Traceability

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Traceability And “Food Miles” notes the trend is for people to want to know where their food is from and who produced it. We already have traceability technology back to farm level. With today’s sophisticated computers, we should be able to tag each bunch of carrots, say, with a hang tag that tells who grew it, shows a picture of the farmer, gives its location, etc. 8/31/2006

Pundit’s Mailbag — Traceability Is Part Of The Food Safety Solution shared a note from Scott Cernosek from Primary Package, Inc. who comments on the European Community’s regulations on tracing food “one step and one step down”. In fact, he devotes a whole page on his company’s website to “track and trace” issues. One thing Scott is absolutely correct about is that in many cases we don’t have to reinvent the “traceability” wheel. The mechanisms are already developed in other countries. 1/25/2007

Guest Pundit — Traceability And The Need For A Common Language wanted to explore how technology could be used to enhance the industry’s ability to effectively trace products back to their source. We spoke with Gary Fleming, Vice President, Industry Technology and Standards at the Produce Marketing Association, who has been kind enough to contribute two Guest Pundit columns related to this important topic. Today we talk about the need for a common language to make traceback work. Tomorrow, we will talk about how to pair that language with technology. 1/30/2007

Guest Pundit – Pairing The Global Language With Technology continues our discussion from yesterday’s Guest Pundit –Traceability And The Need For A Common Language in which Gary Fleming of PMA explored how data standards could enhance the ability of the industry to trace products back to their source. Today we have an encore appearance from our Guest Pundit as Gary takes the industry one step further, exploring how that common language can be paired with technology and how doing so can bring the produce industry into a new, and more sophisticated, age. 1/31/2007

Pundit’s Mailbag — Traceability explains one of the problems with the draft Good Agricultural Practices document for spinach, lettuce and other leafy greens is that, although it requires people to retain a lot of documents, it doesn’t specify their retention in a form suitable for quick traceback. Usually we hesitate to run letters that promote one particular product, but this gentleman claims to have a solution. Certainly it is worth exploring. 2/1/2007

Traceability Calls For Enhanced Communications Language as part of our effort to find ways to enhance traceback we revealed another take on this issue sent to us by PMA. It seems that PMA is a member of something known as the Perishable Foods Coalition, and this group is working together to combat inefficiencies in the supply chain. Of course, these same efforts have a profound impact on our traceability efforts. 3/15/2007

Guest Pundit: Traceability — A Forgotten Piece Of Food Safety Gary Fleming, Vice President,  Industry Technology and Standards for the Produce Marketing Association has been kind enough to bring us another Guest Pundit focused on some findings he made during a trip to Argentina. It comes as a shock to most Americans, but quite often shippers in other countries are ahead of many U.S. shippers because these shippers often have to meet stringent requirements in order to be able to export. Here we share Gary’s take on what he found to be a practical traceability system used in Argentina. 4/12/2007

Mechanisms For Trace-Back And Trace-Forward Needed  asserts that the logical way to reduce the impact of any future foodborne illness outbreak is to limit its scope. This is what traceability is all about. As part of its leadership on traceability issues, PMA should develop a mechanism for these two things: The FDA and other regulators can never again be confused by who produces what brands, and we can never have recalls dribbling in for days because we don’t know instantly where our product went. 4/17/2007

Bruce Peterson Focuses On Traceability when the press release arrived advising that Bruce Peterson had entered into a collaboration with Michael McCartney, Principal of QLM Consulting, to promote a traceback effort for the produce industry, we wanted to find out more. We asked Pundit Investigator and Special Projects Editor, Mira Slott, to speak with Bruce. What is nice about this interview is to learn that Bruce, after having left Wal-Mart, still continues to focus on industry-wide initiatives. 6/8/2007

Pundit’s Pulse Of The Industry: Chilled Food Association’s Kaarin Goodburn comments how we here at the Pundit have scoured the world looking to learn what we can about food safety from other countries. Now we have asked Pundit Investigator and Special Projects Editor Mira Slott to speak with Kaarin Goodburn, Secretary General of the U.K.-based Chilled Food Association, who offers some insight into the UK’s built-in traceability. 7/4/2007

