Food is a dynamic substance which changes with time and through exposure to different temperatures, storage conditions and processing methods.
- Food safety is a scientific discipline describing the production, harvesting, handling, processing, preparation and storage of food in ways that prevent foodborne illness. This includes a number of procedures and practices that should be followed to avoid potentially severe health hazards. Food can transmit disease to humans as well as serve as a growth medium for bacteria that can cause food poisoning.
- Traceability gives the ability to identify the past or current location of a food item, as well as to know the item’s history. To achieve traceability, a producer and other supply chain participants must be able to link the physical flow of materials and products with information about locations, parties, processes and conditions. Traceability of food products is driven by food safety requirements and consumer concerns about where the food they eat comes from and how it was produced.
Some notes on traceability
Traceability helps to identify the source of products and their ingredients, to identify the processes conducted, to assure compliance with food safety standards, and to affirm the authenticity of a product and claims made about it. When something goes wrong, the information recorded for traceability purposes can help to locate and prevent further distribution of products that may be affected, and if necessary support withdrawals.
Implementing traceability requires supply chain participants to link the physical flow of materials and products with information about locations, parties and processes. This requires each party to keep “vital records”. “Vital records” are the minimum records required to achieve a particular outcome.
The following actions are required in order to achieve traceability:
- Identify and record the food and its components
- Identify and record relevant locations and parties
- Identify and record treatments and processes
- Record movements of products, one-step-back and one-step-forwards, in other words – what exactly was received from whom, and what exactly was sent to whom
- Record changes of constitution of products, such as breaking or building a pallet
- Record transformations of products, for example on-site processing
- Link the inputs to the outputs, taking account of constitutional changes and transformations
- When needed, recreate what happened from records,
- View across the whole supply chain (which is the greatest challenge)
Typical uses for traceability:
- provides a foundation for vital data records
- determines the origin of a product
- gives evidence of compliance to requirements of regulations, agreements and standards
- authenticates claims made about a product, such as “Organic” and “Fairtrade”
- satisfies consumer demands for information on production conditions
- reports on, locates and manages products that might have a problem.
Traceability vital records enable us to recreate the production, processing and distribution of a food or feed product, and associate a specific product with others that shared its experiences or which it met in its journey on and from farm to fork. Traceability systems enable this to happen quickly and efficiently.
The details to be recorded would depend on the reason for having traceability – food safety data requirements and records would differ from those for organic products, fair trade and carbon footprint. However, all could apply to the same product across its production and supply chains.
A “traceability system” is defined as the totality of data and operations that is capable of maintaining desired information about a product and its components through all or part of its production and utilisation chain (ISO22005:2007; SANS22005:2009).
Source: Gwynne Foster of Interlinks Traceability Services
International business environment
If we wish to be internationally competitive, exporters of food and beverages must be aware of and implement the numerous protocols, systems and standards which include:
- Find the standard documents on www.globalgap.org
- The GLOBALG.A.P. standard is primarily designed to reassure consumers about how food is produced on the farm by minimising detrimental environmental impacts of farming operations, reducing the use of chemical inputs and ensuring a responsible approach to worker health and safety as well as animal welfare.
- Find guidelines on www.fao.org
- HACCP is a food safety management system that is based on proactivity and prevention, and is therefore seen as the management of product safety to prevent food poisoning incidents. It can be used to ensure quality, and goes a long way to ensuring food safety.
- There are control points – and critical control points (CCP). The CCP is any point at which a hazard can be prevented, reduced or eliminated in a food process.
- Find these documents on www.codexalimentarius.org
- This is a collection of international set of standards, guidelines and codes of practice. Each country has the right to set stricter standards and/or regulations than Codex guidelines, under the WTO SPS agreement, provided that that country can scientifically prove why their regulations are stricter (otherwise these can be seen as an artificial barrier to trade).
- These food standards aim to protect consumer’s health and ensure fair practices in the food trade. The Codex Alimentarius includes standards for all the principle foods, whether processed, semi-processed or raw, for distribution to the consumer.
