TRACEABILITY AND RECALL
Traceability and recall: a brief introduction
Traceability is one of the cornerstones of food safety. It involves tracking a food product across the entire chain, from origin to distribution, through record-keeping. The reason is simple: if an issue arises that could put public health at risk, the company must be able to quickly identify where the deviation occurred (and which products may be involved) in order to correct it and prevent it from happening again.
Types of traceability
Generally speaking, traceability is addressed in two directions:
Backward (upstream) traceability: makes it possible to identify the raw materials that make up the product, packaging, inputs, transportation conditions, and suppliers.
Forward (downstream) traceability: makes it possible to identify where the product was distributed or marketed (customers, destinations, channels, and geographic areas).
In practice, traceability is managed by batches, because foods are produced and released in groups. A robust system will be based on well-defined batches and consistent records.
What is a recall?
A recall is the withdrawal of foods or products from the market when they are not safe or when they present non-compliances that may affect the consumer: contamination, adulteration, counterfeiting, labeling errors, or regulatory non-compliances. Depending on the case, a recall may also involve condemning the product to prevent it from reaching consumers.
Why traceability and recall go hand in hand
There is no effective recall without traceability. To withdraw a product quickly and accurately, records must be clear, complete, and well organized. These records must detail the following:
animals or raw materials of origin,
ingredients and inputs,
packages and materials in contact with foods,
food additives and processing aids,
products used throughout the production chain.
In addition, records should specifically include origin, receipt date, quantity, the health certificate or supporting document, the assigned batch number, controls and processes performed, and the destination of the items listed above (depending on what is relevant in each case).
Link with the HACCP system
This system is directly linked to the HACCP system: when an incident occurs, HACCP provides the framework to assess where a deviation may have happened within the chain and which controls failed or need to be strengthened. It enables fast and effective traceability.
Given its importance (food quality and safety were declared a matter of national interest under Argentina’s Law 27233), every food-producing establishment must have a written traceability and recall procedure, with clearly defined responsibilities, standardized records, and a clear circuit of actions.
Recall procedure in Argentina: a summary
Possible causes for a recall
Reports from different sectors of the community (consumers, governmental and non-governmental organizations, healthcare professionals, food businesses, etc.).
Actions initiated by INAL/SENASA or the provincial/municipal health authority.
Information about an international incident involving a country that exports foods to Argentina.
An adverse result from an official sample collected during a routine inspection.
Recall management
In general terms, recall management considers:
1) Scope of withdrawal: distribution level (wholesale, retail, consumer) and geographic scope (broad or limited).
2) Public communication: where applicable, scope, speed and channels are defined based on the assessed risk and the distribution level.
3) Effectiveness verification: the company monitors implementation (product seizure, recovery, and placing at the disposal of the competent authority).
4) Disposition/destination of recovered product: the competent health authority assesses and authorizes product disposition or destination, as applicable.
5) Risk assessment: considers health consequences and the size/profile of the potentially exposed population.
6) Recall classification:
Class I: reasonable probability of severe adverse health consequences or death. Requires maximum urgency and recovery, including units in the hands of consumers.
Class II: reasonable probability of temporary and/or reversible adverse health consequences.
Class III: low probability of adverse health consequences, but it constitutes a regulatory violation.
7) Recall strategy: designed based on risk, scope, and classification.
Stages of the procedure
The procedure includes the following stages:
1) Recall initiation: incident detection, risk assessment, decision to recall, and notification to the competent health authority, the food business, and consumers.
2) Classification and strategy: the authority conducts risk assessment, classifies the recall, and defines or evaluates the strategy.
3) Notification and alert: each initiated recall is assigned a six-digit identification number; the first four digits are sequential numbers and the last two (separated by a hyphen) indicate the year. This allows the incident to be identified across all jurisdictions. This stage also includes public communication.
4) Monitoring and auditing: the food business is responsible for monitoring progress and measuring effectiveness. The health authority audits the procedure.
How should it be audited?
For Class I and Class II recalls, visits must be conducted to those who should have been notified. If visits cannot be carried out, they may be replaced with phone calls. For Class III recalls, audit verification is not required.
What is verified?
Method and date of customer notification regarding product recall by the food business.
Whether the customer followed the instructions provided.
Where necessary, whether the customer informed its subcustomers about product recall and the actions to be taken.
5) Closure: the incident is closed once all feasible actions to ensure product withdrawal from the market have been exhausted. A summary of actions taken, units recovered, product disposition, and other relevant details is communicated to the parties involved.
WHY IS ITS ACCURATE TRANSLATION IMPORTANT?
A robust traceability record is the foundation of an effective recall procedure, especially in incidents that pose a risk to the population. As with an HACCP plan, a written traceability and recall procedure is evidence of control, accountability, and response capability. In demanding markets, that level of seriousness is paramount.
Translating this document into Spanish carries significant responsibility, because it involves a procedure that may be activated in a critical scenario. Agribusinesses and food companies present a traceability example to demonstrate the records they keep at every step and their ability to identify the point at which the product deviated. There can be no room for doubt about what is done, when it is done, who does it, and how it is documented.
Tell me in the comments below: what concerns you most when a document of this nature and importance has to be delivered in Spanish?
Some related English-Spanish terminology
Incidente alimentario: food (safety) incident
Alimento contaminado: contaminated food
Alimento adulterado: adulterated food
Alimento falsificado: counterfeited food
Alimento alterado: altered food
Alimento no inocuo: unsafe food
Retiro de alimentos del mercado: recall
Trazabilidad: traceability
Trazabilidad ascendente: backward traceability
Trazabilidad descendente: forward traceability
Lote: batch
Empresa Alimentaria (EA): Food Business (FB)
Operador de Empresa Alimentaria (OEA): Food Business Operator (FBO)