Despite all the hype, the traceability clauses in the new European General Food Law barely raised an industry eyebrow when they hit UK statute books this January, and software companies hoping to cash in as companies rushed to bring their systems up to scratch were instead left scratching their heads, admits Baxter.
So why the damp squib?
Part of the reason is that the legislation makes deceptively simple demands, he suggests. Forget batch segregation and linking incoming raw materials and outgoing finished products; regulation 178/2002 simply stipulates that food companies must be able to identify where they got their products from and who they sold them to, so-called 'one up one down' traceability.
It's not rocket science, and as a result, many companies have barely given it a second glance.
As Geest procurement development manager David Barney points out: "Legislation is the least of our worries. What's driving traceability are retailer requirements and the need for food safety, plant efficiency and food assurance."
That's as may be, says Baxter, but there are two words in article 18 of the General Food Law that many suppliers appear to have overlooked. Traceability information must be made available to competent authorities 'on demand'. And if that means within four hours, as is stipulated in the US bioterrorism laws, then companies without decent electronic traceability systems could be in serious trouble, as the Sudan 1 recall recently demonstrated.
We all heard about how Marks & Spencer identified 95% of products affected by Premier Foods' rogue batch of Worcester sauce in 30 minutes, or how Asda put an immediate block on barcodes of affected products, says one UK regulatory source.
What we didn't hear about were the traders further up the chain that had to frantically rifle through piles of papers in dusty store cupboards in the vain hope of finding the invoice that would tell them who they bought a particular batch of chilli powder from two years ago, he points out.
"We are not talking four hours, we're talking four weeks. And that was just the stuff that went through the books. Cash transactions don't lend themselves to great traceability."
The warning signs were already there. As the European Commission's standing committee on the food chain and animal health pointed out in guidance notes on how to interpret the new regulations back in December: "Food crises in the past have shown that tracing the commercial flow of a product [through invoices] is not sufficient to follow the physical flow of the products."
Likewise, the Food Standards Agency's food chain strategy division report on traceability back in March 2002 drew particular attention to the threat to traceability posed by the brokerage system, whereby goods are traded several times before reaching the end customer and documentation is passed along the chain between people that have never seen the goods in question.
A major study into traceability in the UK food industry commissioned by the Department for Trade and Industry last year suggests that there is little room for complacency, says Vincent Tombros, who led a study team of experts from business and technology consultancy Lysis, Brunel University and Campden & Chorleywood Food Research Association.
While most large UK firms have reasonable traceability systems in place, he claims: "Significant black holes were identified in many cases where UK companies used non-UK suppliers, especially those from outside the European Union. And we are not talking about a handful of small companies here, but of hundreds of firms with turnovers of £10m-250m."
If the problem of illegal dyes entering the food chain is arguably less about traceability than the efficacy of the supplier auditing and the testing and certification regime in the spice chain, it does raise some interesting questions about whether 'one up one down' is really enough, agreed manufacturers attending a recent roundtable discussion hosted by Air Products.
The event was subject to Chatham House rules, which means Food Manufacture can report what was said, but cannot quote individuals by name.
Not surprisingly, much of the discussion focused on whether terms such as 'trusted supplier', 'hazard and analysis critical control points-based systems' or 'certified Sudan-free' are being bandied around rather too liberally in the trade.
Unbelievably, one company known to one of the participants had helpfully written: 'Sudan 1 has not knowingly been added to this product' on his goods, he said. "You'd be amazed by the misconceptions about what constitutes due diligence. Taking all reasonable precautions is translated as, 'we did our best'. Unfortunately, the courts don't see it that way. Take the Denby case [where meat unfit for human consumption entered the food chain]. It came from 'an approved cutting plant'. But what does that actually mean? You can't take anything for granted."
Problems often arise when a new supplier is used on an ad hoc basis in order to meet a sudden hike in demand, and there isn't time to make all the necessary checks as to the provenance of the products, he added.
As to what manufacturers should be working towards, retailer requirements are typically far stricter than legal ones, said one large chilled food manufacturer present. "When Asda did an audit with us, they picked out one ingredient and wanted to know exactly how many products it was used in, which batches, and exactly where they had gone -- in four hours."
While internal traceability can reduce costs and limit damage through more targeted recalls, it can also play a greater role in prevention as well as cure, says Ross Systems' Baxter. "A process can cause a problem as well as an ingredient." If manufacturers link traceability and enterprise resource planning systems to process control systems on the factory floor, they can stop faulty products entering the supply chain in the first place, he adds. "If an alert goes out that the temperature of a pasteurizer has dropped too low, your systems should be able to identify exactly which products have been affected before they leave the factory."
There is a tendency in the industry to record information for subsequent analysis rather than using it in real time for prevention rather than cure, suggests Siemens manufacturing execution systems UK manager Matt Holland. "But just sending out alerts is no good either. It has to be actionable. So the temperature in machine X is 10°C. What does that mean? Which orders have been affected?"
If you have to issue a recall, it should be possible to target it far more systematically if you have the right traceability systems, says Carsten Sorensen, systems and applications manager at coding and marking solutions specialist Imaje UK. "Say you have three separate batches of meat going into one batch of finished product. Companies now want to be able to target recalls to material batch level if at all possible."
Similarly, if you have a system that generates alerts if the time certain raw materials are in transit exceeds a pre-set boundary, you should link this to your autocoding system and automatically remove a day of shelf life, ensuring quality and avoiding issues further down the line, he says.
It is often in the course of implementing a traceability system that companies realise that their processes need revisiting, says Lawrence Hutter, head of the consumer business division at Deloitte. Take rework, he says. As US meat processor Hudson Meats found out to its cost in 1997, re-using off cuts of meat from one batch in the next is all very well until you get an E. coli scare and end up recalling one billion hamburgers because you have lost the link between batches of raw materials and finished product.
Better batch control frequently pays for itself through improving stock rotation and reducing wastage, he claims. "We've been working with a number of UK food manufacturers on this over the last year and there really is a business case."
However, the real question any technical manager should put to a sceptical board is not whether they can afford to pay for a new traceability system, but whether they can afford not to, argues Diageo's former European track and trace programme director John Davidson.
Good systems aren't cheap, points out Davidson, now md of traceability and quality management consultant Carsebreck. But neither is rebuilding a shattered reputation or winning back lost market share if things go disastrously wrong.FM
EU General Food Law 178/2002
Article 14 -- Prohibits food from being placed on the market if it is unsafe
Article 18 -- Places obligation on food businesses to keep records of their suppliers and businesses they supply to and make such records available to competent authorities on demand
Article 19 -- Places obligations on food businesses to recall food from the market if it is not in compliance with food safety requirements and to notify competent authorities