Getting A Better Grasp On Traceability discusses how our piece, Bruce Peterson Focuses On Traceability detailed this basic point: that the produce industry is more likely to reduce the negative impact of food safety problems by enhancing traceability than through any other single measure. To find out how we might make this happen, we asked Pundit Investigator and Special Projects Editor, Mira Slott, to speak with Michael McCartney Founder and Principal of QLM Consulting so we could better understand the collaboration between Bruce and Michael and so we could fill in the details about the challenges ahead. 7/19/2007

Pundit’s Mailbag – CPMA & PMA To Lead Industry Closer To Global Traceability relates how much of the trade’s actual knowledge about traceability in the produce industry and the specific problems the trade has relates back to a joint endeavor by the PMA and CPMA, which was published as a Traceability Best Practices document for the North American fresh produce industry. So we were especially pleased to receive this letter from Jane Proctor, Director - Industry Technology & Standardization with the Canadian Produce Marketing Association regarding our coverage of this critically important issue. 7/25/2007

Traceability Falls Short At Distributor Level explains that in the wake of the Metz Fresh recall, one thing that has become obvious is that traceability is breaking down. The problem is not growers and packers and processors as we have all been focusing on; it is local distributors and retail distribution centers. We need to really look at better traceability systems on this end of the business. 8/30/2007

Pundit’s Mailbag – When It Comes To Traceability, We Have The Technology mentions how our piece, Traceability Falls Short At Distributor Level, pointed out that many products lose their unique identity — and thus their traceability—when they get slotted at foodservice distributors or at retail warehouses. This makes recalls far more difficult and expensive. Two wholesaler/distributors, Alan Siger of Consumers Produce Co. Inc. of Pittsburgh and Scott Danner or Liberty Fruit Co. Inc., wrote to remind us that this failure is not one of technical capability. 8/31/2007

Pundit’s Mailbag — Increasing Concern Over Food Safety Vulnerabilities explains it is not necessary for the whole industry to collapse or even for a whole commodity to collapse because of a food safety crisis. The key is improved traceability solutions so that regulators and consumers will feel comfortable that any known problem is contained. Nothing the industry will do is likely to prevent all future outbreaks of food borne illness. But while acting to minimize outbreaks, we can do many things to improve traceability and thus limit the impact of any issues that may arise. 8/31/2007

Inspection Agencies Could Assist In Traceability explains that public health authorities have been critical of the industry for failing to maintain suitable traceability systems. As a result, millions have been spent and countless efforts are underway to enhance traceability. But the public health authorities could assist the effort. Everyone should be thinking about what would help traceability of a pathogen if it was found. 9/25/2007

PMA, CPMA And United Form Traceability Initiative the issue of traceability has been a top priority for the industry ever since the spinach crisis, when the urgency of food safety concerns was added to the long term interest in traceability for supply chain management, efficiencies, best practices, etc.  Now, in a rare joint announcement, Bryan Silbermann, President of PMA, will use the occasion of his annual presentation to issue a major call to action on traceability. In order to find out more about this important step we asked Mira Slott, Pundit Investigator and Special Projects Editor, to talk with some of the key players in bringing this about. 10/12/2007

Traceability Initiative Lacks Full Industry Representation suggests that the Traceability Initiative steering committee seems fated to produce at best a half-solution if it is not expanded to include the brokerage and wholesale sectors of the trade. The exclusion of whole industry sectors is a major oversight. If we don’t change the make-up of the panel we are going to wind up with an “industry solution” that won’t apply to a big chunk of the trade. Traceability only works if we start with the seed and end with the consumer. 11/30/2007

Pundit’s Mailbag — Traceability Initiative Requires Broader Base Of Participants shares a letter from Nelson Longenecker, Vice President - Business Innovation at Four Seasons Produce, Inc. who confirms that wholesale/distributors have something to contribute to the discussion of the industry’s new Traceability Initiative. The initial list of steering committee members reveals some gaps. Fortunately, there is adequate time to fill them. We can and we should. 12/4/2007

Traceability Group Meets Tuesday reports that today marks the first meeting of the trade’s Traceability Initiative. It is a milestone for the industry and one The Pundit has been dedicated to preparing the ground work for, for a very long time. Includes links to our series of articles on traceability. 1/8/2008

