Internal Traceability And External Traceability

Traceability itself does not make food safe. However it is a risk management tool whenever a food safety problem is concerned. Past experiences have shown that the operation of food or feed market can be jeopardized when it is impossible to trace food or feed. Seafood is a highly perishable food item, increasingly globally traded and many particular conditions have to be taken into account (Schröder, U. 2008). Therefore a comprehensive system of traceability is targeted to avoid unnecessary wider disruption in food business.

According to ISO 8402:1994, traceability is defines as the ability to trace the history, application or location of an entity by means of recoded identification. Starting from 2002, all fishery products in European Union must be labeled with commercial designation of the species, the production method and the catch area or production location according to traceability Requirements for Fish (Regulation EC/2065/2001). E.U. General Food Law Regulation 178/2002 (Article 3) mentioned that traceability means the ability 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. Traceability is mentioned in the Food Hygiene Regulation 2009 (Regulation 10) that it should be identified as one step back from where the food came and one step forward where the food went at any specified stage in the food chain

80.5% of fishery production in Malaysia is captured whereas 94.4% of seafood in European Union is capture fisheries. Marine fish landing in Malaysia has been quit consistent around 1300 tonnes per annum (Buku Perangkaan Perikanan Tahunan, 2009; Fisheries statistic, 2011). However, there is a trend of dropping in the capture of fishery products in the European Union from 7253 tonnes in 1998 to 5148 in 2008. Hence, European Union tends to import more fish and has stringent rules and regulations on the import of seafood products.

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Traceability procedure may seem to be lengthy but its importance and benefits outweigh its all. The main purpose of traceability is to improve safety and quality control and this could boost import potential, market access and lead to better business management and efficiency. In food safety issue, it not only safeguards against bioterrorism, but also enables immediate recall and withdrawal when a risk or hazard is identified. Besides that, it also provides a channel for transparent and fair trading between operators. Accurate information is provided to the public so that consumers will not be misled by inaccurate label and make informed purchasing decisions. Traceability records help control authorities to perform better risk assessment (Regulation (EC) No. 178/2002 (Article 18)). Traceability also helps to increase one’s market share or product value. Its importance in the implication of sustainable fishing may be unseen by the society. With traceability record, seafood business operators cannot make false claims and we can get rid of the false perception of plentiful seafood supply in the marine ecosystem.

2.0 Internal Traceability and External Traceability

Generally, traceability can be divided into two types, which is the internal traceability and external or chain traceability. Internal traceability is the recordkeeping of a product within a particular operation, company or production facility. It relates the data about raw materials and processes to the final product before it is delivered. Many seafood processing companies have effective internal traceability systems as part of their HACCP based quality assurance systems. Internal traceability is aimed at productivity improvement and cost reduction within a production unit such as fish plant. This type of record keeping is already required throughout the seafood industry as it is essential for keeping track of inventory, purchasing and other in house accounting.

External traceability refers to traceability the product outside of a business entity, in the entire supply chain. It is between companies and countries and depends on the presence of internal traceability of each entity. Therefore it is a challenge that requires the cooperation of all operators in the supply chain from farm to table. For instances, external traceability allows the tracking of a product and attributes of that product through the successive stages of the distribution chain such as from boat or fish farm to table. “One step back” and “one step forward” approach is the simplest model of external traceability. It comprises the capability to track the movement of the product forward through the supply chain to understand where it has gone, what it has gone into and what it has come into contact with. Besides, it enables to trace a product back to understand the custody chain of product, components and ingredients. Under this system, each partner in the supply chain is responsible to record input and output data but not for information which may be several steps ahead or behind in the supply chain (Can-Trace, 2007). Tracing upstream means looking back along the supply chain towards the harvester or producer steps. Downstream looks forward towards distribution and consumption. External traceability makes use of a set of tools that aids in traceability such as identifiers, carriers (Bar code and RFIDs) and readers. As seafood supply chains become longer and convulated, there is raising demand for external traceability data by both regulators and consumers.

Both internal and external traceability system had been used in European Union (EU) and Malaysia. They are used to achieve different purposes or objectives such as for food safety regulatory requirements or to ensure quality and other contractual requirements. Besides a well-developed technological infrastructure, the speed of trace-back and trace-forward (traceability) is influenced by well-functioning and well-organized competent authorities (CAs). Legistlation and the accuracy, efficiency of data exchanges and controls are vital to the functioning of the CAs. The Malaysia food safety system is characterized by its complexity and diversity with different authority entrusted with the task of ensuring food safety at different stages of the food chain such as Ministry Of Health (MOH), Department Of Fisheries (DOF) and Fishery Development Authority Of Malaysia (LKIM).

