in the box.

The size of boats and the subsequentsize of the catch will influence at whichpoint in the chain product traceabilitystarts.

58


6. External traceability: Tracing the product through the supply chainThe supply or processing chain isdefined as the entire sequence ofevents that occur from the moment rawmaterial is obtained until the product isconsumed. This is often termed "net toplate" approach. In the fishery industrythis can start at the moment the fish iscaught, although in the case ofaquaculture it will also include wherethe fish fry were obtained and recordsof feeding and medication etc.

often reluctant to give informationaway.

Identification of the necessaryinformation to be transferred along thechain. Which of the large amount ofproduct related information isnecessary to maintain producttraceability?.

Compatibility of the informationbetween individual Internal traceabilitysystems.

Differences in legislative requirementsfor product in different global markets. There are two main models forinformation exchange across thesupply chain, Independent andIntegrated systems. In both models it isstill essential that product is labelledsince the product must still be linked tothe additional data provided by thisexchange of information.

Independent traceabilitysystems.

Sometimes termed a "closed system"this is where individual companies takeresponsibility for obtaining theinformation necessary for traceabilityfrom their suppliers, and providingsuch information to their customers.This transfer of information meets theminimum legal requirements under EUlegislation. and is some-times termedthe "push-pull" model, since thecustomer request (push) a supplier toprovide the information in the requiredformat and the supplier responds(pulls).

In order fortraceability to bee f f e c t i v ei n f o r m a t i o ngathered by ani n d i v i d u a lcompany withinthe supply chainmust be sharedwith others alsoin the supplychain.

This exchange of information operatesin parallel with the product through thesupply chain. The need for a parallelsystem of data transfer is because thenature and amount of informationlinked to a product far exceeds thecapacity of either product labels or bar-codes.

Whilst simple in theory, there are manyobstacles to be overcome inestablishing systems that efficiently puttraceability into practice, these include:

Commercial confidentiality: Productinformation is increasingly seen asbeing an asset and companies are

59


In such a system a processingcompany would ensure that allinformation that it needs to identify itssupplier and the supplier's productidentification code is obtained. In mostcases this means receiving productinformation in the form of aconsignment/delivery note togetherwith labelling on the product itself.

What information is needed to betransferred? The minimum informationto be included would be:

• Supplier Name (& contact details)

• Product Description

• Supplier Product Codes

• Date of Production

All other details required by appropriatelegislation, i.e. species name, countryof origin etc.

Although such paper based systemsfor information transfer can be used,exchanging data in this way isinefficient since the information mustbe entered into the individualcompany's information system at everylink in the supply chain. The electronictransfer of information in an agreedformat would greatly improve theefficiency.

The problem is that each company hasmany suppliers and just as manycustomers each which are likely torequire the information in differentformats.

A simple solution is the use ofstandardised bar codes on productlabels, which can be easily read byscanner and the informationtransferred to the company database.

This is where an integrated approachto traceability can benefit the entiresupply chain.

Integrated traceabilitysystems

Integrated or "Open" Systems differ inthe degree of integration involved, fromthe simple use of standardised bar-coding on labels to the transmission ofall information regarding the productduring its progress through the supplychain to a central data-base.

There have been a number of Opensystems that have been developed thatprovide examples of how traceabilitycan be implemented within industry.

Such systems have been establishedby multinational sea-food groups whowish to collect and analyse data fromacross the supply chain for commercialreasons.

More recently the development of on-line auctions on the internet for fish hasresulted in information relating to fish(species, quality, weight, location ofcapture and boat) being transmitted tothe auction site from the boat bysatellite link and that buyer purchase

60


the fish based on this informationbefore the fish are even landed at port.Due to the standardised systems ofdata capture and management theinformation is easily transmitted to theprocessor or retailer over the internet,so maintaining traceability of productinformation.