Traceability Committee Cuts To The Chase For Workable Standards reveals that the three associations driving the effort — CPMA, PMA and United Fresh — have issued a joint statement: “Produce Traceability Initiative Steering Committee’s first meeting begins laying groundwork for industry-wide standards program”. So grab the tablets; the industry leadership went up the mountain and came back with four “key elements” for the trade. Let us look at the elements and what they really mean. 1/16/2008

Pundit’s Mailbag — Traceability Precision shares a letter from Dennis Flynn of Apio Inc., who wrote to us in response to our piece, Traceability Committee Cuts To The Chase For Workable Standards, requesting some clarification on what precision standard would be used for case identification. It looks like the Produce Traceability Initiative is working, as it seems close to developing some specifics on exactly what will be required by the industry and when it will be required — all in the cause of full traceability. 2/29/2008

Tomato/Salmonella Situation Cries For Improved Epidemiology shares insight on the tomato/salmonella situation from Dr. Jim Gorny, Executive Director of the Postharvest Technology Research & Information Center at UC Davis, who points out that as important as effective traceback may be, traceback, by its nature, can’t start until effective epidemiology has identified what the product is and where it was purchased. Of course, the great advantage for the industry of focusing on traceability is it is the part of the puzzle we can actually do something about. 6/6/2008

Pundit’s Mailbag – Look At Lot Size our coverage of the tomato/salmonella out break brought us a letter from James D. Still of the Moraitis Group of Companies who, after spending a couple of years in the traceability space, thinks the real issue is one of “lot size management”. He is 100% correct that the key to traceability is lot size. 6/10/2008

Retail And Foodservice Buyers Share Their Experiences shares our discussion with Maurice Totty Director of Procurement Foodbuy who, in reaction to the recent Salmonella Stpaul outbreak, says “Traceability continues to be the missing link. The amount of time it takes to identify the source is just too long.” Traceability remains crucial, but this particular outbreak reminds us that, as Dr. James Gorny explained, you can’t start doing trace back until FDA has done the epidemiology that tells us where the product was purchased. In this case, that took six weeks — just for New Mexico. 6/10/2008

Repackers and Traceability highlights one of the difficulties in doing traceback in the tomato segment is the role of repackers. There has been much talk about the role of these firms as a kind of “black box” in which product enters as a thoroughbred with clear traceable pedigree and leaves a kind of mongrel with parentage difficult or impossible to trace.  It is probably true that the trade’s traceability initiative, which we discussed both here and here, should pay attention to this link in the chain as it is equivalent to a “critical control point” on where traceability can fail. 6/17/2008

The Glorification Of Traceback comments that if you listen to the pronouncements of the FDA, you see them as heroes searching with great difficulty to trace back the Salmonella outbreak to its source. They are searching for 122 servings of tomato, within a time frame in which Americans consumed over four billion servings of tomatoes. We wish the FDA luck; we think traceback will be difficult but even more unlikely is actually learning anything useful if we ever do find the farm. 6/20/2008

Trace Back The Control Group learned that CDC was doing new survey work with people who became ill after June 1, 2008. What was shocking — and very disappointing for the produce industry — was word that even in this new investigation, CDC is not doing any traceback of the control group. Produce trade associations should be requesting that CDC add this to their methodology right now so that this new survey will be more likely to produce an answer as to the source of the salmonella. 7/3/2008

Consumer Watchdogs Ignore Current Outbreak In Pursuit of Predetermined Agenda reports The Center for Science in the Public Interest and the Consumer Federation of America held a press conference issuing this statement: “Emergency Regs Needed for Tracking Produce, Food Groups Say”. First, they issued an “urgent plea to Dr. Andrew von Eschenbach”, commissioner of the FDA, to issue an “emergency regulation” requiring “traceability for produce.” The first and most obvious thing is that whatever the problems with traceback, this outbreak indicates a problem with our public health system’s epidemiological efforts — not with traceback. 7/10/2008

State Health Departments Need Increased Level Of Competence doubtless the most prescient person in this whole Salmonella Saintpaul outbreak is Dr. Jim Gorny at UC Davis. Dr. Gorny foresaw that the focus would move quickly to traceback, although the real problem was epidemiology. Traceback is inherently limited as you can’t trace back what epidemiology has not identified as the cause. So even perfect traceback will not find you a jalapeño if epidemiology says the problem is tomatoes. 7/30/2008