C:UsersCH@RLENEDesktopFood traceability systemexternal and internal.jpg

Figure 1: External versus internal traceability. (Source: Petersen and Green, 2007)

3.0 Fishing Scenario in Malaysia: What Causes Malaysia to Change?

The introduction of import conditions for seafood and other fishery products by European Union (EU) in year 2002 had been a wakeup call for the Malaysian authorities. In year 2005, the Directorate General of health and Consumers (D.G. Sanco) visited Malaysia after the harmonization of the EU members import condition. Among the main problems identified were (Shahridan and Nagalingam, 2011):

No specific legislation was in place to ensure that fishing vessels and landings sites are in line with EU standards,

No generic approval of a farm for export, those who wish to export must register with the Animal Health Quarantine Centre of the Department of Fisheries,

Laboratories involved in testing were not adequately equipped and staff were not knowledgeable enough,

The HACCP programme was not a prerequisite for an establishment to be proposed for the EU export list, and

There was a need to implement minimum hygiene standards in processing plants, fishing vessels and landing sites.

After the findings, recommendations were made to improve the situation by the next visit in 2008. In year 2008, D.G Sanco found that most of issues from the previous visit have not been addressed and concluded that all official controls put in place by the Malaysian competent authority were not equivalent to the EU requirements for import of live fish and finished products. Therefore, EU contemplated to impose a ban, which would then be gazette into a law which would be harder to reverse. This lead the Malaysian competent authority to immediately impose an unilateral export ban to the EU (Shahridan and Nagalingam, 2011).

The impact of unilateral EU export ban caused huge lost to the seafood and fishery products industries and the government. Forty-five processing establishments and one freezer vessel lost their licenses or EU numbers to export to the EU immediately. Processing plants that had their shipment ready for EU and also in process had to appeal for a gestation period to fulfill those orders. The ready stock for the upcoming EU festive seasons had to be reprocessed and repacked for other countries. Half of the processing plants in the country shut down and many lost their jobs overnight (Shahridan and Nagalingam, 2011).

Several improvements were implemented to meet the EU requirements. New regulations were enacted (Table 1) and the official controls put in place by the Malaysian competent authorities were reorganized (Figure 2). Details regarding traceability were discussed in detailed in the next subtopic.

Table 1: New regulations enacted to improve the food safety regulations.

Regulation

Content

Food Hygiene Regulation 2009

Health certificates need to be issued for all relevant parties involved in finished product heading for the EU.

Fisheries Regulations 2009

Fishing vessels and aquaculture farms have to get quality control certification for seafood that would be processed into finished product for the EU.

Lembaga Kemajuan Ikan Malaysia Regulations 2010

Hygiene and recognition of fish landing sites approved for raw material heading to the EU.

MOH

DOF

LKIM

Central competent authority

Directly responsible for public health in this matter.

Controls of potable water supply

Competent authority directly responsible for animal health matters in this area.

Competent authority for issuing the license that allows a company to carry out the activity of import/export of live fish or final product (fishing vessels).

MOH

DOF

LKIM

Middlemen/ Transporters

Processing plants

Sources of imported raw material

Water and ice sources

Aquaculture farms

Fishing vessels

Landing sites

MOH: Ministry of Health

DOF: Department Of Fisheries

LKIM: Fishery Development Authority Of Malaysia

Figure 2: Reorganization and detailed description of competent authorities’ framework.

(Source: Shahridan and Nagalingam, 2011)

Improvements

4.0 Chain Traceability

The ability to connect incoming and outgoing goods or one-step backward and one-step forward is a prerequisite for chain traceability to show the relationship between business partners. This requires that the business partners are known to each other and able to cooperate to successfully create traceability graph. This graph is a representation of elements and relationships consisting of knowledge about a traceable unit represented as a directed graph of trace events and relationships to resources, actors and other traceable units (Tracefish, 2009).

Before establishing chain traceability, one must decide on what system, method and tracing tool to be used to identify, mark and label his products. It is also necessary to be able to define business partners that are involved in the traceability. The partners should be divided into the following categories which are: suppliers (producers of raw materials, ingredients, finished products and packaging), customers (retailers) and transporters. Types of traceability system and the food supply chain will be further discussed below.

4.1 Paper-based and electronic systems – Identification, marking and labelling

Paper based system and electronic system are examples of traceability system used throughout the food supply chain. The purpose of both systems is to provide information, recording and linking of the particular food from farm to fork. Most traceability system adopted by companies utilizes the mixture of paper and electronic systems. The key factor in determining the type of traceability system depends on the size of the company.