7. Verification of traceability

Irrespective of the area of fisheriesoperations for which a traceabilitysystem has been established, theoperation of the system needs to beverified. From the product identificationcode, or alternatively a bar code on theretail label, it should be possible totrace back through the records of eachcompany in the supply chain. At eachlink the source and (original) identity ofall raw materials as well as the entireproduct processing/transport/storagehistory can be traced.

Although this is the primary objective inestablishing traceability systems, it israre that such a detailed review isundertaken due to the time and effortnecessary to trace all the records. Thecost of such an exercise, even for asimple supply chain, would mean thatonly in the instance where public healthwas at risk and a product recall wasnecessary, would such a review beconducted.

There is no benefit in waiting until suchan incident occurs before reviewingand validating a traceability system. Bythen a product recall is required andthe system must work.

In addition to validating its owntraceability system (termed 1st partyaudit) the system may also bevalidated by external auditors.

Supplier audits: conducted bycustomers who need to verify that, theirraw materials can be traced to theoriginal producer.

Legislative audits: conducted by thecompetent authority to verify that thelegal requirements for traceabilitysystems are implemented by thecompany.

Accreditation audits: conducted byindependent auditors to establishwhether the criteria of specificstandards are met by the traceabilitysystem. An example of such astandard is the, Marine StewardshipCouncil (MSC) Chain of CustodyCertification, which sets out therequirements of a traceability system toensure that only fish that originate froman MSC certified fishery as beingsustainable are labelled with the MSCEco-label.

It is important that such verification oftraceability is managed systematicallyand efficiently. There are manyapproaches that can be taken toverifying traceability and the followingis one example based on the work ofDillon & Griffith in their book "How toAudit". The management of an audit isdivided into the following steps;

• Planning and preparation

• Conducting the audit

• Analysing the results

• Agreeing Corrective Actions

• Verifying effective completion

61


Planning and preparation

Probably the most important of thesteps in which the questions; why?what? where? who? when? and how?are answered with relation to the audit.

Why?

The objective in establishing atraceability system is to provide adocumented history of the processingand sources of raw materials for aspecified final product in order todemonstrate "due diligence".

The reasons for verification oftraceability system may include;internal verification of systemefficiency, supplier audits, competentauthority inspection, accreditation, etc.

What is to be verified?

Verification of traceability can beapproached from two perspectiveseach of which can be conducted todifferent depths depending on therequired objective, e.g.

Verifying that traceability is maintainedthrough the entire processing chain. Inthis situation the depth of the audit canbe defined as how far through thechain the audit is conducted. This willbe dependant on the reasons for theverification.

Verifying traceability of product within acompany's operations, including theintegration of supplier and customerproduct information into the traceabilityprocedures. In this case the depth ofthe audit is defined as being either asystem or compliance audit.

The 5 W's and the big H used ineffectively asking and answeringquestions.

Depth of audit is dependent on theobjectives of the verificationprocedures.

62


System audits are often undertaken todevelop an overview of the existingbusiness performance or during thedevelopment of a new operation toensure that the business has therelevant plans and procedures toensure traceability. This level of auditwould be used to ensure that thesystem meets the requirements ofeither the law or a given standard.

Compliance audits are more limited inscope and are used to verify in detailthat a given traceability system is beingadhered to by evaluation of objectiveevidence from the operation of a giventask e.g. can the processing records fora specific product be traced throughthe companies operations.

In answering the what? is to be verifiedthe question where? is usually alsoanswered, since the locations of theoperations to be audited should beclearly identified using a flow diagram.

Scope of audit

It is important that the areas ofcompany operation to be covered byan audit are clearly defined so theproject remains focused. This isespecially true for an area such astraceability which itself is integral tomany different company operationsand procedures (e.g. purchasing,processing sales etc). It is oftenimportant to keep the scope of an auditas simple as possible which may meanthat the scope is initially limited to onlyone product or process and is laterexpanded to encompass all companyoperations.

Who will conduct theverification?

This will be dependant on the reasonsfor verification and may be an internalor external auditor. It is essential thatthe team of people with knowledge andexperience of the product andprocesses are used to develop andconduct the audits. The audit focus onconfirming control within key elementsof the traceability systems demandsproduct and process experience.