Three Congressional Hearings Focus On Salmonella Saintpaul announces three food safety hearings to be held over the coming days. The first, focused solely on traceability, will be held by the Subcommittee on Horticulture and Organic Agriculture, titled:  To review legal and technological capacity for full traceability in fresh produce. 7/30/2008

Though Traceability Initiative Is A Big Win, Weak Links Still Exist examines how recently traceability was identified as a weak link in the food safety system during the Salmonella Saintpaul outbreak. We are not sure that the industry’s joint initiative on traceability, even if fully successful, is ever likely to achieve Bruce Peterson’s vision. Our take is that the basic design of the industry traceability system is a very good. The “paradigm shift” recognizing that traceability is best obtained with industry-wide standards rather than proprietary systems is a breakthrough. The accomplishment of this task force should not be underestimated. 9/9/2008

Is Tesco Defrauding Consumers? Promising Only Nature’s Choice Certified Product But Delivering Cheaper Alternatives? explains that retailers and large buyers dictate a set of standards to their vendors. The supply base is told to invest time and money to conform to these standards with the implicit promise of business from the buyer. Now, with value the watchword for retailers worldwide, this deal is disintegrating. From an industry perspective, the problem is clear: There are supply chain responsibilities in food safety, traceability and sustainability. Top producers in the industry strive to meet these responsibilities. Then, they are put in a position by many retailers of having to meet the price of vendors that have not met these responsibilities. The premise of Tesco’s Nature’s Choice program is that part of the value equation is safety, sustainability and traceability — if Tesco wants to offer cheap product that has not been audited for adherence to this standard, they need to inform consumers that when they buy this particular product, they are not getting all the assurances they usually do when shopping at Tesco. 1/22/2009

Is Produce Traceability Initiative Worth The Investment? reprints a copy of a letter that a Midwestern firm sent to David Gombas, Senior Vice President of Food Safety and Technology, United Fresh Produce Association, critiquing the Produce Traceability Initiative. We find this letter interesting because it raises three often overlooked points: First that it focuses on the consumer. Second, it questions the sincerity of this effort pointing out that despite the trade’s supposed commitment to food safety standards, these standards are regularly waived for local growers. Lastly, he asks what evidence there is that investment in this traceability initiative is the best use of scarce resources. So why not abandon this effort as our correspondent suggests? 1/29/2009

‘Professor’ Bruce Peterson Talks About Traceability, Immigration, Transportation and Water Utilization discusses how since its founding, the Pundit been honored to play a role on the faculty of the United Fresh/Cornell University Produce Executive Development Program. Each year’s iteration is a unique variation on the theme. This year, one of the special aspects of the program is that we are bringing in both Bruce Peterson and Bruce Knobeloch. We did think it would be nice if we could offer a sneak peak into the insight that will be gained by participating in the program. So we asked Pundit Investigator and Special Projects Editor Mira Slott to speak with Bruce Peterson who tells us that: “Immigration is still a major political problem. There has not been meaningful change, but economic problems of the country have taken over.” 2/11/2009

Pundit Mailbag— Joint Response To Produce Traceability Cost Concerns finds it a happy coincidence that we run this letter from the three national associations that have shepherded the Produce Traceability Initiative on the same day we run an interview with Bruce Peterson. For it was out of Bruce’s insight expressed in an earlier interview toward limiting the scope and damage of outbreaks that the industry focus on traceability arose. We have praised the outcome of the Produce Traceability Initiative, even while acknowledging it was not a panacea. We are skeptical that companies on the buy-side will, in the end, constrain their supply chain to those in conformance with the PTI requirements and, even if they do, large parts of the industry operate in a netherworld far from these association initiatives and the mandates of big corporate buyers. 2/11/2009

Pundit’s Mailbag — How About Subsidy Money For GTIN Conversion? recalls running many pieces on traceability and most recently we ran two articles based on a letter that Greg Fritz, President of Produce Packaging, Inc., sent to United Fresh Produce Association regarding the Produce Traceability Initiative and the response from United, PMA and CPMA in to that letter. The two pieces dealt specifically with the cost concerns for many companies of adopting the PTI. Now we have a letter from a frequent Pundit contributor Eric Schwartz President of Salyer American Fresh Foods suggesting an alternative. If in Stimulus Bill II someone can slip in a little technology money for the produce industry well, why should the produce industry be left out? 2/19/2009

