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Dear Sprouters,

There are many issues you have to deal with everyday in your operations, paying bills, inventory management, taking orders, packing product, etc. the list seems endless. However, one of the inevitable truths is that the job is not done until the paperwork is completed. We wanted to work with you on one of these issues that is also critical to Food Safety, this being traceability paperwork. Should there ever be a need to trace a batch of contaminated seed or product, there must be documentation to show:

  • Who you got each lot of seed from
  • When/how you made/processed the batch, which lot of seed was used
  • Who and when you shipped it to, and how to identify each batch

This documentation must be accurate and available to the FDA or corresponding state or local Health officials. In 2002, the FDA began requiring this documentation because of the potential threat of Bio-terrorism, see:

http://www.fda.gov/Food/FoodDefense/Bioterrorism/Recordkeeping/ucm061631.htm#IIa

This requirement though is equally pertinent to any inadvertent microbiological, chemical or foreign substance contamination. This documentation will also be part of the requirements of the Sprouters Audit checklist, which we will all be reviewing soon. One tool that can be used is a Mock recall. This paperwork exercise can be done by tracking a random processed lot back through your system, being sure that you have all of your records on when and which lot was used and your testing associated with it, who and when you sold it to, and then backwards to the seed supplier. This exercise should be completed at least twice per year, and any failures should prompt corrective actions.

No one wishes more work to do, but this exercise a couple of time a year, will allow you to sleep better knowing your documentation is complete and ready should there ever be an issue, help satisfy the regulatory community, and help the requirements of the new upcoming audit.

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