A team approach to verification isessential.

When?

The key to effective management ofany audit is advance planning anddefining times, resources, andresponsibilities. There are manymanagement methods by which thiscan be achieved including the use of aGannt Chart.

63


How to verify traceability.

A structured checklist can be usedwithin a traceability audit to ensure athorough analysis of the controls. Thisis developed specifically for the scopeand depth of the audit and may bemodified to suit an individual processor production facilities.

A checklist poses a series of questionsto be answered for each element of theprocedure to be audited. Thequestions may be derived fromelements identified in publishedstandards e.g. Codex, ISO 2000,MSC, where each statementcontaining a "shall" or "must"statement is turned into a question.e.g.

The company must have a documented product recall procedure.

Is converted to the question

Does the company have a documented recall procedure?

These questions can be furtherdeveloped using the 5W's and the bigH, to provide a full description of thesituation.

Depending on the depth of auditverification being required the checklistquestions may result in;

• Simple yes / no answers; often using a tick or cross.

• Detailed descriptions of the procedures or operations and observations of their effectiveness inachieving objectives.

Examples of how similar questions canbe asked in order to obtain differentresults and hence different levels ofassessment.

Simple Gannt Chart for verification ofestablishing time management for atraceability audit.

64


• Qualitative assessment of compliance; where the auditor makes a judgement on how well a procedure complies with the requirement.

• Quantitative evaluation of compliance; in which performance measurements are made to determine the efficiency of a procedure/operation.

One method for determining whichquestions should be asked duringverification is to identify each elementor requirement of a standardnecessary to meet the audit objective.Then determine what evidence interms of procedures, records and otherdocuments should be looked at toprovide evidence that they comply. Inorder to determine whether thestandards have been met, details ofwhat should be looked for should alsobe defined. The points that are to belooked for, can in turn be scored as totheir compliance, from which aquantitative analysis of the traceabilitysystem can be completed.

This approach has been developedinto a dedicated audit software toolnow used by the Greek and EastAfrican Government’s to confirmeffective control in export fish and foodproducts. The IT tool has a specificsection on traceability compliancewihich is also described in theGovernment inspection manuals. Thetool was used to assist the AfricanGovernments (Tanzanaia, Uganda andKenya) to strengthen their controlsystems and was supported by theUnited Nations Industrial DevelopmentOrganization (UNIDO).(www.foodcontrolinternational.co.uk)

Excerpt from verification requirementtable detailing the standard, what tolook at and what to look for. The fulltable is reproduced in Appendix 3.

65


8. Concluding Remarks

The book has outlined the legal requirements and international standards relatedto traceability and highlighted the increasing market requirements for such control.

The project team also reviewed traceability approaches in different parts of thefish supply and processing chain and documented how the practical traceability ofproducts can be achieved within the normal working environment. The workdemonstrated that a traceability system links many procedures and managementsystems that are normally operated within a factory, vessel or aquaculture unit. Ageneric traceability system can not exist since each company will differ in itsprocedures and systems. This book therefore provides a practical step by stepillustrated guide to building traceability systems which can be applied to similaroperations by individual companies at any stage of the supply chain.

Traceability control can be successfully achieved using a paper based system oflabelling and recording. However the benefits of using modern technology areclearly shown in larger or more complex operations as they reduce the time andmanual work required to operate the paper-based systems. Traceability systemsalso provide benefits to the individual company beyond meeting the legal andcommercial requirements. The necessary data collection and recording sytemsenable the rapid measurement and analysis of process efficiency and thereforedrive improvements thus increasing the company's competitiveness.

As mentioned at the start of this book this is the beginning of the traceability story-future seafood traceability projects will continue to add to our knowledge on whatworks in practical situations. We are currently implementing the fully integratedsystems into our own pilot plant and the local factories and we look forward tosharing this experience.

The next step is to place example traceability procedures and a full paper basedsystem on the partner web-sites (www.eurofish.dk and www.foodsector.com) in thenear future. The information collected on the time and cost of the differing systemswill be dealt with through web-site discussions.

