Traceability Overview
Traceability is a system in which fruits and vegeta- should be on each container in the lot and recorded
bles can be traced from the field to the buyer by lot on the invoice. The benefit of having the lot number
through unique codes. A code could be a number, on the container is that in the case of co-mingling
number-letter combination, or some other designa- with other lots, each container is identifiable.
tion that is unique to the lot. Each farm should have
a traceability system in place that allows the grower Lot Number Specifics
to track the produce from the field (one step back) A lot number is a unique code that identifies a des-
to the buyer (one step forward). Traceability is made ignated lot. The number (which can also include
easier by establishing lots so each distinct lot can be letters) should incorporate the date. Many growers
traced separately. find using the Julian calendar date useful when
developing lot numbers. From the lot number, you
Who Needs a Traceability System? should be able to identify the following information
Everyone. Being able to identify and recall a defined about the lot:
segment (or lot) of contaminated product not only n Commodity/Produce item
protects consumer health, but also helps reduce your
losses by not having to recall the entire lot. In case of n Farm location where produce was grown
a foodborne illness outbreak or customer complaint, n Field where produce was harvested
you will be able to identify what products you have
n Harvest date
in the marketplace, determine when they were sold,
and recall them if necessary. A working traceability n Harvest crew
system is an asset to your farm because it can be n Packinghouse used (if any)
used to settle customer complaints and questions
about the product that was sold. If you direct market
n Packing date (if different than harvest date)
at farmers markets or other places where the buy- n Packing crew (if different than harvest crew)
ers are anonymous, develop a system to track what
Growers can use existing farm and planting maps to
you took to market (where it came from and when it
establish field numbers to reference in harvest logs
was harvested) and document what was sold (crop,
that track harvest and packing dates. If the farm only
volume, date and location). If you have an on-farm
has a few employees, the employees can be grouped
market, keep track of what you put out for sale and
together as one harvest crew responsible for picking
how much is sold each day. Another benefit of a
and packing all produce on the farm. All of this infor-
traceability system is that it helps you keep track of
mation should be linked to the lot number. Please
when your produce was harvested so you can keep
see Sample SOP: Traceability for an example of how
your inventory moving and reduce loss.
to develop a lot number.
What is a Lot?
Labeling Issues
A lot is a distinct and limited portion of a crop. A lot
Most farms are not required to label each piece of
could be defined as all of the same crop harvested
produce under the Federal Food, Drug and Cosmetic
from the same field on the same day. Some farms
Act, but each farm should consider labeling each
may find this definition results in lots that are too
container that leaves the farm. This makes traceabil-
big, so they may choose to divide the harvest further,
ity of lots more efficient and effective.
thereby making several different lots. Each lot must
be assigned a unique lot number. The lot number
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Even growers who may be exempt from the Food
Safety Modernization Acts produce rule must
prominently and conspicuously display, at the point
of purchase, the name and complete business address
of the farm where the produce was grown, on a label,
poster, sign, placard, or documents delivered contem-
poraneously with the produce in the normal course
of business, or, in the case of Internet sales, in an elec-
tronic notice. This means that growers who sell at
farmers markets or have a CSA could meet this label-
ing requirement by making a simple sign with their
farm address to hang at their booth or pick up site.
Traceability System Options
Traceability options range from paper systems to
electronic ones; choose the system that works best
for you. Growers can use simple systems like grocery
store labeling guns for marking all the containers
of a particular lot. Markers and self-adhesive mail-
ing labels can also be used. Electronic traceability
systems can also be purchased but are not required.
Electronic systems often use bar code technology. As
the need for traceability grows, commercial options
may increase and become more affordable, making
bar codes a reasonable option for small farms.
Testing the Traceability System with a
Mock Recall
In a mock recall, a buyer is contacted and asked
about a particular lot number or series of lot num-
bers. The buyer should be asked how much of the lot
remains in their possession and how much has been
sold. Document the buyers response to your request
about the selected lot numbers and match it with
your farm information. If produce is sold through
direct markets, the mock recall may include devising
a way to contact a set of customers, such as through
e-mail lists or by posting signs at the direct mar-
ket stand. Collection of information could be done
through e-mail, phone calls, or the postal service. The information in the template food safety plan, SOPs, and
recordkeeping logs are examples you can use. They are not
intended to be used directly. Tailor each to fit your farm operation
and practices. These documents are guidance for risk reduction
and for educational use only. These documents are not regulatory
and are not intended to be used as audit metrics. These
documents are subject to change without notice based on the
best available science.
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Traceability Decision Tree
Is each container that is sold by your farm
No
labeled with your name, city, and state?
1 Yes
Every sellable container needs to be labeled with the farm name including city and state so
that so you can be contacted to take action if there is a food safety problem.
Is each container that is sold by your
No
farm labeled with a lot number?
2
Yes
All produce containers leaving the farm should contain a lot number.