Continuous Tracking Study Of Consumer Attitudes Shows Eroding Confidence In Food Safety saw that in the course of an editorial on food safety drawing on a new study of consumer attitudes toward the safety of the food supply, the editors of the Star Tribune elected to quote us discussing the relationship between this decline of public confidence and the inability of the industry to quickly trace-forward all the affected products. We were intrigued by this new study, particularly the fact that it is a continuous study of consumer attitudes, whereas most studies are only episodic. We asked Pundit Investigator and Special Projects Editor Mira Slott to find out more from Jean Kinsey, Co-Director of the Food Industry Center and Professor in Applied Economics at the University of Minnesota and Principle Investigator on the Continuous Consumer Food Safety/Defense Tracking Study. 3/12/2009

Insights On The Alfalfa Sprout Advisory reveals the FDA has issued a consumer advisory not to eat alfalfa sprouts. We turned to frequent Pundit correspondent Bob Sanderson to see if we can find a solution to this long running food safety issue with sprouts and asked Pundit Investigator and Special Projects Editor Mira Slott to see what we could learn. Bob is a real insider with deep knowledge of the business, and he has given us two very simple changes that could make a world of difference. One issue highlighted in our discussion is the blending of seed lots, which makes traceability almost impossible, so the practice should be halted. 4/28/2009

Alfalfa Seed Company, FDA, USDA And Supporting Cast Comment On Seed Withdrawal reminds that the alfalfa sprout industry is operating under an FDA recommendation not to consume since April 26, 2009. We discussed this issue in Insights On The Alfalfa Sprout Advisory. Then the FDA issued an “Alert,” identifying an epidemiological link between a specific seed supplier and the outbreak. We asked Pundit Investigator and Special Projects Editor Mira Slott to find out more from Lyle Orwig, spokesperson for the Caudill Seed Company. There are several points made in the interview we question. Mira also reached the person at USDA charged with seed regulations and testing, Dr. Richard Payne, Chief of Seed Regulatory and Testing Branch at the USDA’s Agricultural Marketing Service (AMS). Finally, Mira sought clarification from the Association of Official Seed Certifying Agencies, Chet Boruff, CEO of the Association of Official Seed Certifying Agencies (AOSCA). Our interview with Michael McCartney regarding traceability emphasized the importance of starting traceability with the seed. One doesn’t have to be a traceability expert to know that if you blend seed you make traceback more complicated. No one knows that the contaminated seeds came from one of two or three fields or farms as opposed to one. So blending seed is a really bad idea. 5/12/2009

Pundit's Mailbag — Mike Stuart Of FFVA Speaks Out On Ballantine And Buyer/Seller Relations received many letters on our recent piece, Did Wal-Mart Have A Role In Ballantine’s Fall?, which focused on the implications of the story for the future of the industry, including this one from Michael J. Stuart of the Florida Fruit & Vegetable Association. Mike asks the question precisely: “At the end of the day, how are these firms going to make significant investments in food safety, traceability, sustainability and other important industry initiatives if the profitability of the business is squeezed to the breaking point?  How are they going to survive at all?” The elephant in the room during the traceability initiative was simple: Would big buyers constrain their supply chain to vendors that conformed to the Produce Traceability Initiative? Or was this going to be another bait-and-switch in which producers were enticed to make investments by the promise of business, but, in the end, the business would only go to traceability-conforming vendors if they were also the cheapest? It is a sign of how difficult it is for suppliers and associations to deal with issues such as these that, in the end, everyone just declared victory and went home, without the buying community making any binding commitments. 5/15/2009

