traceability_factsheet.pdf

TRACEABILITY FACT SHEET FOR CATERERS

BACKGROUND

Since 1 January 2005, all food businesses have a legal responsibility to implement a

traceability and recall system. The requirements are laid down in Regulation (EC) No.

178/2002 of the European Parliament, and of the Council of 28 January 2002 laying

down the general principles and requirements of food law, establishing the European

Food Safety Authority and laying down procedures in matters of food safety (referred to

hereafter as ‘the General Food Law’).

SCOPE OF THIS FACT SHEEET

This fact sheet is directed at Food Business Operators (FBOs) working in catering

premises. It outlines the requirements laid down in the General Food Law. Other legal

traceability obligations with respect to labelling, country of origin and tracing genetically

modified organisms are not covered in this fact sheet. This fact sheet is intended to be

read in conjunction with relevant guidance notes from the FSAI, including Guidance

Note 10 on traceability and recall.

WHAT IS TRACEABILITY?

‘ Traceability means the ability to trace and follow a food, feed, food-producing animal or

substance intended to be, or expected to be incorporated into a food or feed, through all

stages of production, processing and distribution ’ (the General Food Law).

WHY IS IT NEEDED?

Traceability is necessary to ensure food safety, and to assist in the removal of unsafe

food/feed from the market. Traceability also has other advantages for the food industry

but these lie outside of the scope of this fact sheet.

WHAT ARE THE BENEFITS TO YOUR CATERING BUSINESS?

· In the event of a food incident, a traceability system is essential to enable your

business to track and trace any foodstuff which is unsafe. Without a traceability

system, a product recall/withdrawal would be more difficult and extensive.

· Protection of the health of your customers by enabling a rapid response to food

incidents.

· Financial benefits - a complete traceability system will ensure that only the

incriminated foods are recalled/withdrawn in the event of a food incident.

· Protection of the integrity of your business.

GUIDANCE ON THE LEGAL REQUIREMENTS FOR FOOD

BUSINESS OPERATORS

The legal requirements for FBOs in relation to traceability are outlined in Article 18

(sections 2-4) of Regulation (EC) No. 178/2002. This Article should be read in

association with Recital 28, Recital 29 and Article 3 Point 15.

General Requirements for Traceability Systems

· Supplier traceability: FBOs should be able to identify any “person” from whom they have

been supplied with a food, or any product expected to be incorporated into a food. This person

may be an individual (e.g. a fisherman) or a food business (e.g. an ingredients company).

· Customer traceability: FBOs must be able to identify the immediate customers of their

products. (For caterers this is only applicable when the immediate customer is another business

but not when the immediate customer is the final consumer).

· Systems and Procedures: FBOs must have systems and procedures in place so that information

regarding ‘supplier traceability’ and ‘customer traceability’ is available to the Competent

Authority upon demand.

· Labelling: Any food which is placed on the market must be adequately labelled or identified to

ensure traceability throughout the food chain.

Requirements Regarding Information Maintained in Traceability Systems

Required (Category 1)

(This mandatory information must be kept by catering businesses):

· Name & address of supplier and the nature of products supplied

· Name & address of customer and the nature of products delivered to that customer (not

for caterers only supplying food to the final consumer)

· Date of transaction/delivery

Category 1 information should be made available to the Competent Authority upon demand.

Recommended (Category 2)

(It is advisable, but not mandatory, that this additional information should be kept):

· Volume or quantity of foodstuffs

· Batch number (if any)

· Detailed description of the product (e.g. pre-packed or bulk product, variety of

fruit/vegetable, raw or processed product)

If kept, Category 2 information should be made available to the Competent Authority as

soon as is reasonably practicable.

Requirements Regarding Storage of Traceability Information

Traceability information can be stored in any form, either paper or electronic. However,

an FBO must organise the information into a traceability system covered by related

procedures.

Delivery dockets may be an effective mechanism for maintaining this information

providing that they contain the required information, are organised into a traceability

system, and the information can be made available to the Competent Authorities

immediately on demand (see Required Information in box above)

Records on traceability should be maintained as follows:

Food type

Time period for keeping records

1) Non-perishable foods with a “best before” date less

than five years.

2) Non-perishable foods without a specified shelf life

(e.g. wine).

3) Perishable foods with a “use-by” date greater than

three months

4) Perishable foods with a “use-by” date less than three

months supplied to another food business for further

processing

Five years

1) Non-perishable products with a specified shelf life

greater than five years

Period of the shelf-life plus six months

1) Perishable products, which have a “use by” date less

than three months destined directly for the final

consumer

2) Perishable products without a specified “use-by”

date (e.g. fruit and vegetables, non-prepacked food)

destined directly for the final consumer

Period of six months after date of

production or delivery

GUIDANCE ON BEST PRACTICE

The General Food Law does not compel FBOs to establish a link (internal or process

traceability) between in-coming supplies and out-going products. However, in the event

of a food incident, this type of link would be beneficial as it would contribute to more

targeted and accurate withdrawals/recalls. When determining whether an internal/process

traceability system should be implemented, consideration should be given to the nature

and size of your business:

Catering businesses supplying other businesses (e.g. wholesale caterers)

Implementation of an extensive internal/process traceability system is highly recommended.

The following are the keys points:

¶ Identify a product batch. To ensure that a product batch is a true batch it must be separated

by a cleaning break from other product batches using the same equipment. If this is not

possible, a product recall/withdrawal may require the removal of the affected product

batch plus any other product batches where carryover of ingredients is likely.

¶ A unique batch code should be produced for each product batch. All information relating

to the production of the batch (i.e. ingredients, packaging, QC records etc) should be

linked to this code.

¶ The batch code should be applied to i) each unit in the batch, ii) the outer case and iii)

documentation accompanying the batch.

Catering businesses supplying food direct to the final consumer (e.g. canteens,

restaurants)

Implementation of an extensive internal/process traceability system is not necessary; however

consideration should be given to a number of issues:

¶ A stock rotation system should be implemented to monitor/trace the use of ingredients by

the business. This type of system will be beneficial in the event of a recall by a supplier.

¶ Recipes and menus should be reviewed on a regular basis and updated, when necessary, to

ensure the traceability of the ingredients through the catering process.

SUMMARY OF WHO SHOULD DO WHAT

The following table summarises the scope of the traceability system which should be

implemented by catering businesses.

Function/nature of the catering business

Scope of the traceability system

Supplier

traceability

Process

traceability

Customer

traceability

Supply of food direct to the consumer

(e.g. restaurants, canteens etc)

B *

N/R

Supply of food to other businesses (e.g. wholesale

caterers)

____________________________________

* Implementation of an extensive process traceability system is not necessary for these

businesses; however consideration should be given to a number of issues.

L: Legal Requirement, B: Best Practice Recommendation, N/R: Not Required

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