Lot numbers should trace back to farm records that identify the crop and type, the field
where it was grown, date of harvest, date of packing (if different from harvest), address of
packinghouse (if different from farm), and the worker(s) who harvested and packed the
product.
Does the lot number identify the
No
crop and type?
3 Yes
The lot number should also identify crop information including type (e.g., tomatoes-Roma).
If you already have a lot number process in place, adding the crop and type are the next
steps to improve your traceability process.
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Traceability Decision Tree
Can the lot number identify the field
No
from which the lot was harvested?
4
Yes
The lot number should identify the specific field in which the crop was grown.
If your farm is small, the easiest way to track this information is to have a detailed field map
that you can refer to in relationship to your lot numbers.
Does the lot number identify the
No
harvest and packing date(s)?
5 Yes
The lot number should identify the harvest and packing date for each crop that is sold by
the farm.
Does the lot number identify the worker(s)
No
involved in harvesting the lot?
6
Yes The lot number should identify the workers involved in harvesting and packing.
Workers can transmit foodborne pathogens and some pathogens are only transferred by
people. In an outbreak, identifying the workers who picked and packed produce may allow
for faster identification of the cause of the illness and reduce the impact to your farm.
For small farms (10 or fewer workers), your harvest and packing paperwork can identify
all workers as part of one crew. For larger farms, it may be beneficial to break harvest and
packing into different crews to more clearly identify who was involved in harvesting and
packing specific crops on specific days.
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Traceability Decision Tree
Can your lot number be traced
No
forward to the buyer?
7
Yes
Include the lot number(s) on all invoices to customers. If you direct market, keep track of
the dates you harvest and distribute different crops including field numbers, harvest crew,
and distribution points.
In case of a quality dispute or recall, knowing the lot numbers and as much about the
crop as possible will help you respond and prevent unsold products of the same lot from
entering the marketplace.
Have you conducted a mock recall? No
8
Yes A mock recall helps you test your traceability system. In a mock recall, you contact one
of your buyers and ask about a particular lot number or series of lot numbers. Be sure
to mention that you are conducting a MOCK RECALL so they they do not think it is a
real recall. Your buyer should be able to tell you how much of the lot remains in their
possession and how much has been sold to consumers or other buyers. This information
should be documented and your production information should link to the mock recall.
If you direct market, your mock recall may include contacting a set of your customers and
asking them if they have any product remaining. This could be done through email, phone
calls, or postal mail.
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Traceability Decision Tree
Can you successfully trace produce identified in
No
the mock recall from your fields to the buyer?
9 Yes
Use this opportunity to assess weaknesses in your traceability that prevented a successful
traceback from happening. Identify what pieces of traceability are missing and implement
changes to address these weaknesses.
All products from this farm can be traced from the farm to the buyer through
our identification system. Our traceability program includes labels with the farm
name, city, and address on each sellable container. Lot numbers identify the
field, date of harvest, date of packing, packinghouse, and workers involved in harvesting
and packing. Lot numbers and date of sale are included on invoices to wholesale buyers.
We have conducted a mock recall to test the system and were able to successfully track a
lot from our fields to a buyer.
Finished
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Sample SOP: Traceability
Revision: 3.0
Date: 11/11/13
1Purpose
Describes our farms traceability system.
2Scope
Applies to all lots of produce sold by our farm.
3Responsibility
The farm food safety manager is responsible for making certain that the traceability process is
functioning on a day-to-day basis. The farm owner is responsible for responding to any problems that
the farm food safety manager is unable to resolve.
4Materials
System for labeling lots (lot numbers, labeling stickers, etc.)
System for organizing lot numbers (database, logs, etc.)
A map of the farm and fields to identify locations
Names and crew number designations (if applicable) of workers harvesting and packing
produce
5Procedure
This procedure should result in the labeling of every lot that is sold by the farm.
1. Assign each commodity with a unique lot number.
2. Collect the following information for each lot:
a. Commodity including type (e.g., romaine lettuce, roma tomatoes)
b. Farm of origin
c. Field of origin
d. Harvest date
e. Harvest crew
f. Packing house used (if any)
g. Packing date (if different than harvest date)
h. Packing crew (if different than harvest crew)
3. Create a unique lot number using our coding system to assign a code for all of the variables
listed above. Note: This sample coding system is provided as an example. Use a system of
numbers and/or letters to develop a lot coding system that makes sense to you.
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C05 009 155 02 157 01 SRCF/SRCF
Commodity Field of Harvest Harvest Packing Packing Farm/Packinghouse
type origin date Crew date crew
Code to Lot Number System
C05 = Cabbage (variety #5 = SuperStar)
009 = Field 9
02 = Harvest Crew #2
155 = June 4 (Julian Date)
157 = June 6 (Julian Date)
01 = Packing Crew #1
HCF = Happy Cabbage Farm
Initial codes, such as field of origin, harvest crew, harvest date, and commodity/type, are assigned in
the field and attached to picking totes with a card. Our farm uses the Julian calendar for its date
assignment. Additional codes are added in the packinghouse including packing date and packing
crew. The farm and packinghouse code is static because there is only one farm and one
packinghouse on the farm.
