From Field to Fork

Following last week’s successful traceability symposium in Grand Rapids, Michigan, PMA will continue the discussions and implications of this food safety technology during our upcoming Fresh Summit International Convention & Exposition, October 15 to 18 in Orlando, Florida. Two traceability workshops are on the agenda:

• Traceability in the Real World: Find out first-hand from companies that have already implemented the produce traceability initiative with great success. In this session, an entire supply chain panel, from growers to retailers, will share their findings, discuss how traceability worked for them, and provide invaluable insights as to what you can expect when the traceability initiative takes effect.
• From the “How” to the “Why”- A New Look at Traceability: Since the initiative’s launch a few years ago, a lot of attention has been on “how” companies can implement traceability, but not much focus has been on the “why” (the business implications and benefits). Come to this session and join industry members in a group discussion to learn why traceability is a smart strategy for your business.

For a complete listing of the event’s education program, visit the Fresh Summit Web site and look at the schedule. If you’re planning to come to Orlando in October, remember that the deadline to register online and save is September 17. The last day to register in advance is October 1.

Earlier this year, an industry survey found that 70 percent of the fresh produce industry is working toward implementing the Produce Traceability Initiative, with 58 percent on target to meet the milestones. To help the industry learn more about the initiative, PMA is holding its first Traceability Symposium on August 10 in Grand Rapids, Michigan, at the J.W. Marriott Grand Rapids.

The day-long symposium features traceability experts who will introduce attendees to the new vision for PTI, explain the steps needed to turn this vision into reality and dispel misconceptions about it. The symposium is presented in partnership with Superior Sales, Inc., along with presenting sponsor N2N Global and participating sponsors Avery Dennison, FasCor Inc., HarvestMark, iGPS, Lowry Computers and Virtual One Software.

Featured speakers include PMA’s traceability expert, Vice President of Supply Chain Efficiencies Ed Treacy. He will be joined by representatives from the Food and Drug Administration, GS1 US and US Foodservice. Attendees will also hear perspectives on traceability and PTI from a retail panelist.

To register for this event, visit the PMA Web site. Advanced registration runs through July 30; on-site registration is also available, space permitting.

Approximately 70 percent of the fresh produce industry is working toward implementing the Produce Traceability Initiative, with 58 percent on target to meet the milestones, says a survey conducted by PMA, United Fresh, and the Canadian Produce Marketing Association. Nearly two-thirds of respondents reported they are having communications with their trading partners. Retailers reported they are lagging behind the industry in adopting PTI; by comparison, 51 percent of retailers reported they are having communications with their trading partners. At this date, it appears that 58 percent of the industry is on target to meet the milestones as recommended by the PTI action plan by 2012.

The primary barrier cited by respondents related to PTI implementation is cost, followed by a lack of awareness on PTI, and waiting on government regulations. Speaking of government regulations, earlier this month, PMA submitted traceability comments to FDA. In those remarks, we called on FDA to use existing standards and systems as they provide practical, real-world solutions, and that those solutions must be globally applicable. We continue to collaborate with FDA as it works toward regulatory solutions for traceability.

For more details on the PTI survey, visit the PTI Web site.

Like many others interested in food safety, PMA offered traceability comments to FDA on March 3 – in particular produce traceability. FDA had asked specific questions about food traceability, and we answered those questions. You can find the details in our comments. We supported the Produce Traceability Initiative and provided information on how the protocols for that initiative could meet FDA’s needs.

We urged that FDA consider that case-level, rather than item-level, traceability is appropriate because the case is the unit of commerce that is recognized and “touched” at each link in the chain. We called for the agency to use existing standards and systems as they provide practical, real-world solutions.

We stressed that solutions must be globally applicable. The fresh produce industry is a global industry that relies on product movement around the world. Systems must work for product entering the United States from other countries and must work for U.S. producers who export their products. It is highly inefficient for companies to maintain multiple traceability systems. Globally recognized, market-proven product identification standards are essential to the success of global traceability.

