May 4, 2012
Making traceability work is target of industry, FDA initiatives

It can be a long journey from farm to table. And a lot of things can happen along the way.

With the Food Safety Modernization Act (FSMA) calling for an effective protocol to track and trace foods in the entire supply chain, traceability is the word of the hour.

Label on every case

Even as FDA has initiated pilots to examine the practices, processes and types of technology that might be available to help better trace foods in the event of a foodborne illness outbreak, the industry’s Produce Traceability Initiative (PTI) is trying to stay the path to achieve supply chain-wide adoption of electronic traceability for every case of produce by Dec. 31.

“The end game, I think, is that we’ve got the ability to, number one, track a case of produce wherever it went through the supply chain,” said Ray Connelly, president of Salinas, Calif.-based TRUETRAC and a member of PTI’s technology committee. “Number two, that label on that case is a license plate to additional information about that product – things like food safety, the production practices, things like that.

“The goal right now is to provide a label on every case of produce that goes into commerce in North America. That’s what the Produce Traceability study is.”

PTI is a voluntary collaboration of the Produce Marketing Association, United Fresh Produce Association, Canadian Produce Marketing Association and GS1 US. The group’s latest undertaking was a survey to assess the extent of the industry’s adoption of traceability standards, with results to be completed soon.

In the meantime, FDA is conducting a traceability pilot that focuses on fresh tomatoes, along with one targeting certain processed foods, as it aims for full implementation of FSMA, signed into law in January 2011. Connelly said FDA is working in a three-year window to come up with final rules.

“The Food Safety Modernization Act gave the FDA the clout to redefine a safe food supply,” said Connelly, adding that if PTI’s traceability protocol proves functional, it is likely to be welcomed by FDA.

FDA’s standard for traceability calls for each player in the supply chain to be able to trace the product one step back and one step forward. That means everyone – from grower to retail store, processor or foodservice provider and all stops between – should have an in-house traceability plan.

PTI has developed an action plan, posted at, that spells out a process relying on bar codes to identify individual companies, known as a GS1 company prefix, and a 14-digit GTIN number that contains all of the traceability data for each product. The numbers are to be provided to buyers and are supposed to be displayed and readable on each case. Anyone receiving the cases should be able to read and store information on each one, based on the data provided.

Whose name the identification is tied to depends on how the product is being sold.

“If Farmer Ed is selling his product under Ed’s product brand, then yes, he’s a brand owner and brand owners need to get a GS1 company number and assign a GTIN to every different case they have,” said Angela Fernandez, GS1 senior director of industry engagement during a recent PTI-sponsored webinar. “If they’re packing and shipping under somebody else’s brand – for example, if they’re shipping for a private label and that’s all they do – they don’t sell under their own brand. They are not required to get their own GTIN and GS1 number. That will be provided by the label owner.”


Even though everyone is responsible for internal traceability, there are some pivotal points in the supply chain. Connelly said one of them is at the packer level.

“The brand owners, which are largely the packers – they are the key because they are the ones that effectively create that carton of produce and insert it into commerce,” Connelly said. “They sell it, so it becomes a transaction that comes to another company.”

It is during packing that PTI calls for barcodes to be affixed to each case of produce.

During PTI’s traceability webinar, Ed Treacy, vice president of supply chain efficiencies for the Produce Marketing Association, said it’s important to include all materials in traceability accountability.

“If there is a problem with the product discovered somewhere down in the supply chain, you want to find out all the inputs that went in to create that product,” Treacy said. “It may be you’ve got a bad batch of cardboard – actually the shipping container you’ve shipped it in is causing issues with the product. That’s why it’s best practice to record all inputs – packaging, labels and everything you used.”

Small growers

James Lindemann, an apple grower and cider producer in McFarland, Wis., attended a recent traceability seminar put on by Michigan State University in Grand Rapids, Mich. He came as part of a continuing effort to devise the most workable traceability plan for his operations.

“In terms of traceability, the problem I see for the small grower is that our batches are measured in tens of bushels as opposed to truckloads,” Lindeman said. “We have a traceability system that we think works. Somebody can come in and audit it … no one has challenged it and we haven’t had any recalls.
”But the problem I see is if we look at the time we’re putting into that, it’s increasingly a large portion of the time we have available.”

Expense is another factor for the small grower, he said. While packers and large farming operations might be more likely to have the resources to subsidize electronic software and systems, that can be less likely for small growers.

That’s what prompted Santa Clara, Calif.-based RedLine Solutions to develop a new product called PTI Lite. At less than $5,000, it runs on a home computer and “allows PTI compliance that is affordable for the family farm and small business,” said RedLine CEO Todd Baggett.

“We’ve created different bundles,” he said. “In the most simple bundle, you get software, support, label formats, printer and the labels.

“It’s actually geared for the smaller grower, or re-packer, or grower or distributor getting product in that’s not labeled yet and has to get labeled before it can go to customers.”

A produce buyer for a distributor, broker and packaging operation speaking at the Michigan seminar, said his company asks that there is identification on each box that comes in the door. While that doesn’t always happen, there’s no reason it can’t – and shouldn’t, said MSU Extension Educator Phil Tocco.

During the workshop, Tocco said it’s incumbent on growers to “do a certain amount of due diligence on our side to make it work.”

“It doesn’t have to be real scientific,” he said, noting that lugs should be field labeled. “There should be a tracking number on each lug, and if there are multiple lugs and crates from the same field and the same picker, it should be the same label but on each lug.

“Then each lug shipped should be in your log book … with who you shipped it to. And the invoice needs to have the lug numbers on it so they know what they got.”

Labels can be as rudimentary as the small, blank variety available in sheets at the office supply store, written by hand. Adhering to certain wax boxes may be a problem, in which case Tocco recommended stapling or, better yet, purchasing a hand stamp that identifies the farm and can be adjusted as codes between lots change.

QR codes, which can be read by smartphones, are an excellent option for those who have the means, Tocco said. He demonstrated with his laptop how a label maker could be attached to a computer to generate codes on labels that can then be affixed to lugs or boxes.

The main thing is to have a system that is consistent and functional in case of a recall. New rules from FDA require that records be available within 24 hours. However, it’s in everyone’s interest to expedite tracking – for a lot of reasons that include public health, eliminating unnecessary removal of product and minimizing bad publicity.

RedLine Solutions is seeking a handful of growers to be “early adopters” of its PTI Lite software. Those selected to participate wouldn’t be billed immediately, would provide feedback on how the product works before it is officially released and would receive extended remote support from the company. To find out more, visit or call 888-801-2039.

By Kathy Gibbons, Editorial Director

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