In both European Union (EU) and Malaysian perspectives, there is no definite and singular system to be employed throughout the food supply chain. In EU General Food Law, Article 18 states that the system must simply guarantee a link supplier-product and a link customer-product which allows providing the essential information to the competent authorities upon their request. The same goes for the Malaysia, whereby Regulation 10 in Food Hygiene Regulation 2009 states that a food traceability system shall be provided to be able to identify one step back and one step forward at any specified stage from production to distribution.

Although there are differences in approaching traceability and major structural differences between the chains for different types of fish, products and varies among countries, there is also a degree of commonality in information requirements by the respective law and regulations. These information requirements can be categorized as (Tracefish, 2009):

Each food business has to collect and record information and make it available to the competent authorities upon request and to other food business operators for the purpose of product withdrawal or recall.

Information on the nature of the food and the operations involved is required for particular purposes and must be available to the appropriate authorities.

Commercially desirable information on the nature of the food and the operations can be requested by food business for reasons such as, Good Manufacturing Practice (GMP), ethical, environmental, quality assurance records, raw material or product standards and specifications.

Paper traceability system is widespread and is the oldest system used throughout the supply chain. Most companies in both EU and Malaysian, who are making small profit and producing limited quantity of products, utilise this system as it is cheap and changes can be easily made. However, its disadvantages are manually intensive, reliant on correct procedural operations, trace-back of information is time consuming and difficult and records are not easily reviewed. A paper traceability system also requires a lot of storage space.

Electronic traceability consists of bar code systems and Radio Frequency Identification (RFID) systems. Bar code systems are widely used and are well established in the food industry in both EU and Malaysia. It is inexpensive to implement and use. EAN.UCC system (European Article Number and Uniform Code Council) are the most widely used across EU. The more recent RFID technology uses tags that send identification codes electronically to a receiver when passing through a reading area. RFID identifiers consist of a surface/chip, which can be attached onto or implanted into any surface to provide encoded information of identity. One of the major advantage of RFID is that it is able to scan the whole pallet in seconds while passing through a reader area as many tags can be read simultaneously even when not in-line of sight which is the disadvantage of bar codes. However, RFID is less widely used technology in EU when compared to bar code technology as it is expensive. Thus far, the usage of RFID technology in Malaysia has not been introduced in tracking seafood product. However, RFID technology had been introduced in government-run livestock tracking programme which is funded by the veterinary Department of Malaysia’s Ministry of Agriculture and Agro-based industries to control disease outbreaks among livestock (RFIDNews, 2009). One major advantage of electronic traceability systems is their ability to handle large amounts of information in a precise manner. Records and reports regarding traceability can be retraced in a short amount of time.

Figure 2: Example of bar code (left) and RFID tag (right).

In EU, all establishments handling food of animal origin must be approved by the national authority. Establishments here included abattoirs/slaughterhouses, cutting plants, processors etc. All foods produced by the approved establishments must carry an EU identification mark, indicating the approval number. Under Regulation EC 1907/90, identification marks are required for all other products of animal origin except for eggs. This legislation came into force in January 1, 2006 to ensure traceability for products of animal origin. The mark must be in oval shape, legible, indelible and clearly visible for inspection. The first part of the approval number is a two-letter national code (UK for United Kingdom), indicating the country in which the food was produced, followed by a site-specific approval number and ending with the abbreviation (EC) for European Commission (Reily, 2009). This kind of regulation however is not implemented in Malaysia.

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Figure 3: EU identification mark comprising country code (UK), establishment code (AZ020), European Commission indication (EC).

4.2 Traceability in fish catching

In both EU and in Malaysia, information on vessel name, fishing trip number, time of catch, quantity in haul, batch size, landing area and fishing area are required to be recorded. The method of record keeping could be paper or electronic, depending on individual company.

The only difference between EU and Malaysia is that the existence of a central database system for foods in EU (TraceFood) for tracking the movement of products. This allows information to be recorded and registered in each link. In Malaysia, information is managed manually; each organization has their own way of keeping and transferring information.

In EU nations, fish are sorted on board according to species and iced in boxes. Each box is labeled with information on fish species, catch, date, vessel name or number and a unique box number, readable as ordinary numbers and in the form of a bar code. The information is registered in a computer onboard the vessel and the data are transmitted via a mobile phone to a computer at the next step in the chain, the collector. This enables the collector to receive all information from the vessel before it enters the harbor. At the collector, each specied of fish is sorted according to size, keeping the fish from each catch date separated to enable fish to be traced according to the same vessel with the same catch date. At the collectors’ stage, information about the collector name, fish size/weight and a new box number registered at the computer adding this new information to the database (Frederiksen and Gram, 2004). This kind of technology is not implemented in Malaysia due to its high implementation cost and training cost to the fishermen.