We also noted that traceability should apply to all companies, regardless of size, method of production, location, or commodity type. PMA has long said that there cannot be any holes in the safety net. That said, solutions must be scalable and workable for companies of all sizes and the industry’s varied production methods, locations and commodity types.

FDA is working toward regulatory solutions for traceability even as Congress considers traceability as part of its overall food safety bills. Stay tuned.

Wrapping up a three-week stint of sharing PMA’s 2010 legislative and regulatory forecast with East Coast growers, at the end of this week I will be presenting this information (as well as an update on traceability) to attendees of the Tennessee Fruit and Vegetable Association during its Horticultural Expo.

As I looked at PMA’s economic impact study, I learned that, in Tennessee, the fresh produce and floral industry accounts for 30,755 direct full time equivalent jobs. These direct jobs generate an additional 17,625 jobs for a total employment impact of 48,380 jobs. In total, these workers earn $1,209,120,857 and the total economic output is $9,536,221,697.

Getting out and connecting to members at meetings like these are one of the things I really enjoy doing for PMA. While my e-mail (and Blackberry) keeps me constantly linked to what is happening, it’s very easy to become over-reliant technology and lose sight of the value of industry gatherings.

That said, technology can be used to bridge the information gap. For those who can’t be there but would like to know what is going on at the meeting, you can follow me on Twitter.

I attended and spoke at the 2010 Atlantic Coast Agricultural Convention and Trade Show, sponsored by the Vegetable Growers Association of New Jersey. On and off the show floor and in and out of educational sessions, there was a lot of talk about food safety and traceability. Attendees talked about costs, level playing fields, fairness, scalability, regional and commodity differences. This same conversation is going on at grower meetings around the country this month. I’ll report on what I hear at the Delaware meeting next week and the Tennessee meeting later this month. You can follow me on Twitter as I share updates from those meetings.

Growers embrace food safety with the caveats that new rules don’t serve to put them out of business. They want to be sure everyone is playing by the same rules because they’ve been burned by prior outbreaks and the resulting market disruptions (New Jersey growers were significantly affected by the spinach and pepper/tomato outbreaks even though neither originated in that state). But they want the rules to meet their real-world needs. One grower told me about one of his fields that is 780 feet across. Requiring wide buffer zones would mean he couldn’t plant anything as buffer would meet buffer in the middle.

I spoke about the proposed National Leafy Greens Marketing Agreement, the progress of food safety bills in Congress, and FDA’ s consideration of new regulations and guidance for our industry. It’s a lot to take in. I heard from growers who are on thin margins as it is and see financial gloom in the future under new regulations. New Jersey ranks 10th out of 50 in terms of produce supply-chain economic output for the United States, according to PMA’s Economic Reach and Impact of the Fresh Produce and Floral Industry study. It is vastly different from states like Florida and California in the top 10 as it is smack in the center of the largest U.S. population base, pressed on all sides and from within by people. Farms are wedged in between developments, and farmers work to keep the Garden State a strong source of fresh produce. Every state, every county has unique needs.

It’s more important than ever that legislators and regulators hear from the companies they regulate so that we get rules that advance public health and safety without undue burdens on those who grow and market our fresh produce.

Last month, FDA announced it extended until January 4 the deadline for industry comment on the draft commodity-specific food safety guidance documents for melons, leafy greens, and tomatoes. PMA submitted its comments on leafy greens, tomato, and melon guidance in early November.

In those remarks, we urged FDA to direct industry to include risk assessment and risk management in their activities. We also asked FDA to provide industry with more information about the foodborne illness outbreaks and related investigations involving these commodities so we can learn more. We called on FDA to partner with the Center for Produce Safety to research answers to information/data gaps and other produce-specific food safety questions.

Members who are considering offering comments to FDA are encouraged to use PMA’s insights as a guideline if they so choose. FDA will consider the comments it receives on these guidance documents, revise them as needed, and then publish final guidance. We’re actively engaged with FDA and will keep our members updated on new developments as they occur.