4. Label each [enter type of container to be labeled, e.g. box, carton, bin] of the lot with the
unique lot number.
5. Include lot numbers on invoices when produce is sold.
6. Keep all codes on file for two years [enter location here].
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Sample Recall Contact List
Farm Name, Address, Contact person and phone number and/or Logo
Product Withdrawal: Still under the farms control (at the warehouse, on the truck). Product has not
reached the consumer.
Product Recall: In the hands of the consumers and the consumers need to be notified.
You should have a plan to handle product traceability, recovery and disposal of affected product. This
may mean designating a field for disposal or a commercial landfill where it can be taken.
Farm Name
Name of Contact #1
Phone # (w)
Phone # (c)
Name of Contact #2
Phone # (w)
Phone # (c)
Buyer #1
Name of Contact #1
Phone # (w)
Phone # (c)
Name of Contact #2
Phone # (w)
Phone # (c)
Buyer #2
Name of Contact #1
Phone # (w)
Phone # (c)
Name of Contact #2
Phone # (w)
Phone # (c)
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Buyer #3
Name of Contact #1
Phone # (w)
Phone # (c)
Name of Contact #2
Phone # (w)
Phone # (c)
Buyer #4
Name of Contact #1
Phone # (w)
Phone # (c)
Name of Contact #2
Phone # (w)
Phone # (c)
Other Relevant Contacts
Name of Auditor
Name of Company
Phone # (w)
Phone # (c)
Other Important Contacts
Name
Phone # (w)
Phone # (c)
To view Guidance for Industry, Product Recalls, Including Removals and Corrections,
see http://www.fda.gov/Safety/Recalls/IndustryGuidance/ucm129259.htm
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Sample Mock Recall Log
Name of operation: Happy Cabbage Farm
_________________________________________ Fred
Conducted by: ______________________Date: 8-25-13
__________________
210 W. Farm Rd., Any City, NY 14456
Farm Address: ________________________________________________________________________________________________________
224-5-1-M-13, 224-5-1-A-13
Selected Lot number(s): __________________________________________________________________________________________________________
Please see the food safety plan for overall traceback procedures.
Step backward
Commodity/ Field of origin Harvest Harvest crew Packinghouse Packing crew Shipping
Lot # Packing date
Variety (#) date (# or name) address (# or name) date
224-5-1-M-13 Cabbage/Fresco Field 5 (see map) 8-12-13 Crew #1 Field packed 8-12-13 Crew #1 8-13-13
224-4-1-A-13 Cabbage/Fresco Field 4 (see map) 8-12-13 Crew #1 Field packed 8-12-13 Crew #1 8-13-13
Additional information about the selected lots: No overhead irrigation was applied and manure was last applied three years ago to these fields.
Produce was field packed and sent directly to store.
Step forward
Amount of lot remaining in
Customer contacted Date lot(s) was received Amount of lot sold Additional information
customers possession
5 bags of lot 224-5-1-M-13 All of 224-4-1-A-13
Retailer of choice 8-13-13 20 bags of lot 224-5-1-M-13
Reviewed by: ____________________________________________________ Title: _______________________________ Date: _______________________
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Template Language for
Traceability Section of a Farm Food Safety Plan
Risk Assessment
Fresh produce is labeled so it can be removed from the marketplace if it is contaminated or has some
other issue that makes it unsafe for humans to eat. Our farm has established a traceability system to
identify our produce in the marketplace so that we can recall the product if a problem is identified.
Actions to Reduce Risks
All produce harvested and packed for sale is organized into a lot system. Each lot is given a unique
number that identifies the:
Commodity, including type (e.g., Romaine lettuce)
Farm where grown
Field where grown
Harvest date
Harvest crew
Packinghouse used (if any)
Packing date (if different than harvest date)
Packing crew (if different than harvest crew)
Each [package type, e.g. box, clamshell, pallet] is labeled with the lot number. Lot numbers are
included on all invoices, so that the farm and buyers know what lots have been purchased. We use a
[paper or electronic] traceability system. All records are kept [enter location here].
In addition to lot numbers, each [invoice or container type IF you are labeling them with farm
contact information] contains the postal address, telephone number, and e-mail address for the
farm.
All wholesale buyers are listed on our Recall Contact List so they can be contacted immediately in
case of a recall or other problem. Our traceability system is tested through [add frequency here, e.g.
annual] mock recalls. During mock recalls, we call one of our buyers and ask them to trace a specific
lot number or set of lot numbers. The buyer is asked when they received the lot(s), how much of the
lot(s) remains in their possession and how much of the lot(s) has been sold. This information is
recorded on the Mock Recall record keeping sheet and kept on file [enter location here].
All logs and record keeping sheets are reviewed by management [can enter name of individual
here, if only one person] and kept on file for at least 2 years.
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