Nevertheless, ongoing effort is being conducted by the Malaysian authorities to improve the traceability in both fish catching and aquaculture farms. The introduction of import conditions for seafood and other fishery products by EU in year 2002 was a wakeup call to Malaysian authorities. To enforce traceability in fish catching, all fishermen need to get comply regulations in Fisheries Act 1985 :(i) Fishing license (ii) Fishing vessel permit/license (iii) Permanent marking of ID on fishing vessel. In aquaculture farms, Malaysian Aquaculture Farm Certification Scheme (SPLAM) was introduced which incorporated traceability principles. SPLAM is managed by Department Of Fisheries (DOF) which emphasizes in the implementation of HACCP at source. It is a voluntary scheme to encourage Good Aquaculture Practice to ensure the safety, quality, consistency and competitiveness of the products based on criteria, guidelines and standards determined by DOF. Aquaculture entrepreneurs have to fulfil certain requirements and criteria set by the DOF Malaysia, make an application, undergo a review audit and final approval before their farm can be awarded the certificate and logo (Department of Fisheries Malaysia, 2011).

4.3 Traceability in fish processing plant

The information generated from the stage of fish being catches on vessel until reaches the end consumer are transmitted from one link to the next unit. In fish processing plant, the raw material received to be processed from its own fishing vessels. The information that may obtain from catching and from production stage are shown in the Table 2. The freshness of fish and fishery products are important along the processing as these products are perishable commodity. It needs to be evaluated frequently. There are several evaluation methods could be chosen from, which included microbiological methods, biochemical and chemical methods, physical methods as well as sensory methods.

Table 2: Information registered or generated in fish processing stage.

Information from catching

Information from production

Vessel name

Fishing trip number

Fishing area

Fish species

Units per catching day

Condition of fish

Weight of fish

Ratio of ice to fish

Other parameters

Name of product

Origin of raw material

Plant number

Authorisation number (especially for EU perspective)

Product number or code

Production date or lot number

Best before date

Product weight

Temperature

Quality and processing parameters

Sensory evaluation results

Microbiological results

In Europe, since the European Union (EU) Regulation 178/2002 requires mandatory traceability for all food and feed products in EU countries, there is a comprehensive and complete traceability system implemented in the region. In the fish processing plant, several batches of raw materials may be processed into different finished product in one day. Different batches of raw materials came from different vessels, and graded mechanically. The graded raw materials will be distributed into different containers or tanks according to size. Each container labelled with a grade ID. These graded fishes are ready to be processed, which is also known as in-feed batches. The in-feed batch ID carries the information which able to be tracked back from final product. The information are carried between links of batch number, grade ID and in-feed batch ID, or even final products. The processing manufacturers must also able to identify whom they provide their products to.

For Malaysia perspective, the traceability in fish processing plant is adopted from ISO 22005, Hazard Analysis and Critical Control Point (HACCP), Good Manufacturing Practice (GMP) and Sanitation Standard Operating Procedures (SSOP). ISO 22005 described a traceability system is influenced by regulations, product characteristics and customer expectations within a feed and food chain. The manufacture company should identify the product or ingredients used, the raw materials’ suppliers and finished products’ customers, flows of materials, manufacturing process history and other related information. These information shall be recorded as documentation for traceability data.

Hazard Analysis and Critical Control Point (HACCP) is aimed to determine whether there is any food safety hazards that are likely to occur on the fish and fishery product processed through the analysis and control of biological, chemical and physical hazards from the raw material, to processing, distribution and consumption of the finished product. At the same time, the hazard analysis is to identify possible preventive steps that may be applied to control those hazards. The general records that required to make included name and location of the processor or importer, date and time of the activity that record reflects, signature or initials of the person performing the operation and identity of the product and its production code. These records should be done at the time that it is observed. All records as well as all plans and procedures required should be available for official review and copying at reasonable time periods, usually 1 year from the processing date for refrigerated products and 2 years for frozen, preserved or shelf-stable products.

Good Manufacturing Practice (GMP) certification scheme aimed to assist manufactures of food products and food related products to provide assurance to consumers that the products are manufactured in a hygienic manner and the best practices in manufacturing accordingly. GMP is one of the pre-requisite programmes (PRP) required to established prior implementation of HACCP. Records are made along the manufacture process show all the steps required by the defined procedures and instructions were taken to achieve the expected quantity and quality. The documentation may divide into quality manual, operating procedures and support documentation. Support documentation will be the significant element for traceability system. It records how the manufacture company carries out and details of their processing process on materials, procedures, operations and finished products. These records may enable the complete manufacture process of a batch to be traced are retained in a comprehensible and accessible form.

