This week, more than seven weeks after an outbreak of deadly E.coli bacteria was reported in certain romaine lettuce, the U.S. Food and Drug Administration has indicated that it cannot pinpoint the exact source of this outbreak, nor what caused it. Needless, to state, this development is yet another wake-up call for food-based supply chain networks to increase efforts in product traceability and visibility, but that implies a significant change management challenge.  Lettuce

The tainted lettuce has reportedly sickened 172 persons across 32 states, 45 percent of which were hospitalized, some with serious kidney ailments. The outbreak, equated to the E.coliO157:H7 strain, was the largest outbreak in the U.S. in more than ten years, and associated with romaine lettuce believed to have been gown in the Yuma Arizona region. The lettuce was sold or consumed at supermarkets, restaurants, and food outlets.

After discovery of persons getting ill from consumption of lettuce, federal heath officials urged consumers to throw away and not consume romaine lettuce. Later, health officials were able to trace product contamination to the Yuma Arizona growing region but have been unable to pinpoint the exact farm sources. Any remaining romaine was destroyed or plowed-under by farmers due to the nationwide product recall.

Costs of the recall are expected to be in the millions for all participants in this specific food supply chain. According to various media reports, it could take months before sales of romaine or other lettuce recovers from the past incident. The U.S. Department of Agriculture indicates that prices for whole romaine heads have declined as much as 60 percent since early April. According to Nielsen POS data, sales have declined 45 percent from year-ago periods. Restaurant chains and food establishments are facing lawsuits from patrons contending that proper safeguards were not taken in removing recalled lettuce from kitchen stores.

In an update yesterday, FDA Commissioner Scott Gottlieb confirmed that investigators were not able to trace the tainted lettuce completely through the supply chain to a particular farm, processor, or distributor, primarily because the growing season has since been completed, and consumers consumed mixed lettuce varieties. Further indicated was that the FDA will consider improvements in its capabilities to trace the source of future outbreaks.

The latter is where actions to improve supply chain traceability become a conflict in stakeholder interests.

The FDA made available a specific traceback diagram that works backward from the point of consumption or purchase through the various tiers of the romaine supply chain. Upon glancing this diagram, reproduced below, readers can determine the complexity of handoffs in the overall supply chain. FDA investigators seek out what they term as points of convergence in illness, consumption, retail distribution and farm sourcing through the tiers of the supply chain. Admittedly, not a simple task, one that can take a lot of time to map out.

FDA Romanine Traceback Diagram

 

The Food Safety Modernization Act of 2011 provides for a Produce Safety Rule, designed to foster practical measures to prevent contamination of fruit and produce. This rule implies close collaboration among different federal agencies as well as industry groups. Seven years since, the Rule has yet to be acted upon.

Readers may recall the prior 2015  E.coli outbreak associated with food served at specific Chipotle Mexican Food restaurants. Federal agencies were unable to trace the specific source or cause in that outbreak, and the restaurant chain has since had to deal with the fallout of once loyal patrons.

The FDA now indicates that the agency wants to explore the use of improved product packaging that could enhance traceability such as QR codes. Retailers such as Walmart, are calling for the application of blockchain technology as a means to trace each handoff in the food supply chain. The above diagram would likely be an available end-result of such a distributed ledger, and depending on implementation, could begin at the farm source. Creation of the chain of custody can conceivably be a real-time display.

On the other stakeholder spectrum is  a coalition of termed food industry and consumer groups calling for less high-tech approaches, no doubt concerned about the added cost burdens of advanced technology approaches such as blockchain. The FDA desires mandatory record-keeping for “high-risk” foods such as lettuce or other produce.

Solving the Conundrum

Thus, is the current conundrum.

Incidents of food contamination involving high-risks foods continue causing various degrees of illness and death. Federal agencies use all available methods and tools to try to trace sources of contamination, but such methods take considerable time and resources to complete. Too often, the incidents of contamination exposure continue during the investigative period, exposing added others to sickness.

New technologies such as blockchain are becoming available, that can make supply chain multi-tiered traceability nearly real-time, but such approaches spark fears of added costs, lower profits and too much visibility to supply chain participants. Let’s not forget the political environment in Washington where industry lobbyists yield considerable influence.

From our Supply Chain Matters lens, solving this conundrum of assuring food safety and traceability is not gated by technology. There are many technologies, advanced and otherwise mainstream, that can be deployed in a phased milestone program.

Instead, the challenge of solving food safety and traceability requires the alignment of industry, consumer and retailer stakeholder interests. It is a complex change management problem that requires bold leadership and a bias for action.

The question remains as to which stakeholder will take the ball.

Bob Ferrari

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