The Food Safety System Certification (FSSC) is a voluntary certification based on ISO standards and is recognized by the Global Food Safety Initiative (GFSI). The certificate affirms that the inspected production facilities of global food companies meet the food safety requirements of its customers. See www.fssc22000.com.
- Find out more at www.gs1za.org
- The GSI Standards identify locations, trade items and logistics units. The GS1 South Africa User Manual, the Global User Manual and the GS1 General Specifications can be ordered from GS1 South Africa.
ISO 22000 is a Food Safety Management System that can be applied to any organisation in the food chain, farm to fork. Becoming certified to ISO 22000 allows a company to show their customers that they have a food safety management system in place. ISO 22 000 was modified in July 2018 to reflect new food safety challenges. Find more at www.iso.org/iso-22000-food-safety-management.html.
This is a Global Food Safety Initiative (GFSI)-benchmarked certification programme recognised worldwide. The Safe Quality Foods Institute (SQFI) (USA) manages the SQF standard. See www.sqfi.com.
Find the different GFSI documents at https://mygfsi.com.
Some international websites
- African Accreditation Cooperation (AFRAC), www.intra-afrac.com
- www.brc.org.uk – British Retail Consortium, “for successful and responsible retailing”
- www.colead.link – promoting sustainable horticultural trade in African, Caribbean and Pacific countries, especially with the EU (which includes helping producers with EU food safety standards).
- The Consumer Goods Forum (CGF) www.theconsumergoodsforum.com
- The role of EFSA (European Food Safety Authority) is to assess and communicate on all risks associated with the food chain. See www.efsa.europa.eu.
- The European Commission DG Health and Food Safety audits compliance to food safety issues. Find their information on https://ec.europa.eu/food/index_en.
- Find European Union Rapid Alert System for Food and Feed (RASFF) pages at https://ec.europa.eu/food/safety/rasff_en.
- Find Guideline for the Conduct of Food Safety Assessment of Foods Derived from Recombinant-DNA Plants at www.fao.org/input/download/standards/10021/CXG_045e.pdf
- Food Marketing Institute (FMI) (USA) www.fmi.org
- GLOBAL DIALOGUE on Seafood Traceability https://traceability-dialogue.org/
- Global Food Safety Initiative (GFSI) www.mygfsi.com
- Global Pest Management Coalition (GPMC) www.pestmanagementcoalition.org
- www.identigen.com – This company, active in Europe and North America, uses a DNA-based system for accurate traceability back to the farm where the animals were raised.
- International Association for Food Protection – www.foodprotection.org. The affiliate directory gives details of role players worldwide.
- International Commission on Microbiological Specifications for Foods (ICMSF) – www.icmsf.iit.edu
- International Committee on Animal Recording (ICAR) www.icar.org
- The International Food Safety Authorities Network (INFOSAN) is a joint initiative between the UN’s World Health Organisation and Food and Agriculture’s Organisation. See www.fao.org/food-safety/emergencies/infosan/en/
- International Life Sciences Institute (ILSA) http://ilsi.org
- World Organisation for Animal Health (Organizacion Mundial de Sanidad Animal) – www.oie.int Food safety is an important theme.
- Safe Food Alliance (USA) https://safefoodalliance.com
- www.fsis.usda.gov – the USA Department of Agriculture’s Food Safety and Inspection Service
- www.who.int – the UN’s World Health Organisation. Find the “Food safety” pages.
- The World Trade Organisation (WTO) Sanitary and Phytosanitary (SPS) Agreement allows countries to stop imports in order to protect human, animal and plant life or health. Find the “Sanitary and phytosanitary measures” menu option on www.wto.org.
The World Health Organization’s five keys to food safety :
- Keep clean. Wash your hands before handling food and often during food preparation.
- Separate raw and cooked food. If you are handling or storing raw food, do not touch already cooked food unless you have already washed your hands and food preparation utensils.
