I am sure you have all heard about the various food borne illness outbreaks and the tragic results that have killed and sickened people. In every case, it takes the FDA several weeks to identify the source of the contamination and the chain of custody. To recap, we have had these issues in peanuts, tomatos, spinach and hamburger just in the last 2 to 3 years.
As an American citizen, this is infuriating. The laws addressing this issue are clear and concise, although not originally developed to address this specific issue. The law was drafted to address the intentional contamination of our food supply but the non-intended benefit is that it also will support non-intentional contamination. The Bioterrorism act of 2002 clearly outlined the types of records to retain, the length of retention and more importantly, the response time to an incident. Essentially, the rule reads that from the time a manufacturer is alerted to a potential issue, they must respond with the products genealogical records with-in 24 hours. So, when the FDA calls me and tells me they think I have a problem, I have to turn over all of the information I have related to that specific lot number which must include point of origin, raw material point of origin, manufacturing process data, etc. So, why does it take so long to identify the source and contain the problem?
As an Automation Professional, it is equally infuriating. All of the major software vendors modified their products to support this important initiative and built large marketing campaigns to advertise the features. Unfortunately, the industry response was essentially zero. I personally cannot point to a single project that was originated due to this regulation. I can also tell you that most producers I have consulted with since this act has been on the books has not followed the spirit of a mock recalls. They all maintain a separate file of information for any mock audits that come up. In fact, one client uses the same information for each audit. I guess that FDA inspector is really on top of his game.
As in all tragic situations, there are opportunities for improvement. In this case, the improvement solution is already clearly defined. There is simply not enough “justification” for producers to take the time to install this functionality in their systems. I am somewhat surprised some enterprising young lawyer has not jumped on this since these producers are conscientiously not taking the sufficient steps required by law to protect the public. The outbreaks are becoming more frequent and they are taking longer to identify the source. Statistically, that would mean we are still on the hill moving up and will probably continue to do so until the “justification” for installing these systems works. That will probably take a major legal battle but I predict it is coming. I have to believe that there are a large group of producers that have implemented the systems to follow the intent of the law.
The Automation Profession can easily solve this problem if the accountants and MBA’s would get out of our way and let us do our jobs. We have an obligation as professionals to protect the public. I wish other professions followed a similar ethical practice. The odd thing is that by implementing systems like this, overall production effectiveness would increase and would drive bottom line results. MBA’s and accountants don’t have that sort of long term view as they cannot seem to make it past there view of the world from SAP. The current state of the American and global economy is a clear picture of that.
I hope recent consumer trends maintain and that we all get a clear view of our food supply chain. I want to know where my food is coming from and make sure it is not coming from China or other country’s with relaxed consumer protection regulations. It is a shame that people must get sick and die in order for decision makers in companies to do the right thing.