Pundit’s Mailbag — Retailers Should Pay For What They Say They Want our piece Mike Stuart Of FFVA Speaks Out On Ballantine And Buyer/Seller Relations brought several letters including this one from one of FFVA’s members, Tom O’Brien, President of C&D Fruit and Vegetable who comments that over past several years while retail prices have inched up, producer prices have inched down. The issue is not that retailers should always pay more, per se; the issue is that retailers should pay for what they say they want. If Wal-Mart wants to require Global Food Safety Initiative certification, or conformance to the Produce Traceability Initiative or companies deeply dedicated to sustainability — bully for Wal-Mart — but it has to take out of the competitive pool companies that don’t meet these standards so that those who have invested to do so are not forced to compete with producers in the soft underbelly of the produce trade. 5/21/2009

YottaMark Advisory Board Adds Bruce Peterson To Roster finds some individuals seem to always attract the interest of many in the trade. So it goes with Bruce Peterson. Now comes word that Bruce is involved with a new industry activity: “Bruce Peterson Joins YottaMark Advisory Board.” YottaMark is the leader in this field and with Bruce’s long time interest in traceability, this is a good place for him. Its marquee product is an item-level label. We do suspect, though, that its “item” orientation, as opposed to the Produce Traceability Initiative’s “case” orientation, is more in consort with whatever regulations the federal government may come up with in this space. We suspect that this opportunity to sync industry technology with any future federal regulation is part of what would make this opportunity appealing to Bruce. 6/23/2009

RPA’s RFID/RPC Study: Pathway To More Comprehensive Traceability? heard that the Reusable Packaging Association had done a study that implied there could be a dramatic reduction in the cost of RFID by utilizing tags multiple times on RPCs. We asked Pundit Investigator and Special Projects Editor Mira Slott to find out more from Jerry Welcome, President of the Reusable Packaging Association. We find RPA’s test results very encouraging as they do indicate economies may be available that will bring down the cost of RFID if we combine it with RPCs. It seems like some kind of traceability dream, but one could imagine some kind of industry database with readers everywhere feeding into it. So if product goes from a shipper to a wholesaler to a smaller wholesaler to a purveyor and even into a store or restaurant, one could imagine readers everywhere effortlessly tracking the RPC. 8/5/2009

Pundit’s Mailbag — Wholesaler’s Struggle With PTI And Real Life Situations a piece we ran in Pundit sister publication, PRODUCE BUSINESS on the issue of traceability and, specifically, the Produce Traceability Initiative (PTI) brought this letter from Jeff Pieracci Vice President of Galli Produce, a wholesaler in California. This letter strikes us as a particularly poignant and incisive window on an aspect of the industry often ignored in the councils that discuss industry affairs. Jeff’s letter points to small wholesalers and independent restaurants as just two of the big holes PTI leaves open in the traceability web of the produce industry. 8/11/2009

International Federation for Produce Standards (IFPS) – Potential Voice Of Global Produce Industry mentions that we have been pleased to exchange a few e-mails with Dr. Hans Maurer over the years and have been honored by the many links to the Pundit he has provided to the trade in New Zealand. We were pleased to see he had taken on the Chairmanship of The International Federation for Produce Standards. What, however, exactly is the IFPS? And what standards does it wish to see established? Why do we need such an organization rather than just ad hoc committees? We asked Pundit Investigator and Special Projects Editor Mira Slott to find out more from Hans who also touches briefly on IFPS’ work with GS1 on traceability and we link to their “traceability guide” here. 9/15/2009

Is PTI Too Expensive And ‘Untenable’? A Retailer Speaks Out in one of our pieces, Is Produce Traceability Initiative Worth The investment, Gregory J. Fitz, President of Produce Packaging, Inc., pointed out severe doubts that the Produce Traceability Initiative was worth the cost for individual companies. Now Dan Sutton, Director of Produce for Albertsons LLC, has written us a letter questioning whether it makes sense for the industry as a whole. It takes people of integrity to be willing to buck the flow and stand up and say what they think to be correct. If PTI is a good idea it will withstand the scrutiny of many skeptics. If it is not, the voices of those willing to subject the initiative to public scrutiny may save firms in the industry more than a small fortune. So we thank Dan for speaking out.  Now the question is what does the industry do with this input? 9/22/2009

Troublesome Traceability Letters From PMA Veiled As Being Sent From Buyers our recent piece, Is PTI Too Expensive And ‘Untenable’? A Retailer Speaks Out brought a substantial response. Although part of that piece dealt with substantive issues regarding traceability and, specifically, the Produce Traceability Initiative, the piece also raised questions about the proper role of trade associations in communicating with their members — specifically whether it is appropriate for associations to facilitate communication between select firms, in this case nine specific buying organizations that do not constitute any official board or committee, and their vendors and prospective vendors. One observant reader questioned the whole idea of associations using the names of their board members to scare people half to death. 9/29/2009