- Cook food thoroughly. Food that does not usually need cooking before eating should be washed thoroughly with clean running water.
- Keep food at safe temperatures.
- Use safe water for domestic use at all times or boil before use.
Local business environment
Read about Food Business Operators under the “National strategy and Government contacts” heading.
In order to meet the requirements of the EU regulations, South Africa promulgated “Standards Regarding Food Hygiene and Food Safety of Regulated Agricultural Food Products of Plant Origin for Export”. These are collectively referred to as SA-GAP. SA-GAP is often used as the basic standard for inspections of produce destined for the local market.
SA-GAP standards require that food products are handled under hygienic conditions through all stages of the supply chain, good record keeping, and that Food Business Operators (FBOs) are able to withdraw or recall products that pose a risk to human health from anywhere in the trade chain.
- The reader can pick up the links and standards from either the “Old” DALRRD website, www.dalrrd.gov.za (find the “Food Safety & Quality Assurance” pages) or the Perishable Products Export Control Board (PPECB) one, www.ppecb.com. The reader will find it valuable to contrast this with the G.A.P. programmes at www.globalgap.org
Listeriosis is a disease caused by a bacterium, not a virus. You get it when you ingest food contaminated with this bacterium. Listeriosis is widely found in nature – in soil, water, vegetation or faeces of some animals. From these sources, it can contaminate food from four different areas.
- The food production site – that is the farms and the abattoirs
- The food processing factories
- The food packaging sites
- The food preparation at restaurant hotels or in individual homes.
The disease occurs annually in South Africa, with doctors typically seeing 60 to 80 patients per annum. This has been the case for the past 40 years. (The 2017/18 outbreak, traced to a processed food facility and which led to over a thousand cases, was a tragic exception). The disease is treatable with an antibiotic called ampicillin which is widely available in health facilities, both public and private.
Source: A speech by then Health Minister Aaron Motsoaledi as reported in SANews, 8 March 2018 (adapted).
Genetically modified (GM) products
South African regulations state foodstuffs containing more than 5% of GM organisms should be labelled “contains genetically modified organisms”, whether or not they originate in the country. GM opponents say that the law has been “flouted” since it was passed in 2011 (tests carried out by the African Centre for Biosafety found GM ingredients in maize meal and baby cereal without the called-for labels on the products). Business disputes the interpretation of the regulations, and so the country has a stalemate at present.
- Find the Cliffe Dekker Hofmeyr discussion on GMOs and the Consumer Protection Act at www.cliffedekkerhofmeyr.com/export/sites/cdh/en/news/publications/2014/consumer-protection/downloads/Consumer-Protection-Act-Alert-12-March-2014.pdf
- The World Health Organisation has a page on genetically modified food.
- Find notes at www.saconsumercomplaints.co.za.
The attention given to exports had not always extended to produce destined for the local market. The Consumer Protection Act (CPA) changed this.
The CPA flipped accountability for quality and safety of produce from the “buyer-beware” principle to the legal assumption that the supplier is responsible until and unless there is evidence to show that is not the case. This had the unintended consequence that mature local retailers, processors and supply chain parties now require suppliers to provide evidence, through certification, that they comply with good practice standards. This has caused a backwash up the supply chain to producers; most affected are the emerging sector.
A problems of this legislation is that emerging farmers, struggling with the administrative and bookkeeping demands of food safety, could be shut out of the supply chain.
Source: Gwynne Foster of Interlinks Traceability Services
National strategy and government contact
The South African government has created a regulatory framework and related instruments for food safety and traceability. The Department of Health (DoH) and Department of Agriculture, Land Reform and Rural Development (DALRRD) have responsibilities relating to safety of food locally and with regard to meeting requirements of international markets.
