Traceability is the ability to track to the point of origin a specific product, or an ingredient in a product, in a time frame dictated by the “need to know” information in order to mitigate the impact of a negative effect believed to be caused by a product, or one or more of its components or ingredients. Classic cases involved over-the-counter medications, SUV tires, avian influenza in chickens, Mad Cow disease, food supplements, and widely publicized cases involving defective parts or ingredients in one product or another. When the problem has been diagnosed, the issue of tracing its cause or origin becomes time sensitive and expensive both in dollars and in corporate reputations. There have also been costly ethical implications.
When a grocery store, manufacturer, car dealer, or shoe store takes a product into inventory, it adds to the inventory database. When the product is sold, it is deleted from the database. With this system, databases remain roughly the same size as inventory turns over. With traceability and tracking requirements, it may become necessary to create records retention plans that enlarge databases as products sold can no longer be deleted, just taken off inventory. Separate systems will need to be designed and maintained in accordance with regulations or consumer demands for information throughout the normal life of the product. This could be extended depending on how the product is disposed of once it surpasses its useful life. For example, how is the product disposed of and what are the ecological or environmental hazard potentials once it is discarded?
In the case of the food animal industries, considerable work is under way to create an animal ID tracking system. The United States Animal ID Plan is a work in progress being developed by an interdisciplinary team (National Identification Development Team at www.usaip.info) chaired by the Animal and Plant Health Inspection Service (APHIS), an agency of the USDA. The industry-state-federal partnership “... was formed in 2002 to more uniformly coordinate a national animal identification plan.” Some of the systems being considered are a Premises ID, an Individual ID, and Enhanced Tracking using RFID technology in slaughter plants and markets. The system is referred to informally as “Farm to Fork” in Canada and “Birth to Burger” in the United States.
The implications for business continuity and disaster recovery planners are considerable. Recommendations forthcoming could require that animals or foods containing animal products, including feed, be fully traceable to their points of origin within 48 hours. Protocols are being considered for ID numbers for each of the three systems – premises, individual animal, and plants/markets – that employ file format specifications of more than 21 characters.
For example, an ID in the national premises repository could be x23456720030801032312.PRM. There would be a similar individual animal ID and a similar group/lot movement record. This data would be generated simply to track an animal to its point of origin or birth. Additional information would be required to track the animal’s ancestry. Of interest is that the database would need to be maintained even after the animal is slaughtered to guard against the spread of a disease attributed to a food product containing any part of this animal for as long as the food product is kept for possible human consumption.
During a foreign animal disease outbreak, BCP/DR plans would need to provide accurate, trace-back information in order to mitigate the health and economic impact of such a situation on the industry. According to Lawrence J. Dyckman of the Government Accounting Office (GAO), “... the federal government spends about $1.3 billion annually to ensure the safety of domestic and imported foods, and estimates that the costs associated with foodborne illnesses are about $7 billion, including medical costs and productivity costs from missed work [based on 2003 expenditures of the FDA and USDA].”
In addition to these federal government expenditures, there are the enormous costs (in billions) to states, producers, and markets when import prohibitions are declared by foreign governments for American products when a credible threat to the food supply is discovered. For example, one Mad Cow in Canada and one more in the U.S.
Disaster recovery planners will have to include in their plans a means for addressing the 48-hour, trace-back issues during a crisis.
Outside the agriculture and food industries, there are the newly required RFID systems in the wholesale/retail business as initiated in 2004 by Wal-Mart. Not only will Wal-Mart suppliers have to adopt and implement ID tracking systems (called Electronic Product Codes, EPC), but their BCP/DR planners will have to incorporate response plans for dealing with product-related emergencies.
According to recent articles in RFID Journal, Information Week, and a white paper from www.datavision.com, Wal-Mart is seriously moving toward RFID technology in its supply chain. Aside from requiring RFID chips on pallets and cases by 2005 for their top-100 suppliers, all of Wal-Mart’s suppliers are expected to comply by 2006.
According to the EPC Insider, significant steps in 2003 included Wal-Mart’s announcement, Gillette’s purchase of 500 million EPC tags, the joint venture of the Uniform Code Council and EAN International to commercialize EPC technology, and the Department of Defense’s requirement that suppliers send pallets and cases with RFID tags.
Clearly, the momentum is sufficient to warrant inquiries by BCP/DR planners in order to prepare for the impending rise of RFID tagging across industries, from retail to defense. It’s a “moving train” with the only decision being “when to climb aboard.” Whatever technological support systems might be created to make traceability a reality, whether through RFID or some other means, the BCP/DR plan will need to address the issues of emergency access to the data.
One key issue is standards. Already, food animal producers, manufacturers, and distributors are expressing confusion over what types of devices will ultimately be acceptable to their markets.
For example, when Gillette applies its 500 million EPC tags to its products, will their choice of technology be universally acceptable to each of their market outlets? If food-animal producers affix RFID tags to animals, will all 50 states adopt a technology that is acceptable to slaughter houses and the USDA?
According to Laurie Sullivan of Information Week, “Defense officials have been in touch with counterparts at the General Services Administration, the Department of Homeland Security, and the Federal Department of Agriculture [USDA], to ensure there’s a common RFID infrastructure across the government.”
The problem will be compounded for BCP/DR planners if their organizations fail to standardize on RFID or EPC systems before it becomes essential to back up, recover, or restore systems supporting their inventory and traceability needs.
Looking to the future, what possibilities might exist for emergency applications of RFID technology? Imagine using RFID tags to identify individual firefighters responding to a large incident such as the Murrah Building, the World Trade Center, or a nightclub in Rhode Island.
Could it be possible to find emergency responders in a collapsed building faster and more easily with RFID tags on their equipment? Would it make identification easier? If so, what systems would inventory the data generated by the RFID system, and how might it be accessed in an emergency? Or what about RFID on employee ID cards for better accountability during an emergency evacuation?
The BCP/DR community needs to become a player in the aggressive adoption of RFID and EPC technology. Whether the technology is used to identify animals, pallets, cases, or victims, there will definitely be new systems to include in continuity, recovery, and emergency plans.
Dr. Tom Phelan is president of Strategic Teaching Associates, Inc., a consulting firm focused on disaster recovery planning and emergency management training. He serves in both the private and public sectors for the IBM Worldwide Crisis Response Team, the American Institutes for Research, DMORT Command and the Onondaga County Fire Advisory Board. He is a member of the Disaster Recovery Journal Editorial Advisory Board, a founding member of the U.S. Department of Homeland Security, a founding board member of Business Network of Emergency Resources (BNet), and training director and board member of Private & Public Businesses, Inc. (PPBI). He was awarded the New York State Senate Liberty Award for his service at Ground Zero in September 2001. He is also a member of the International Association of Emergency Managers (IAEM) and a licensed Dale Carnegie instructor. Dr. Phelan is actively engaged by clients developing solutions to the processing of critical information related to food animal identification tracking and public health crisis communications at the national and international levels.