The recent tragic outbreak of listeria in cantaloupes underscores that what we’re doing in the Produce Traceabilty Initiative (PTI) continues to be relevant and timely for our industry. The importance of being able to trace back product is a generally accepted tenant in our industry, yet traceability without a common framework is of limited benefit. PTI presents just such a framework for helping the industry achieve supply chain wide traceability and enable faster and more surgical recalls. Increasingly, companies all along the supply chain are looking to PTI as a standard for their traceability requirements.
This year’s Fresh Summit seminar on PTI will showcase what specific companies have learned from their PTI pilot programs. We are pleased to welcome two retailers, Wal-Mart and Publix, and two grower/shippers, Alpine Fresh Inc. and Ippolito Fruit and Produce Limited, who will share their real-world experience of implementing PTI in their business. The panel will impart tips about what worked well and key learnings about what didn’t. Attendees can take home the insight of these PTI pioneers and be better prepared to face the challenges and potential pitfalls in implementing a traceability program.
The final PTI milestones for grower shippers and the first milestones for receivers are only three months away and coming fast. So, I’ll be opening the session with an overview of the PTI and its requirements and timeline. After we hear from our panel, we’ll finish up the session with a panel discussion where attendees can ask any question of the four panelists or me. We expect it to be an incredibly interactive, constructive dialogue.
For anyone shipping or handling produce, this seminar will provide invaluable examination of PTI implementation. Those just starting the traceability journey will find the reality shared in this seminar facilitates the process as they glean information from those who’ve already walked the PTI road. Companies with their own in-house traceability system will benefit by understanding what modifications may be needed to make their current system PTI compliant.
The future of the produce business demands PTI compliance – the consequences of not doing so is just too great. Very quickly PTI is evolving to be a marketplace requirement and an important step in ensuring our food safety for our consumers. For more information on registering for Fresh Summit, or any of the workshops, please log onto our website www.pma.com and look for the Fresh Summit link under Events and Conferences.
Meg:
Hello, this is PMA public relations manager Meg Miller, and welcome back to our audio blog, “Ask Dr. Bob” with PMA’s Chief Science & Technology Officer Dr. Bob Whitaker. In recent posts, Bob and I talked about how PMA plans to generally approach the Obama administration’s implementation of the new Food Safety Modernization Act. The Food and Drug Administration is now charged with translating the law into implementing regulations. In those posts, we talked about the different approach that PMA takes to government relations, striving to collaboratively work with government, to inform and educate their work so that we get the best governance possible.
In this post we’re going to look at a specific component of FSMA – its mandates regarding traceability – and discuss what FSMA implementation may mean for the industry’s ongoing Produce Traceability Initiative.
Bob, can you start by giving us the basic 411 – what does FSMA have to say about traceability?
Bob:
Meg, as we talked about in those earlier posts, the FSMA law is basically a blueprint. Congress provided general direction, and now it’s up to FDA to build regulations that define the specifics to implement that general direction. At this point in time, it’s not possible to say exactly what the implementing regulations will look like.
The law’s traceability component provides a great example of what we know, and what we don’t know for now. For example, FSMA calls for better traceability of foods in general, and heightened recordkeeping for so-called “high risk” commodities. Well, it will be up to FDA to identify the commodities it deems to be “high risk” (though we can probably make some well educated guesses.) As for the recordkeeping system, the law also specifies that FDA will develop a system to “effectively and rapidly” trace and track food – it will be up to FDA to determine what such a system might look like.
The good news is, the law specified that those additional recordkeeping requirements must be science-based – Meg, you and our listeners know that PMA is always advocating for food safety decisions that are based on sound science, and that are prioritized based on the risk posed by a particular food.
In terms of what else we know at this point, the law also provided FDA with some instructions to undertake before deciding what traceability and recordkeeping systems should look like. The law requires that there be a produce-specific pilot program, and that FDA evaluates the costs and benefits of traceability solutions that are already available.