DALRRD Inspection Services ensures compliance with phytosanitary agreements. Government assignees assure compliance of products in different sectors, e.g. the Perishable Products Export Control Board (PPECB) is responsible for assuring that exports of fresh and processed products of plant origin meet the requirements of the South African Agricultural Products Standards Act [Act 119 of 1990]. Similarly, the South African Bureau of Standards assures that fish products comply with regulations, and the Wine & Spirits Board assures compliance of wine and spirits processes and products.
The Meat Safety Act, 2000 (Act 40 of 2000) provides for measures to promote meat safety and the safety of animal products; establishes and maintains essential national standards in respect of abattoirs; regulates the import and export of meat; and establishes meat safety schemes.
The national FS & MRL (Food Safety and Maximum Residue Levels) is chaired by the DALRRD Directorate: Food Safety and Quality Assurance. The Forum publishes hazard profiles, and food safety checklists and compliance criteria for different types of food business operators. Separate operating procedures and guidelines may be provided, e.g. for residue sampling and traceability. PPECB inspectors use the checklists during food safety export compliance audits. A Food Safety Forum Technical Working Group updates the documents from time to time. Further documents are under review or in the process of being prepared. The documents are available under the food safety section on the DALRRD website: www.dalrrd.gov.za. This is SA GAP.
Companies handling products of plant origin that are destined for export markets are required to register with DALRRD as Food Business Operators. Producers who supply local fresh produce markets will in future also register as Food Business Operators (FBO). An FBO must adhere to good handling practices and traceability, keep adequate records and be able to withdraw implicated products from the market should there be a serious problem. An approach to responding to product alerts, withdrawals and recalls is provided in the Traceability Standard Operating Guideline published on the website of the DALRRD, www.dalrrd.gov.za. The FBO code database is available under the “Food Safety and Quality Assurance” option on the same website.
Larger South African retailers are adopting international trade standards or/and defining their own standards. This has a domino effect back up the fresh produce chain, and producers and processors who are unable to provide evidence of adhering to good practices may be locked out of storage and processing facilities. The ability to show evidence of due diligence and compliance with a standard would depend on the records available about a specific product or process at each point in the chain.
Source: Gwynne Foster of Interlinks Traceability Services
|In addition to the above, other relevant legislation includes:
There are Food Control Committees in every province consisting of provincial Departments of Agriculture, Health, Municipal Health Services and the South African Police Service Stock Theft Unit. Those Committees conducted joint inspections of food premises, combatted illegal slaughtering and undertook road blocks to search food delivery vehicles for compliance.
Department of Agriculture, Land Reform and Rural Development (DALRRD)
Find information on directorates at www.dalrrd.gov.za.
- The Directorate: Food Safety and Quality Assurance
- Directorate: Plant Health
- Directorate: Inspection Services
- Directorate: Animal Health
- Directorate: Veterinary Public Health
- Directorate: Food Import and Export Standards
- Directorate Marketing – The “Market Requirements and Guidelines” option includes information on GLOBAL G.A.P.
Perishable Products Export Control Board (PPECB) www.ppecb.com
PPECB was mandated under the Agricultural Products Standards Act (Act 119 of 1990) to ensure compliance with the food safety standard by conducting food safety audits on all registered FBO’s (Food Business Operators). Assessors are stationed across the country and delivers inspection services on 200 product types at more that 1500 locations. PPECB also audits the use of legislated pesticides on a regular basis, according to an MRL Standard Operating Procedure. This forms part of the risk based approach of the total PPECB mandated function.
Department of Health (DoH)
- Programme: Food Control www.health.gov.za
- National Codex Office The Food Legislation Advisory Group (FLAG) consists of government departments, industry, academia, research institutions and consumer organisations to provide scientific advice on the development of legislation in food safety.
South African Bureau of Standards (SABS) Food and Beverages www.sabs.co.za
Food-related standards include: (i) SANS 241-2, SANS241-1: 1 Drinking water Part 1: Microbiological, physical, aesthetic and chemical determinants and SANS 241-2: Drinking water Part 2: Application of SANS 241-1. (ii) SANS 10049 – Food safety management — Requirements for prerequisite programmes (PRPs). (iii) SANS 10330 – Requirements for a Hazard Analysis and Critical Control Point (HACCP) system (Intermediate Level). (iv) SANS 289 – Labelling requirements for pre-packed products.