66


APPENDICES Appendix 1 Case study: demonstrating the importance of traceabilityChloramphenical in ShrimpIn January 2002 officials at the GermanMinistry of Agriculture and ConsumerProtection were investigating a reportfrom their Dutch counterparts thatshrimp containing the banned antibioticChloramphenical, had been mistakenlyexported to a German animal feedmanufacturer and had the potential toenter the human food chain.

Chloramphenical is a powerfulantibiotic with restricted use to combatserious infections such as typhoid andanthrax but it is banned from all foodproducts because of a risk that it maycause a potentially lethal form ofanaemia. In normal shrimp production,the use of antibiotics is commonpractice to ensure disease freemaximal growth of shrimp at highstocking densities. However, beforeharvest there is normally a period (10-30 days) where antibiotics are notused. All traces of antibiotic residuesare naturally eliminated from theshrimp by being metabolised toharmless products.

Over the next few weeks using recordsthat enabled traceability it was foundthat a Dutch company had imported27.5 tons of shrimps containing thepowerful antibiotic. They had beenimported into the Netherlands from theFar East. This consignment was testedat the port of entry to the EU and foundto contain Chloramphenical. Thenormal procedures of either returningthe product to the supplier (over 200tonnes of frozen peeled shrimp werereturned to China in 2001) or

destruction and removal from the foodchain by incineration were notfollowed. Due to procedural errors, theshrimp became part of a consignmentof 188 tons of fish scraps shipped to afeed maker in the German state ofLower Saxony in November and earlyDecember 2001.

The fish waste was then distributed tosix animal feed producers in Germanyand three other companies - one eachin Denmark, Poland, and Romania.The authorities in each of thesecountries were investigating therecords of each to establish whetherthe contaminated material had beenprocessed into animal feed andentered the human food chain.

Fortunately, recent food scaresconcerning bovine spongiformencephalopathy (BSE) in the cattleindustry had resulted in theimplementation of good standards ofrecord keeping and traceability of bothraw materials and final products beingimplemented throughout the EU. Thisenabled the rapid identification of howthe contaminated shrimp had passedthrough the food chain. Apart from 4tonnes of the potentially contaminatedfish meal that had been sold to Danishfarmers and had probably beenconsumed before the problem wasidentified, the entire contaminatedproduct was identified and preventedfrom entering the food chain.

This food scare was caused by an errorin the procedures employed at theseafood processing company.Although it cost individual companiesand Government time and money, itdemonstrates how a traceability

67


system can safeguard the consumer.

The effects of this incident werewidespread, with the EU placing a banon all shrimp imports from China thatresulted in much political discussionthat only just averted a wider scaletrade dispute.

The example also demonstrates howintegrated the food industry hasbecome with the waste of one sectorbecoming the raw material for another,which makes the supply chain evenmore complicated and the need foradequate traceability more important.

Appendix 2

The EAN-UCC Codingsystem.

The International NumberingAssociation (EAN) Universal CodeCouncil (UCC), have developed aseries of coding systems that havebeen globally adopted. This gives astandard means by which product,location and services can be uniquelyidentified. The EAN is a global networkof organisations with memberorganisations in currently 99 differentcountries. Each of the memberorganisations are responsible forissuing company identification codestogether with the EAN memberidentification code.Global Trade Item Number (GTIN)

EAN-UCC 13

Standard format of code number

Depending on the length of the countryand company identification digits thissystem has the potential to individuallyidentify from 1,000 to 100,000 uniqueproducts.

The check digit is automaticallycalculated from proceeding digits bythe labelling software and acts as anerror checking device.

EAN-UCC 14, is the full 14 digitnumber of the EAN-UCC system.

68


It is used to identify trade items that donot cross a retail point of sale i.e. it isgenerally used for transportation ofbulk consignments.