Related to food safety, the Produce Traceability Initiative Steering Committee still seeks industry feedback on PTI implementation. Please share your company’s progress and thoughts about the PTI by taking the online survey, also by January 4.

The second day of the public meeting on traceability offered many themes similar to the first day. Hosted by FDA and USDA’s Food Safety and Inspection Service, the meeting moved more into the details of how traceability can happen and what common elements food traceability requires. Speakers from industry, including PMA, talked about the need for common standards, flexibility to accommodate different types of food and businesses, global applicability, and more.

One speaker said that traceability should remain voluntary, handled by industry members. Others talked about the burdens for smaller companies. I spoke about the Produce Traceability Initiative’s ability to connect each link in the supply chain and provide common information to assist traceback and trace forward.

What continues to surprise me is that some believe traceability can remain optional, that requirements from the government might not happen and things can move forward status quo. There is no indication that either FDA or Congress will leave it at that. Government is moving forward on traceability – through the legislative and regulatory processes. That’s why it is so important that we participate in discussions like those held this week and educate legislators and regulators about the PTI, a system created by industry for industry to solve a real-world issue.

The traceability public meeting Dec. 9-10 hosted by FDA and USDA’s Food Safety and Inspection Service attracted the who’s who of the food industry and raised many issues familiar to those who’ve been dealing with this for some time. The meeting addresses traceability for all foods; produce has been mentioned a lot. During the first day, the Produce Traceability Initiative was praised by most, including an FDA official who commended industry for addressing traceability through PTI. However, one Ohio produce company representative called it a boondoggle.

On Dec. 10, I’ll be on a panel talking about supply chain links. As you might expect, I’ll talk about that through the lens of the PTI.

These, in no particular order, are some of the themes we heard during the first day of the public meeting:

• Is the one-up, one-back concept sufficient for traceability? Several said that should accomplish traceability, and FDA should enforce the existing rules before expanding the scope. Others said that each link in the chain should know everything that happened to the product before it reached them. And a couple of FDA officials said that one-up, one-back is a good start but we need more.
• A lot of talk about traceability needing to be flexible and scalable based on commodity needs, business size, and industry complexity.
• Product commingling, lack of lot numbers, inconsistent product nomenclature, and paper records (vs. electronic records) hamper tracebacks.
• Traceability is not an effort to improve food safety, it provides a reaction when there is a problem. Strong food safety programs that focus on prevention contamination are essential.
• To work, traceability must be based on accurate product identification through epidemiology.

Besides these oral comments at the public meeting, the agencies seek more-detailed written comments on specific issues; they’re due in early March.

On December 9-10, FDA and USDA will host a joint public meeting focused on improving traceback for human and animal food. The agencies are seeking public input in identifying elements of effective food product tracing systems; specifying gaps in the current food product tracing methods; and finding specific mechanisms for improvement. This information will help FDA and USDA determine appropriate steps to enhance the current tracing system for food products.

USDA (meat, poultry, and egg products) and FDA (all other foods) investigate foodborne illness outbreaks and other foodborne risks associated with the products they regulate. These investigations, conducted in close cooperation with the U.S. Centers for Disease Control and Prevention and state and local health departments, often involve tracing foods backward or forward in the supply chain.

I’ll be there explaining how the Produce Traceability Initiative (PTI) uses a common platform, common standards, and common technologies to enhance traceability and make it more effective. The agencies are also seeking in-depth written comments on the topic, which are due March 3, 2010.

The agencies are not the only ones seeking traceability information. The PTI’s supply chain-wide Steering Committee and the administering associations (including PMA) need your help to evaluate the industry’s implementation and identify additional support needs. Please share your company’s progress and thoughts about the PTI by taking the online survey.

Please respond by Jan. 4; the survey should take no more than 15 minutes. Your responses will be submitted anonymously, and only aggregated data will be reported.