Meg:
I know some members have asked whether they should wait for those final implementing regulations before moving forward with implementing the Produce Traceability Initiative. What are your thoughts on that?
Bob:
There are several reasons why they shouldn’t wait. First, it’s going to take several years before implementing regulations are developed and go into effect. In fact, the law lays out some ambitious timelines that we think are going to be difficult to achieve. In the meantime, our industry simply can’t afford to wait that long to begin the work of building traceability systems that can minimize the scope and severity of recalls. We know these recalls are expensive for our members. We also know that we need to start restoring consumer confidence in the safety of our foods that has been battered by a series of high-profile foodborne illness outbreaks in recent years. PMA research indicates that consumers are not increasing consumption in part because of food safety concerns.
Second, as Ed Treacy – my colleague who directs PMA’s supply chain efficiency efforts including the PTI – recently wrote, if altruism doesn’t sufficiently motivate you, then consider that we’ve also gotten the legal community’s attention. These days, a foodborne illness outbreak is at the very least expensive and in some cases could well cost you your business, and that’s a price no one wants to pay. We need a better system now.
I think it is also important to note that the buying side of our business is busy at work implementing traceability programs – and for all fresh foods, not just produce. We have seen tremendous support for PTI from leading retail and foodservice buyers. It is going to be important for suppliers to be able to demonstrate that they too are working to meet PTI timelines and have the systems in place to provide for sufficient traceback should the need arise.
As we talked about in the earlier posts about PMA’s approach to food safety government relations, our strategy is to inform and influence their work and collaborate with those responsible for governing us so that we get workable solutions to our needs. We’re planning to apply that strategy to outreaching to FDA on FSMA implementation. The industry has already developed a working, efficient, cost-effective traceability solution in the Produce Traceability Initiative, we’re going to make the case early and often that FDA doesn’t need to look any further than that.
Meg:
Am I remembering correctly that the law specifically doesn’t require case-level tracking, which is a key component of the PTI?
Bob:
That’s right, but I wouldn’t read a whole lot into that right now; the law also didn’t prohibit case-level tracking, nor did it mandate item-level tracking. The industry steering committee that developed the PTI back in 2008 settled on case-level tracking after looking at all the available options, and determining case-level tracking to be the most efficient, effective way to achieve the goal of whole-chain traceability. We think FDA will come to the same conclusion after looking at the matter themselves.
For example, we know from public comments that FDA official have made that the thing about traceback investigations that is giving them the most trouble is the lack of a common identifier as a food moves through the supply chain. They’ve also complained about the inconsistency of recordkeeping from company to company, and the amount of time it takes to access those records. The PTI addresses all of those concerns by establishing a common product identifier – the Global Trade Item Number or GTIN – and with standardized, computerized recordkeeping.
Meg:
Thanks, Bob. We’ll look forward to talking with you more about PMA’s work on FSMA implementation in future posts as that work gets underway. Let’s stop there for today, since I know we’re going to have Ed Treacy join us in the near future to give an update on the PTI.
Listeners, if you’d like specifics on the Food Safety Modernization Act – including a paper that covers more of the details on what it means for the PTI – please check out the PMA Resources section on PMA’s website on the Government Relations page. You’ll also want to check out our new online Food Safety Resource Center there. And for more information regarding the Produce Traceability Initiative, including tools to help you implement it within your company, visit the PTI website at www.producetraceability.org. Thanks for joining us…until next time!
Hello, this is PMA PR Director Julia Stewart, and welcome back to PMA’s audio blog, “Ask Dr. Bob” with PMA’s Chief Science & Technology Officer Dr. Bob Whitaker. Bob, we’re hoping all our listeners will be joining us when PMA’s 2010 Fresh Summit International Convention & Exposition convenes October 15 through 18 in Orlando. In your last post you mentioned the many workshops on food safety that will be presented at Fresh Summit. Will there be other food safety resources there as well?
