Traceback Trials

MATTHEW ENIS

It's a crucial time for the Produce Traceability Initiative, an industry-led effort to achieve farm-to-retail electronic traceability for fruits and vegetables sold in the U.S. and Canada.

Industry groups — including the Produce Marketing Association, the United Fresh Produce Association and the Canadian Produce Marketing Association — recently announced a major PTI milestone, with 34 steering committee members agreeing to a timeline that will move the produce industry toward a common standard for electronic traceability by the end of 2012. However, in the wake of this summer's Salmonella Saintpaul outbreak, the U.S. Food and Drug Administration is watching closely, and possibly considering new regulations of its own.

The goal of chainwide electronic traceability dates back to 2002, when the U.S. Bioterrorism Act that year ordered growers, distributors and retailers to maintain “one up, one back” records that government agencies could access within 24 hours of an illness outbreak or other crisis. Yet, while that law ensured basic traceback capabilities, industry groups, led by PMA and CPMA, recognized that the industry would ultimately benefit from the adoption of a standardized system, and began studying the best options available and examining how such a system might work.

The biggest challenge was deciding what system all of these companies should use, according to PMA spokeswoman Julia Stewart.

“If you want to move everyone to a common language, what language is that going to be?” she said. “Because, you're starting from a point where every company should have the ability to do internal traceback and trace-forward. But they all have individualized systems for doing that. Each company has its own information management systems. So, consider how many systems there might be across the produce industry. Whose system do you move to?”

Industry groups ultimately settled on a system based on standards developed by GS1, the global nonprofit organization dedicated to improving supply chain management efficiencies. These standardization efforts reached a new level of urgency after the widespread E. coli outbreak of 2006, which devastated the fresh spinach and leafy greens industries. In addition to developing new agricultural safety standards through programs like the California Leafy Greens Marketing Agreement, the industry banded together to focus on the traceability issue, with PMA, CPMA and United Fresh announcing in the fall of 2007 the formation of a traceability steering committee composed of leaders from throughout the produce supply chain, as well as major retailers such as Wal-Mart Stores, Kroger Co., Food Lion and Wegmans Food Market.

Everything was going great until this summer, when the Salmonella Saintpaul outbreak was first blamed on tomatoes and then, weeks after sickening more than 1,300 consumers nationwide, finally linked to irrigation water at a pepper farm in Mexico. Tomato growers were furious that epidemiological evidence from the U.S. Centers for Disease Control and Prevention had pointed traceback and recall efforts in the wrong direction. Some lobbied the federal government for financial compensation for recalled and destroyed crops.

FDA officials, meanwhile, complained that the variety of record-keeping systems used by the produce industry had left them with mountains of unstandardized paperwork to sift through, slowing their investigation to a crawl. Congress held a set of hearings on the issue in August to determine what went wrong, and the FDA is holding two public meetings to “determine what short- and long-term steps [FDA] should take to enhance the current tracing system,” according to the agency's official notice.

Currently, industry leaders are hoping to convince the FDA that the Produce Traceability Initiative is already well under way, and is the best and most efficient way to enhance the industry's current traceability system.

“That plan was developed over a lengthy, thoughtful and intensive process by the PTI's multidisciplinary steering committee to ensure that plan is achievable across the produce supply chain, from field to store to foodservice,” Kathy Means, vice president of government relations and public affairs at PMA, said in remarks submitted to the FDA prior to the first public meeting on Oct. 16 in Rockville, Md. “We strongly urge the agency to consider the PTI's work and plan before taking any further steps on this topic, as these produce industry experts are in the best position to make recommendations that are realistic and achievable in the marketplace. And a significant number of produce industry members have already agreed to implement the PTI plan.”

In fact, earlier this month, PTI announced a seven-step timeline agreed upon by the 34 members of the steering committee that will ensure full electronic produce traceability throughout the produce supply chain by the end of 2012.

“By first quarter 2009, brand owners will (1) obtain GS1-issued company prefixes required to create [Global Trade Identification Numbers], and (2) assign 14-digit GTINs to every case configuration they pack. They will then (3) provide those GTINs to their buyers by third quarter 2009, so that buyers can input this data into their information management systems. By third quarter 2010, brand owners will begin placing the GTIN and lot number on case labels in (4) human-readable form and (5) machine-readable barcodes. Each subsequent handler of the case will be able to scan and store the GTIN and lot number on (6) inbound cases in 2011, and on (7) outbound cases in 2012,” PMA, CPMA and United Fresh announced in a joint release.

Stewart said that many companies should be able to meet these goals much earlier.

“Our focus, first and foremost, is on getting industry the tools and information they need to execute this by 2012, if not much earlier,” she said. “We think a lot of people have the ability to do this now. The 2012 deadline is to ensure that even the smallest companies can participate.”

Steve Arens, senior director of GS1 US, agreed, noting that readiness varies from company to company and from channel to channel. In general, the retail industry is further along than the foodservice industry, he said, but the timeline sets in place realistic, achievable goals for all of these companies.

“[The PTI steering committee] recognized that it's going to take several years for growers and packers to get the printing and record-keeping applications in place,” Arens explained. “They also recognized that it will take some time for retailers and distributors to acquire, install and train their people to use scanners, as well as set up the supporting systems to collect that information, store it and, when necessary, retrieve it.”

Ultimately, though, the GS1 system will allow not only full electronic traceability, it will also work with the “Product Recall Collaboration Zone,” an online portal developed by GS1 and the Food Marketing Institute that allows suppliers to quickly disseminate standard recall information to retailers, Arens noted.

“The GTIN provides a common touchpoint between the applications,” he explained.

As an industry-developed plan, PTI is voluntary, but the steering committee expects that market forces will ultimately push the produce industry toward full adoption as retail buyers demand compliance from their suppliers. With major retailers, including Kroger, Wal-Mart, Safeway, Supervalu, H.E. Butt Grocery Co., Food Lion, Wegmans and Schnuck Markets, already signing on, that expectation will likely be fulfilled without intervention from the FDA.

Stewart said that industry associations are planning multiple educational efforts, ranging from seminars and workshops at trade shows, to the development of a single website where companies can go to get information about the initiative and how to comply.

“We're planning on using a full range of educational options to get the word out. Everything from workshops at existing venues like [PMA's] Fresh Summit, to webinars and webcasts and online recordings,” she said.

The FDA will hold its second and final public meeting on produce traceability on Nov. 13 in Oakland, Calif., in the Edward Roybal Auditorium in the Ronald V. Dellums Federal Building. It's uncertain at this point whether the agency will ultimately seek to impose new regulations on the produce industry, but for now, the PTI would seem to be the most logical direction for the industry to continue heading.

Arens noted that at the most recent meeting in Rockville, Md., FDA representatives paid close attention to presentations from PMA and United Fresh, and he noted that “during other parts of the day, other speakers — solution providers offering proprietary solutions — parts of their message emphasized that they used the GS1 and GTIN system as a foundation product identification element. So there were a number of references to the GS1 system.”