Meanwhile, Sanitation Standard Operating Procedures (SSOP) emphasize on the sanitation aspect for a fictional seafood company processing a cooked ready-to-eat seafood product. There are several steps in this operating procedure and several records had been made accordingly. Daily Sanitation Control Record is the main document that used in seafood processing monitoring, such as in safety of processing water and ice, condition and cleanliness of food contact surfaces (included utensils, gloves and outer garments), prevention of cross-contamination, protection of food, food-packaging material and food-contact surfaces from adulteration, labelling, storage, employees’ health and hygiene, toilet facilities as well as pest control. Other documents are included municipal water bill and periodic sanitation record, building plumbing inspection report and periodic sanitation control record. These records will be reviewed and kept on file for two years.

4.4 Traceability during Fish and Seafood Products Transportation and Storage

In EU perspective, information needed to be kept during fish transportation and storage includes the name and address of supplier, quantity, batch number and the nature of the supplied fish and seafood products. Other information such as areas and dates of harvesting, location and the date of processing and packaging are also necessary. A more detailed description of the products is recommended such as pre-packed or bulk products, processed or raw fish and seafood products. The conditions of the transportation means should be recorded specifically. This includes the temperature, humidity and the atmosphere of the transport vehicles, length and conditions of handling and also the duration of transportation and storage. The location where the products are stored and the date by which the products should be used are needed to be recorded. Meanwhile, the name and address of the customer (wholesaler or retailer), quantity, batch number and the nature of the fish and seafood products that were delivered to the customer and the date of transaction or delivery should also be recorded.

Whereas in Malaysia, basic information such as the name and address of the supplier, quantity and batch number are recorded. Registration and validation of the cold chain maintenance is required. Record keeping of the temperature and time control, GMP records such as the personnel and sanitation is also required. In general, the information recorded in the transportation in Malaysia is similar to the information recorded in EU.

4.5 Traceability in Retailer

The record keeping of retailer in EU and Malaysia shares the commonality. The retailer should have the record on the information of the producer’s name, product name and quantity, pallet number, carrier’s name, shipment number and also wholesaler’s name and address. RFID system and bar code can be used upon the arrival of the products and these systems aid in the traceability of the food products. Besides, the temperature and hygiene of storage conditions of the products upon receiving; date and places of arrival should also be recorded. Types of boxes or container used and the weight of the fish and seafood products should also be recorded. In addition, the retailer should have the record on the origin of the products.

In general, the commercial documents for these highly perishable products are usually kept for the period of 6 months after the manufactured date or delivery. The legislation of handling and processing of fish and fish products for export to EU are controlled by the Fisheries (Quality Control of Fish for Export to the European Union) Regulations 2009 under Fisheries Act 1985 together Food Export (Issuance of Health Certificate for Export of Fish and Fish Products to the European Union) Regulations 2009 and Food Hygiene Regulations 2009.

4.6 Information available to customers

It is important that there is information available about the seafood products sell in the market for consumers. This is to enhance consumer confidence and by confirming the foods that they consume are safe as well as free from any contamination or diseases. Besides, it is also to strengthen the food safety by increase the effectiveness of product recall during the emergency case such as food poisoning. Information on traceability system enables consumers to avoid specific seafood easily due to the allergenicity, food intolerance or even lifestyle choice (ICTSD. 2006). For consumers, traceability system provides a more controllable condition in food chain which meant to deliver a safer and higher quality of food. Thus, traceability system may be an effective system that provides information about the whole process of product, from the production to the distribution among consumers by providing the consumers information of the origin for that particular product and give consumers a greater choice in deciding whether to buy or not.

Basic information such as species of seafood product, origin of product and suppliers is needed on the package of products as well as Halal certification/ authentication especially in country like Malaysia. With this information, consumers will feel safer in that they will be able to see the detailed information about the origin country and also the farm of the seafood products. Due to the undeveloped and inappropriate management of traceability system, Malaysia is still practicing conventional and manual record keeping. Thus, more detailed information about the product is not available to customers in the market. In developed countries like EU, there are tools to identify the trade and logistics items such as EAN.UCC system. Every item will be given one unique number, and the number will give identity to the products and consists of information concerning the products.

Besides, it is capable in providing the locations where the products are assigned and ensure the efficient flow of products. Through the system, information related to the products can be passed from one stage to another until to the end, which is to the consumers. The information available to consumers are such as fish species (Trade/ Latin name), catching area, catching date, production me