EAN-UCC 12,Is also known as Universal ProductCode (UPC) it is similar to EAN-UCC13 but only has 2 digit countryidentifier. Used exclusively in USA &Canada at point of sale i.e. retaillabelling.

EAN-UCC 8Is a truncated form for use in store itemidentification, the preceding digitsbeing replaced with zeros so thatnumber complies with the EAN-UCC12, 13 or 14 format.

UCC/EAN 128 A more recent development isUCC/EAN 128 this builds on thesuccess of the previous systems. Thissystem expands the amount ofinformation that can be encoded on abar code to include supplementaryinformation such as batch codes,production date etc. It achieves this byintroducing additional prefixes termedApplication Identifiers (AI).

The AIs provide an open standardwhich can be used and read by allcompanies in the supply chainirrespective of the company thatoriginally issued the code.

The system is based on Code128which is a compact system, which hasthree character sets (A, B & C) thatfacilitates the encoding of the full ASCII128 character set. In Character set Cnumeric data can be represented in adouble density mode where 2 digits arerepresented by one character.

There are also 2 independent self-checking features that reduce errors inprinting and scanning.

FNC1 is a non-data character thatalways follows the start character ofthe bar code; this enables scannersand processing software to identify thecode as UCC/EAN-128 so as to ensurethat the correct data is processed.

The UCC/EAN-128 is generally notused in the retail outlets since thescanners used are unable to read orprocess the additional information.

The importance of the additionalinformation is most useful in the supplychain and where traceability of theproduct is considered essential.

Structure of the UCC/EAN 128 bar codedata, the details are explained in theaccompanying text.

69


Appendix 3

Traceability systems checklist

Mathew

Thompson 2003 (unpublished)

70


1. Verification of traceability control

71


72


2. Verification of traceability control

73


74


Appendix 4 Technical contact details

75

Nesco Weighing Ltd.88-91 Lambert Street,Hull,England Tel +44 1482 346865HU5 2SH Fax +44 1482 445483

Email: [email protected]

Omron Electronics Ltd.Opal DriveFox MilneMilton Keynes Tel +44 1908 258258MK15 0DG Fax +44 1908 258158

Web: www.omron.co.uk

Scanvaegt GB Ltd.Felspar CloseThe Warrens Ind. ParkEnderby Tel +44 116 284 3500Leicester Fax +44 116 284 9339LE19 5JS Web: www.scanvaegt.com

Innovation Software Ltd.Innovation CentreEuroparcGrimsby Tel +44 1472 500345N.E. Lincolnshire Fax +44 1472 500313DN37 9TT Email: [email protected]

Web: www.isc-limited.com

Food Control International32 Hainton AvenueGrimsbyN.E. Lincolnshire Tel: +44 1472 348852DN32 9BB Fax: +44 1472 356838

Email: [email protected]


Bibliography

Adams R., 2002. History of the BarBarcode [online], Available fromhttp://www.adams1.com/pub/russadam/info.html

ADCA (Automatic Data CaptureAustralia), 2003. RFID TechnologyExplained Data [online], Available fromhttp://www.adca.com.au/buyers_guide/2003-2004_Buyers_Guide/RFID_Technology_Explained.pdf

Canadian Food Inspection AgencyFood Safety Directorate Office of FoodSafety and Recall. Nov 2001. Make ARecall Plan [online], Available fromhttp://www.inspection.gc.ca/english/fssa/recarapp/rap/ig2e.shtml

Clapp S., 2002. A Brief History ofTraceability [online], Available fromhttp://ift.confex.com/ift/responses/2002/16.doc

Dillon M., 2001. Building EffectiveTraceability Systems: A Risk BasedApproach [CD-Rom], Grimsby UK: MDAssociates, 2001.

Dillon M. & Griffiths C., 1995. How toHACCP and Illustrated Guide,Grimsby UK: MD Associates.

Dillon M. & Griffiths C., 1997. How toAudit, Verifying Food Control Systems,Grimsby UK: MD Associates.