National Regulator for Compulsory Specification (NRCS) Food and Associated Industries www.nrcs.org.za
See the “Laboratories and agriculture” page.
Training and research
- Some agricultural colleges/Provincial Departments of Agriculture provide short courses on health and Food Safety e.g. the KwaZulu-Natal Department of Agriculture and Rural Development, who can be contacted at 033 355 9444/5. Find details on the “Agricultural education and training” page.
- Find South African Qualifications Authority (SAQA)-accredited qualifications like “Apply basic food safety practices”, and “Operate and support a food safety and quality management system in the agricultural supply chain” on the SAQA website, www.saqa.org.za.
Websites and publications
Visit the websites listed earlier in this page.
- Various guidelines and checklists are available from the CGCSA, like (i) CGCSA – GFSI GMP General Guidelines (ii) CGCSA – GFSI GMP User Guidelines V1 (iii) GFSI Global Markets Manufacturing Checklist (iv) GFSI – Food Safety Auditor Competencies Edition 1 (v) GFSI Global Markets Toolkit V2 (vi) GFSI Guidance Document.
- Find the Traceability Reference Book and many other publications at www.gs1.org.
- Find SA-GAP Certification Programme for Smallholder Producers of Fresh Produce on the internet.
- Find the draft Livestock Identification and Traceability System South Africa (LITS SA) at www.greengazette.co.za/notices/draft-livestock-identification-and-traceability-system-in-south-africa-lits-sa-invitation-for-public-to-comment-on-the-revised-draft-livestock-identification-and-traceability-system_20180213-GGN-41440-00108.pdf
- The Pork Best Farming Practice website, http://porkbfp.co.za, include guidelines on traceability.
- Find the different food safety Info Paks like “Our Meat is safe” and “Food preparation and home food safety” at www.dalrrd.gov.za.
- The Traceability Reference Book 2021 by GS1 provides some global stories of traceability. See www.gs1.org/standards/traceability/case-study-library/traceability-reference-book
- Find what Bayer says about Glyphosate at www.bayer.com/en/glyphosate-roundup.aspx. and www.glyphosatelitigationfacts.com/main/.
- Find the “How safe is the food on your plate?” at RM (Research Matters), a University of Pretoria website.
Food safety is frequently covered in the articles on the Food Stuff South Africa website, www.foodstuffsa.co.za.
- Find our blogs “How does food get contaminated? The unsafe habits that kill more than 400,000 people a year” (May 2023), “From Farm to Fork: Why Traceability is Key to a Sustainable Future in South African Agriculture” (April 2023) and “Sustainability, Traceability & the Future of Farming” (July 2021)
- Papadopoulos A. & Cornelius C. 2023, June 23. “Proposed new draft labelling regulations – R3337”. GoLegal. Available at www.golegal.co.za/draft-labelling-regulations/
- Cronje J. 2023, June 20. “Product labelling in South Africa: Little margarine for error”. GoLegal. Available at www.golegal.co.za/product-label-butter/
- McCarthy D. 2023, June 23. “AI could democratise nutritional advice, but safety and accuracy must come first”. The Conversation. Available at https://theconversation.com/ai-could-democratise-nutritional-advice-but-safety-and-accuracy-must-come-first-206728
- Reporter. 2023, May 24. “SA consumers called to comment on draft food labelling regulations”. Bizcommunity. Available at www.bizcommunity.com/Article/196/307/238677.html
- Sabinet. 2023, April 17. “South Africa’s Agricultural Product Standards Amendment Bill”. Go Legal. Available at www.golegal.co.za/agricultural-product-legislation/
