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Well another recall from a major producer, Michael Foods, Inc., was announced this month. Michael Foods is a $2B processor of mainly egg products. This recall has some interesting side notes.

1. They use  a lot # identifier that is not a contiguous number thereby forcing them to increase the recall scope.
2. Inside industry sources have told me that a very large Food Service Retailer that uses their products in their breakfast menu was so concerned about the recall that they are seriously considering instituting their own Food Safety standards for their vendors to comply with so they can prevent these recalls in the future.

Well guys #2 is real bad because no only do you have FDA,USDA,and SQF standards to comply with, major Food Service retailers that create their own standards will play another tune you'll have to dance to.

TRACEABILITY AND RECALL: DO IT NOW OR PAY LATER, MAYBE WITH YOUR BUSINESS !!!!!

Let's take a look at the recent recall information From FDA

"February 1, 2012 -Michael Foods, Inc. is recalling specific lot dates of hard-cooked eggs in brine sold in 10- and 25-pound pails for institutional use that were produced at its Wakefield, Nebraska facility because the product has the potential to be contaminated with Listeria monocytogenes...The recalled eggs were purchased by food distributors and manufacturers located in 34 states...The recall was initiated after lab testing revealed that some of the eggs within the recalled lot dates may have been contaminated with Listeria monocytogenes.  A recall of three lot dates was announced on Thursday, January 26.  As a precautionary measure, the recall was expanded today to include additional lot dates...Michael Foods reached the decision to expand this recall after a thorough investigation which indicated a specific repair project that took place in the packaging room as the likely source of the contamination."

Now let's take a moment to break down the good the bad and the ugly.

• The Good: The packaging includes a lot number, line number and facility identifier.  This is the absolute minimum for any production facility.
• The Bad: The lot number, line number and facility identifier appear to be separate pieces of information and include an alphanumeric character (the letter W).  Breaking these data elements out instead of incorporating them into the lot number makes recalls far more difficult.
• The Ugly: Most distributors I work with that have implemented traceability utilize the manufacturer lot number as the unique identifier for the product batch.  In the example above it appears that Michael Foods might have multiple identical lot numbers for the same product item ID.  Their Instruction that only  'Only lot codes immediately preceded by a “1” AND ending in a “W” are affected' indicates to me that if a distributor were unlucky enough to be recording only the lot number he might be forced to call his customer and ask them to check whether the printed code on the packaging had the lot preceded by a "1'.

A solution:

Whenever possible a lot number should contain all the data elements needed to effect a recall of product.  Depending on the production policy of the manufacturer this can often be accomplished by including the Julian date of the recall indicator the company uses (production date, use by date, expiration date, etc.), production line indicator, and facility indicator within the lot number rather than breaking those fields out individually.  In the example above this would result in a 11 digit lot number (assuming they have fewer than 100 lines at fewer than 100 facilities).  This is well within the up to 20 digit limit given to lot numbers in the standard GS1-128 bar code.

By making this small change manufacturers enable proactive distributors to enact near instantaneous system based recalls, rather than force time consuming box checking.  Let's hope the FDA page didn't show the whole story and that Michael Foods is including this information in scannable form already, otherwise there's going to be a lot of stock searching going on.