Dillon M. & Thompson M., 2003.Developing and Implementing anEffective Traceability and ProductRecall System. In LEES M. ed.Food Authenticity and Traceability,Cambridge UK: Woodhead Publishing,2003, pp 496-506.

Dillon M., Hannah S. & Thompson M.,2001. Globalisation, Economics AndThe Need For Traceability Systems. In4th World Fish Inspection QualityControl Congress, Grimsby UK. 22October 2001.

Dillon M., Ogier J. & Thompson M.,2001. Systems and InformationTechnology: Paper Systems AndSoftware For Traceability. In 4th WorldFish Inspection Quality ControlCongress, Grimsby UK. 22 October2001.

Economic Research Service (ERS)USDA, 2004. Traceability in the U.S.Food Supply: Overview [online],Available fromhttp://www.ers.usda.gov/briefing/traceability/overview.htm

Evmorphopoulos E., 2001. LegalPerspectives of Traceability inMariculture. In 4th World FishInspection Quality Control Congress,Grimsby UK. 22 October 2001.

FAO Committee on Fisheries, Sub-Committee on Fish Trade, 2002.Traceability of Products from FisheriesAnd Aquaculture. Bremen, Germany[online], Available fromhttp://www.fao.org/docrep/meeting/004/y3015e.htm#p60_675#p60_675

FAO Committee on Fisheries, Sub-Committee on Fish Trade, 2004.Industry workshop on traceability ,Bremen , Germany

FDA Press Release, December 11,2003. FDA And CBP Announce TheirTransitional Compliance Policy OnFood Imports Under The BioterrorismAct [online], Available fromhttp://www.fda.gov/bbs/topics/news/2003/new00995.html

76


FoodTracE, 2003. ConferenceProceedings, London, 11-12 March2003.

Furness A. & Osman K. A., 2003.Developing Traceability Systemsacross the Supply Chain. In LEES M.ed. Food Authenticity and Traceability,Cambridge UK: Woodhead Publishing,2003, pp 473-495.

Hedley C., n.d. Internet Guide toInternational Fisheries Law [online],Available fromhttp://www.oceanlaw.net/guide.htm

Hilbrands, A. 2001. Quality, traceabilityand labelling in aquaculture - a mustto become a preferred supplier? Paperpresented at the ad hoc EIFAC/EUWorking Party on Market Perspectivesfor European Freshwater Aquaculture,Brussels, Belgium, 12-14 May 2001,[Online] Available fromhttp://www.fao.org/DOCREP/004/Y2792E/y2792e0f.htm#bm15.15.

IDtechex , Oct 2004, An IntroductionTo RFID And Tagging Technologies,[online], Available with free registrationfrom http://www.idtechex.com

Krohgs C., 2004 What Is Traceability?[online], Available fromhttp://www.tracetracker.com/chain.html

Morrisson C., (Youngs Bluecrest Ltd).,2003. Traceability In Food Processing:An Introduction. In LEES M. ed, FoodAuthenticity and Traceability,Cambridge UK: Woodhead Publishing,2003, pp 459-472

National Food Processors Association(NFPA), 2002. Traceability - Status OfWork In Codex [online], Available from

http://www.nfpa-food.org/members/international/int_comments/082202traceability.htm

Notermans S. & Beumer H., 2003.Traceability Of Animal Feed. In LEESM. ed, Food Authenticity andTraceability, Cambridge UK:Woodhead Publishing, 2003, pp 518-553

Rippel B., 1999 The New Role Of TheCodex Alimentarius Commission[online], Available from,http://www.foodstuff.org/news/ontheplate/ontheplateindex.htm

Safefood NSW. 2002. Dairy ManualSection 2 - Technical Information FoodRecall. New South Wales Australia[online], Available fromhttp://www.safefood.nsw.gov.au/pdf/4.5.11.Section%202%20-%20Food%20Recall.pdf

Smith I.G. (ed.), 2003. FoodTracEConference Proceedings, London, 11-12 March 2003.