Tesco Goes LEED, But Is LEED Sustainable? finds Fresh & Easy has received a LEED Gold certification for a store in Cathedral City, CA. However, there is increasingly a question about whether the LEED certification process does anything useful at all. A recent article in The New York Times helps to illustrate the problem, and it quotes a New York City energy consultant who says a building's LEED plaque "should be installed with removable screws" instead of being glued on, giving incentive to do better. The consultant points to a general problem — applicable in traceability and other areas — with what are called “conformance systems.” These programs require a participant to do X to gets its certification; anything beyond that gets no extra credit. Wouldn't we be better off looking at “continuous improvement” models? 10/2/2009

PMA Convention Observations And Lessons For Produce Promotion observed that although the most common thread at this year’s PMA convention was definitely traceability, with every booth seemingly either selling a traceability system or claiming its products already had perfect traceability, for the most part it seemed as if traceability had just become the new marketing craze as virtually all these efforts had the same limitations: They worked fine on product being sold through an aligned supply chain in which everyone knew what to do and was committed to doing it. They worked not at all, however, if the product was sold through random people without commitment to a particular traceability system — or to traceability at all. 10/16/2009

Despite Progress Made, Feedback On PTI Reveals Real Problems declares that our sense is that the Produce Traceability Initiative is in a lot of trouble. Even if the technical problems could be solved, the signatories to the agreement actually spend the money to implement it, and if the sectors not participating in the agreement could be persuaded to join in, there is still a major question necessary to accomplish the realization of PTI: Will buyers constrain their supply chains to PTI-compliant product? Some feel case-level specificity won’t be relied upon in the event of an outbreak and so to “err on the side of caution,” major retailers will dump 10,000 boxes instead of only the few hundred identified as implicated. Is the positive consensus that is thought to exist actually a façade? 10/16/2009

Will PTI Put Liability Onus In Retailers’ Court? explains we've entertained many strong views on the Produce Traceability Initiative. We received a letter from Michael McCartney, Principal of QLM Consulting, in response to our piece built around a letter by Dan Sutton, Director of Produce for Albertsons LLC decrying the PTI's expense. Michael asks if buyers may want to reconsider resisting PTI, giving an example of a hypothetical farmer who, in the event of an outbreak, can prove, through flawless traceability and testing regimes, that his product is free of the suspected contaminate. His example gives us the opportunity to discuss the legal issues that will hamper a producer's claims. Michael ends his letter by raising two additional points — the cost of lives saved and brands preserved. A balance must be struck, and it is no easy task. 10/23/2009

Gary Fleming Speaks Out: Produce Traceability Series Part 1: ‘Absent Of PTI’ details how an important part of our coverage of traceability came from Gary Fleming who has recently resigned as Vice President of Industry Technology and Standards at PMA. Wasting no time, Gary has launched a new consultancy, the Symbolon Group. We reached out to Gary hoping he might contribute to the industry by speaking bluntly on the issue of traceability in general and the Produce Traceability Initiative in particular. He has been generous enough to contribute three separate pieces and we run the first here. We also thought it would good to get a little more insight into his purpose in leaving PMA and in his general thoughts on PTI. We asked Pundit Investigator and Special Projects Editor Mira Slott to raise some questions. 1/18/2010

Symbolon’s Fleming Sheds More Light On Traceability received another contribution to our discussion on traceability from Gary Fleming, formerly the Vice President, Industry Technology and Standards for the Produce Marketing Association, and now head of his own consultancy, the Symbolon Group. Here we present Part II of a series of three pieces by Gary that aim to help the industry think through the Produce Traceability Initiative. In this second series, Gary discusses what is happening in other sectors in the food industry that could have impact on what your company is doing. For Gary Fleming, there is something more than technique in his proposals; there is passion, a belief that not only is PTI right, it is also technically beautiful. 4/12/2010