- Dlamini T. 2021, December 9. “South African Bureau of Standards calls for food safety management after a spate of food recalls”. Daily News. Available at www.iol.co.za/dailynews/news/kwazulu-natal/south-african-bureau-of-standards-calls-for-food-safety-management-after-a-spate-of-food-recalls-2d8aaa78-7603-4b43-bd73-ed760003561a
- Anelich E., Lues R., Farber J. & Parreira V. 2020, November 2. “SARS-CoV-2 and Risk to Food Safety”. In Tutrition. Available at www.frontiersin.org/articles/10.3389/fnut.2020.580551/full
- Searcy C. & Castka P. 2020, July 27. “The coronavirus pandemic requires us to understand food’s murky supply chains”. The Conversation. Available at https://theconversation.com/the-coronavirus-pandemic-requires-us-to-understand-foods-murky-supply-chains-143229
- Fortune A. 2020, June 17. “Albert Heijn introduces DNA traceability system for branded pork”. GlobalMeat. Available at www.globalmeatnews.com/Article/2020/06/17/Albert-Heijn-introduces-DNA-traceability-system-for-branded-pork
- Reporter. 2020, May 26. “Covid-19 and food safety: Are SA’s food handling regulations up to scratch?”Bizcommunity. Available at www.bizcommunity.com/Article/196/306/204406.html
- See the AgribookDigital blog “Food industry health risks and how to avoid them“.
- Fredericks R. 2019, September 25. “#FoodNextAfrica: Blockchain will simplify and transform supply chain traceability”. Bizcommunity. Available at www.bizcommunity.com/Article/196/741/195840.html
- Kriel G. 2019, August 29. “How the pork market recovered from ‘listeria hysteria’”. Farmer’s Weekly. Available at www.farmersweekly.co.za/animals/pigs/how-the-pork-market-recovered-from-listeria-hysteria/
- Fryer D. 2019, May 6. “How to ensure batch traceability in your food process”. Bizcommunity. Available at www.bizcommunity.com/Article/196/307/190421.html
- Reporter. 2019, February 18. “International push to improve food safety”. Bizcommunity. Available at www.bizcommunity.com/Article/196/306/187484.html
- Kshetri N. 2019, January 30. “Blockchain systems are tracking food safety and origins”. Bizcommunity. Available at www.bizcommunity.com/Article/196/306/186859.html
- Ras H. 2019, January 7. “#BizTrends2019: Traceability at item level across entire supply chains”. Bizcommunity. Available at www.bizcommunity.com/Article/196/718/185738.html
- Reporter. 2018, October 3. “New African Food Safety Index launches”. Bizcommunity. Available at www.bizcommunity.com/Article/196/330/182571.html
- Wayman F. 2018, July 16. “New: ISO 22000:2018 Food Safety Management Standard released”. RiskZA. Available at www.riskza.com/2018/07/16/iso-22000-food-safety-standard
- Chow L. 2018, June 12. “Beekeepers File Legal Complaint Against Bayer Over Glyphosate in Honey”. EcoWatch. Available at www.ecowatch.com/glyphosate-honey-bayer-monsanto-2577435405.html
- The DALRRD-NAMC TradeProbe May 2018 includes the feature “Impact of listeriosis on the trade of processed meat”. Find the document at www.namc.co.za/wp-content/uploads/2018/06/DALRRD-NAMC-TRADEPROBE-ISSUE-NO-73-MAY-2018.pdf
- Korsten L. 2018, March 12. “What led to world’s worst listeriosis outbreak in South Africa”. The Conversation. Available at https://theconversation.com/what-led-to-worlds-worst-listeriosis-outbreak-in-south-africa-92947
- Koen N. 2016, June 24. “If food labels aren’t simple, consumers may ignore them”. Bizcommunity. Available at www.bizcommunity.com/Article/196/741/146845.html
Source: www.foodsafetyinitiative.co.za (website, now defunct, of the Consumer Goods Council of South Africa’s Food Safety Initiative)
Our thanks to Gwynne Foster of Interlinks Traceability Services for valuable feedback
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