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Ernie Redfern, CIO
Using RFID for Regulatory Compliance
Who is Blommer Chocolate Company?
•Founded in 1939•Four generations in chocolate•Family owned and operated•Four plants strategically located:
Chicago, ILEast Greenville, PA
Union City, CACampbellford, Ontario
Company Overview
Largest Cocoa Bean Processor in North America Currently - 225,000 Metric Tons (8% of World Crop)
Largest Presser in North AmericaSupplying to All Major Cocoa Butter and Cocoa Powder
UsersLargest Fully Integrated Chocolate & Cocoa Manufacturer
in North America supplying:Confectionery, Baking, Dairy and
Pharmaceutical/Cosmetic IndustriesLowest Cost Manufacturer in North AmericaSole Focus is Cocoa Business
Some of The Brands We Supply
Bioterrorism Act Title-306 :Establishment and Maintenance of Records
2002 - Congress passed the Public Health Security and Bioterrorism Preparedness and Response Act
June 12, 2002 President Bush signed into law “THE BIO-TERRORISM ACT” (BTA)
HIGHLIGHTS OF BTA III:SUBTITLE-A SECTION-306Start of Compliance date December 9, 2005Records must be kept for 2 yearsAvailable to FDA in 24 hoursCompanies with Multiple Manufacturing
locations do not need to have duplicate Records
FDA does not Require Specific type of Forms or Systems to Maintain Records
Tracking of samples, trade show merchandise, give aways.
BTATitle – III : Subtitle-A Section - 306
Who need to be in compliance?Manufacturers ProcessorsPackersDistributorsReceiversHoldersImporters
BTATitle – III : Subtitle-A Section - 306
Key Provision of Record Keeping:Two Years of RecordsIn processImmediate Previous SourcesImmediate Subsequent recipients
Why Blommer Chocolate Company Implemented RFID InitiativeCompliance to new regulations within our overall
inventory control strategyExtensive use of outside logistics partners put
greater burden on record keeping to meet new requirementsNeeded to track when products left our custody (shipment
to outside warehouse).Needed to track when products returned to our custody.
Interplant shipments needed greater trackingNeeded to know when product left our custody for
shipment to customersTracking Incoming Raw MaterialAutomatically relieve raw material in batching
processAccurate Inventory Counts
Why Blommer Chocolate Company Implemented RFID Initiative … continued
We were NOT mandated by any customer to implement an RFID strategy in order to integrate with their system
Food industry has no standards (schemas) on data exchange universally adopted
RFID strategy is viewed as a way of cutting costs and augment increased record keeping burden while allowing for future expansion without additional headcount
Non-Liquid Products We Ship Tracked By RFID
Bulk Product Tracked by RFID
What We Do Not Track with RFIDLiquid Shipments (tankers)Silos
Cocoa BeansSugar
Raw MaterialLiquid form pumped directly to holding tanks
RFID & Shipment to Outside WarehouseGoal: Eliminate manual tracking of
product movement and automatically generation of shipping documents while complying with BTA accountability.
Solutions: Reserved shipping docks for warehouse
shipments and put in RFID tunnels. Operators open dock, move product into
trailers, and close dock – bill of laden automatically prints.
Bar coding of trailer seals helps. We know when product was loaded and trailer
sealed (date and time).
RFID & Shipment to Outside Warehouse
(Receipt by Outside Warehouse)Installed VPN tunnel at outside warehouse.Installed Access Points at warehouse as
extension of Blommer Chocolate’s facility.Incoming trailers scanned & palettes
scanned while being offloaded in real time (date and time annotated automatically).
We know when product returns to our custody and what is in-transit.
RFID & Batch Control (Lot Control)Goal: Track raw material usage throughout batch
cycle to include lot number traceability and rework control
Solutions:Rework tagged with RFID label Install RFID Tunnel in Paste/Mixing Room
Provides visibility of product moving to production area.Provides accurate lot number information associated with
raw material.Alerts operator through visual signal if raw material or
rework is not released from QC hold.Alerts operator through visual signal if wrong raw material
is being moved to production area.Operator annotates raw material/rework quantity
usage for each batch through handheld terminalsIntegrated rework into batch process as indented bill-
of-material
Paste Room RFID Tunnel
ROI Task # of
timesPrior to
RFIDPost RFID Savings
Mock Recall 21 per yr
12.75 hrs 3.25 hrs 9.50 hrs199.5 hrs yr
Transfer of product to outside warehouse (processing time)
59 trailers per day
1.17 hrs .57 hrs .60 hrs8,850 hrs yr
Interplant Transfer
8 per week
.75 hrs .34 hrs .41 hrs164 hrs yr
Tote Billing Accuracy
9,375 Lbs
$1.18 per lb $11,062 yr
What We Did RightSet everyone’s expectations.
We were going to go through growing pains.RFID was not going to be the savior for our
inventory problems.Appointed high level executive sponsorIncorporated bar code scanning with RFID.Ensured all our people were trained on new
system. Prototyped system in one plant before
implementing in all plants.Understood complexity of programming
that needed to be done for RFID tunnel integration.
What We Did WrongUnderestimated Printer IssuesInitially did not use motion sensors to turn
on/off RFID tunnelOverestimated RFID equipment (readers and
antennas) ability to work in manufacturing environment
Overestimated out vendor’s ability to provide technical support for an RFID solution“Newness” of technology limits number of
“experts” out thereForced to write some of the integration internally
FDA: Contaminated feed could affect farms nationwide
POSTED: 12:10 a.m. EDT, May 2, 2007 – CNN.COM
• Contaminated feed found in 38 Indiana chicken farms; more farms likely affected• Feed contains recalled pet food with tainted wheat gluten• No human illnesses have been reported related to tainted poultry feed • Reports of 4,150 dog and cat deaths related to pet food recall
Where we need to go …..
April 21, 202322
Infrastructure Used - For reference only - not an endorsementRFID Antennas & Reader
SAMSysRFID Printers
PrintronicsZebraDatamax
RFID Label – Printronix RFID SmartTagsWarehouse Management System Software
AGI Worldwide – FinalMoveERP – Microsoft Business Solutions Great
PlainsDatabase - Microsoft SQL Server 2005
Q&A