Bob:
Julia, PMA has made food safety an important element of Fresh Summit for many years now, but this year we’re especially excited as we offer a high visibility resource for the topic right on the exposition floor in the form of our Food Safety Solutions Center. Located right on the show floor in booth 201, the center will be a convenient and easy way for many of our attendees to find out the latest developments in the area of food safety.
Julia:
So what exactly will the center provide?
Bob:
It’s designed to be a one-stop, interactive destination for food safety solutions. It will include educational exhibits, live demonstrations, and videos – all related to food safety technology.The topics we will cover include packaging, traceability, processing equipment, product testing, water purification and much more.
PMA really wants to help industry members get answers to their most critical food safety questions, and this center is one easy way we can accomplish that. It’s being sponsored by Famous Software and we very much appreciate their support and leadership.
Julia:
So what kinds of things can visitors to the center expect to learn?
Bob:
We’ll be holding live discussions and presentations that will tackle issues such as how investing in food safety can offer ROI to your business. We’ll also cover the latest food safety innovations, considering what products and services can address specific food safety needs.
The educational sessions we’ll conduct in the center will complement and expand on Fresh Summit’s food safety workshops that we talked about in our last post. I’m excited about the great line-up of topics and experts we have to address some of our industry’s most urgent issues right now. To give you an idea of what we have planned ….
The session “Pass With Flying Colors: The Value of Product Testing” will be a forum to share ideas and ask those burning questions that sit at the forefront of your mind. What are the problems with sampling either raw or finished products? What are the pitfalls of product testing? If anyone has asked these types of questions, then this session is for them.
On Sunday, “Threading the Needle: Successfully Navigating Food Safety Audits” is geared to provide answers to the key questions surrounding food safety audits. Participants can use this forum to hear first hand from experts in the industry, and get guidance and advice on topics such as costs and benefits, as well as the limitations associated with audits.
The session “Don’t be the Weakest Link: Your Role in Traceability” will offer an update on the Produce Traceability Initiative, the value it can offer your company, and help drive the traceability decisions you make for your company today. Some of the questions we will answer include, what are the benefits behind electronic traceability? What is the driving need for industry-wide implementation of traceability measures? This Q&A session is sure to be in high demand as our experts clarify questions surrounding traceability and what it means to individual companies.
Finally, on Monday, a session called “Experts with Answers: Learn How the Center for Produce Safety is Working for You” will explain the role that CPS is playing in answering industry’s food safety research questions and how you can get involved. We’ll also recap some of the critical research findings that were announced at CPS’s first research symposium in June. (Our listeners will remember from earlier posts that PMA founded CPS with Taylor Farms at the University of Davis back in 2007 to take leadership of industry food safety research, and that I chair the committee that leads its research program. CPS is already making a big difference to our industry.)
Throughout the show, Industry food safety leaders and PMA experts, including myself, will be on hand in the center to lead all the Q&A sessions. Of course, another value of the center is the informal opportunities it will offer to talk with other industry members about their food safety ideas, concerns and solutions.
Julia:
It sounds like the Food Safety Solutions Center will be a great food safety resource, I’m sure our listeners will want to check it out.
We should note that our food safety programming at Fresh Summit is made possible by the support of PMA members who contribute to our Gold Circle: Campaign for Food Safety. These members demonstrate their food safety leadership by contributing $1,000 each year above and beyond their PMA dues to support our food safety work. Their support underwrites the work of Dr. Bob’s food safety and technology team, our support of the Center for Produce Safety, new educational programs for small and local growers that we’ll talk about here soon. So thanks to our Gold Circle contributors for supporting PMA’s work. If you’d like to join our Gold Circle, you can read more on our website www.pma.com– just type “Gold Circle” into the search box on the home page.
Listeners, if you have a food safety product or solution, we invite you to become a Food Safety Solutions Center exhibitor, sponsor or advertiser. Contact PMA’s Dot Siegfried by email at dsiegfried@pma.com.
For more information on registering for Fresh Summit, the Food Safety Solutions Center, or any of the workshops, please log onto our website www.pma.com\freshsummit.