Animal Food Traceability - It Is More Than a Recall Plan

Written by: Louise Calderwood   |   January 15, 2024

Around 200 B.C., when the Silk Road opened the transportation of silk, fruits, livestock and grain from China to modern-day Europe, the lesser-known Royal Road had already been a major communication link for almost 300 years, providing a route for couriers from present-day Iran to Western Turkey. One could say that communication and the transportation of food have been connected ever since, for over 2,600 years.  

From the era of horses galloping through rocky passes to the age of electrons carrying information, the fundamental pillars of traceability—the who, what, when and where—still directly impact the quality of the traceability system for human and animal food. What lies ahead in this ever-changing landscape?  

While animal food may be exempt from the requirements of the Food Safety Modernization Act Final Rule for Traceability, it is likely the marketplace will drive the need to quickly track the source and distribution of food for livestock and pets in the future.  

Traceability is more than just food safety. Last year, the Council for Agricultural Science and Technology (CAST) with the Institute of Food Technologists (IFT) distributed an issue paper examining food traceability fundamentals, including the development and use of various technologies to enhance food safety and consumer confidence. The report stressed that traceability reaches beyond food safety and is propelled by many things, such as consumer demands around environmental concerns and even regulatory requirements (e.g., bans on imports from the Xinjiang region of China). 

The era of camels plodding across the steppes is gone, traceability and recalls are expected to occur about as quickly as data moves along the internet. The portion of the CAST report focusing on agriculture emphasized that traceability systems rely on good data from trusted sources, requiring a comprehensive investment in system design and maintenance efforts. Throughout the report, CAST emphasized the need to address staff training, technology and standardization of systems in cultivating quality data.  

Emerging tools and technologies, like decentralized identifiers (DIDs) and verifiable credentials, offer promising opportunities to improve trust in the digital data used for traceability. Built on the principle that users are in control of their identity data through systems, which are tamper-proof and resilient against identity theft and other attacks, the digital supply chain transformation is part of a bigger conversation happening in the manufacturing sector. First named the Fourth Industrial Revolution, or 4IR in 2016, the speed and accuracy of traceability of food production, processing and distribution are increasing at breakneck speed with the application of big data analytics, artificial intelligence and machine learning. 

 Understandably, the Food and Drug Administration’s Food Traceability Rule is focused on food safety and includes standardized data collection requirements for certain high-risk foods, like some cheeses, eggs, nut butters, seafood and a wide assortment of fruits and vegetables. From the perspective of the FDA, traceability equates to recalls.  

Current FDA regulations state that manufacturing facilities that produce animal food with known hazards identified in their animal food safety plans, which require preventive controls to be in place, must also have written recall plans. Those measures mesh well with the food safety culture that is already embedded in much of the animal food industry.  

Shortly after publication of the CAST report, the American Feed Industry Association submitted comments to the FDA on modernization of the recall of regulated products. In that letter, we encouraged the FDA to increase the efficiency of business responses to recall requirements by clarifying the differences between quality recalls, more accurately described as technically market withdrawals, and food safety recalls, disseminating the agency’s expectations and ramifications of each, and developing a consistent template for notifying direct consignees about recalls. For many companies in the animal food industry, the efficiency and effectiveness of recall information exchange and ensuring effective recalls is currently part of the culture of food safety. 

Ever since the era of Persian kings and Chinese dynasties, communication and the movement of food have been linked. In today’s world of digital traceability tools, is the animal food industry prepared to keep pace with the changes and present more efficient ways to trace food? After all, the value of the animals we feed is greater than “all the tea in China.”