Problems Persist With PTI finds the Produce Traceability Initiative seems to be somewhat stuck. Despite its many advantages, PTI does not actually solve the trade’s traceability problem, and the whole process with its elaborate stages was troubling to begin with because it put the grower-shippers ahead of the buyers. This was problematic. More than one buyer told this Pundit that they felt compelled to endorse PTI for political reasons. That didn’t mean they were actually going to spend the money to implement it. It is easy to see this situation as one simply requiring leadership to insist on the trade seeing through its plan. But it is also true that this whole episode has revealed a tremendous flaw in the way our associations are interacting with the membership. 4/27/2010

Freshway’s Traceability System Worked Like A Charm: FDA And Buyers Don’t Care finds that in the wake of the recall prompted by Freshway romaine lettuce, it is worth looking at the way food safety agencies and buyers react when there is both good traceability data and a foodborne illness outbreak. The short answer is they ignore traceability. Recalls don’t cost buyers anything; they bill all costs back to the vendors, so why take any risk that their own employees will leave an errant bag… better just to dump it all. 5/11/2010

The Great PTI Leadership Let-Down our piece, Problems Persist With PTI, brought a response from a man who has been in the forefront of the trade’s traceability efforts, Bruce Peterson, now President of his own consultancy under the name Peterson Insights. Bruce ends his thoughtful letter by saying it is a matter of leadership that has left PTI to drift, and we would agree.  To us, it has echoes of the discussions over proposals last year for a generic promotion order, an industry-wide proposal, which would have needed mass support to succeed, but was negotiated in secret and then “explained” to everyone. If great produce retailers and foodservice companies would have required PTI compliance, it would have become ubiquitous. Without that requirement, PTI is no standard at all. 5/11/2010

FDA’s Secrecy Causes Retailers To Overreact our piece, Freshway’s Traceability System Worked Like A Charm: FDA And Buyers Don’t Care, dealt with Freshway Foods’ recent recall and the fact that its traceability system did not stop government from imposing a broader recall and customers from throwing everything out. It prompted Dan Lasic, Quality Assurance Manager for the Compass Group NAD, to send this note in which he denounces the FDA’s lack of transparency during outbreaks and how it leads customers to uncertainty and overreaction. Dan is correct; the FDA is ridiculously opaque in an age of transparency. It doesn’t give the kind of “all clear” that the industry needs. 5/13/2010

Pressing The Reset Button On PTI saw that the executive committees of the Canadian Produce Marketing Association, Produce Marketing Association and the United Fresh Produce Association have come out with a joint statement supporting the PTI concept, eating a little crow as to how it was presented and making some minor changes to the deadlines. All in all it is a positive response, but the reality is that this is not a matter in the hands of the associations. Their deadlines and attitudes (although they can move things a bit one way or the other) are secondary considerations. There are really only two issues with PTI. 5/25/2010

What Is The ROI On PTI? notes that Gary Fleming has been a most valuable contributor to our coverage of the issue of traceability. Today we come to the final piece in Gary’s most recent three-part series for the Pundit. Short of a government mandate, significant portions of the industry will not move to adopt the Produce Traceability Initiative unless they are persuaded that there are benefits beyond those that relate to enhanced traceability in the event of a food safety outbreak. We wanted to see if there was enough here to give industry executives ammunition to go before their boards of directors and build an ROI-case for PTI. Gary rose to the challenge and sent us this piece. 5/25/2010

Pundit’s Mailbag – California Citrus Mutual’s Joel Nelson Weighs In On PTI explains how a fair amount of the public attention paid to the issue of traceability is a result of Joel Nelsen, President of California Citrus Mutual, deciding to speak out. Earlier this year he sent a letter to PMA and United expressing his concerns, and we reprint it here. Today Joel follows up with another note to the Pundit telling us that though the Produce Traceability Initiative does have problems, it is not yet finished. 5/25/2010

Richard Goldfarb Asks: Five Legal Questions About Traceability discovered that Richard Goldfarb, an attorney with Stoel Rives, who we’ve mentioned before, took the time to review several pieces we’ve recently done on traceability. After reviewing the articles, he wrote a piece titled, “A Traceability Story: Request for Comments”, which asked five important questions. Since he asked for comments, we thought we would give him some. We list his question first and our comment beneath each question. 6/7/2010