The European Commission, 2002.Comments Relating To TheDiscussion Paper On TraceabilityCodex Circular Letter Cl 2001/27[online], Available fromhttp://europa.eu.int/comm/food/fs/ifsi/eupositions/tffbt/tfbt_ec-comments_cl0127_en.pdf

Theodorou J. A., 2001. Traceability OfThe Greek Seabass - SeabreamIndustry: The Market Perspective. In4th World Fish Inspection QualityControl Congress, Grimsby UK. 22October 2001.

Tracefish, 2002. Philosophy ofTracefish Project, In Fifth draft ofWGC TraceFish standard for captured

77


fish, Annex B,pp28 [online], Availablefromhttp://193.156.107.66/ff/po/EUTrace/WGCaptured/WGC_StandardDraft.docU. S. Food And Drug Administration(FDA) 2003. Food Producers,Processors, And Transporters:FoodSecurity Preventive MeasuresGuidance [online], Available fromhttp://vm.cfsan.fda.gov/~dms/secguid.html

U. S. Food And Drug Administration,(FDA) 2002 Summary Of Title III,Subtitle A of the Public Health SecurityAnd Bioterrorism Preparedness AndResponse Act Of 2002.Title III -Protecting Safety And Security OfFood And Drug Supply Subtitle A -Protection of Food Supply [online],Available fromhttp://www.cfsan.fda.gov/~dms/sec-ltr.html#attach-a

World Seafood Market News Digest,2003. U.S Co Brings RFID To FoodIndustry For End-To-End Traceability[online], Available fromhttp://www.worldseafoodmarket.com/NewsDigest/NewsDisplay.jsp?category=Technology&&filename=TEC58.html

Organisation Websites

European Community Comments forthe Codex Committee on GeneralPrinciples, Consideration ofTraceability/Product Tracing, Paris,France, 7 - 11 April 2003 [online],Available fromhttp://europa.eu.int/comm/food/fs/ifsi/eupositions/ccgp/ccgp_ec-comments_cx-gp03-7_item6_ en.pdf

Europa, Available fromhttp://europa.eu.int/eur-

lex/en/index.html The web portal toEuropean Union law, from whichcopies of the following legislation canbe obtained by using the OfficialJournal reference in the searchengine.

Foodtrace, Available fromhttp://www.eufoodtrace.org/ Detailsand results of European Commissionconcerted action project QTLRT-2000-02202.

Food Traceability Report. FCNPublishing, USA, Available from,http://www.foodtraceabilityreport.comProvides updated news on traceabilityissues

Council Directive 93/43/EEC of 14June 1993. On the hygiene offoodstuffs. Official Journal L 175,19/07/1993 pp 0001 - 0011

Regulation (EC) No 178/2002 of theEuropean Parliament and of theCouncil of 28 January 2002. Layingdown the general principles andrequirements of food law, establishingthe European Food Safety Authorityand laying down procedures inmatters of food safety. Official JournalL 031, 01/02/2002 pp 0001 - 0024.

Council Regulation (EEC) No 2847/93of 12 October 1993. Establishing acontrol system applicable to thecommon fisheries policy. OfficialJournal L 261, 20/10/1993 pp 0001 -0016

Council Regulation (EEC) No 2847/93of 12 October 1993. Establishing acontrol system applicable to thecommon fisheries policy. OfficialJournal L 261, 20/10/1993 pp 0001 -0016

78


Council Regulation (EC) No 104/2000of 17 December 1999. On thecommon organisation of the marketsin fishery and aquaculture products.Official Journal L 017, 21/01/2000pp0022 - 0052

Corrigendum to CommissionRegulation (EC) No 2065/2001 of 22October 2001. Laying down detailedrules for the application of CouncilRegulation (EC) No 104/2000 asregards informing consumers aboutfishery and aquaculture products (OJL 278 of 23.10.2001). Official JournalL 010, 12/01/2002 p 0082 - 0082

Tracefish, Available from


http://www.tracefish.org/ Provides links to voluntary standards for traceability inthe fish industry.


a guide to traceability within the fish industry · the traceability projects discussed in bremen...

Documents