WASHINGTON, D.C. — Fresh produce industry representatives urged the FDA to strictly enforce its guidelines for maintaining one up and one down traceback records but not to impose new traceability requirements Dec. 9-10 in meetings with government agencies at the U.S. Department of Agriculture.

Produce industry stands firm on traceability enforcement


Trying to find ways to improve traceability and speed responses in outbreaks, parties agreed on the need to form a better working relationship to close communication and information gaps.

“The agencies have some real needs for traceability that the industry has to be able to fill,” said David Gombas, senior vice president of food safety and technology at United Fresh Produce Association, Washington, D.C.

“There needs to be a standardized process for every company so that they know what those records are, they know where they are, and they can put their hands on them very, very quickly.”

In his public comments, Gombas told the agencies that traceability is an industry standard, and the Food and Drug Administration should leave it to the marketplace instead of imposing rigid restrictions.

Dave Elder, director of the office of regional operations for the FDA agreed, saying, “The industry knows their customers.”

Elder urged the produce industry to improve recordkeeping so that data is more useful during federal investigations.

He suggested standardized digital distribution systems and records, better use of retail purchasing information such as shopper cards and clearer and more meaningful product coding.

“Paper-based systems … present the greatest challenges for accuracy, completeness and timeliness,” he said. He also praised the effective use of shopper cards to inform purchasers of recalled foods.

A panel representing the consumer later highlighted the public support for traceability initiatives and noted that consumers desire more information about imported foods.

David Plunkett, senior staff attorney for the Center for Science in the Public Interest, Washington, D.C., said studies show consumers would pay a premium for traceability if it were associated with quality assurance.

“The market does not have what you need to drive traceability,” he said, adding that food was up to one-third more costly because “we elected not to do safety to the extent that we perhaps should.”

In a 90-minute comment period, traceability company leaders summarized their traceability solutions while encouraging the FDA to support item-level traceback.

Meanwhile, some industry representatives called into question the heavy cost of item-level traceability technology for small growers.

The PTI is case level, but some traceabilility products companies are pushing item-level traceback because of consumer demand.

Gregory Fritz, president of Produce Packaging Inc., Cleveland, called the Produce Traceability Initiative a “boondoggle” that creates an excessive cost burden for small businesses.

Fritz described new costs to adopt a traceability program to meet customer requirements including $8,500 to purchase a GS1 number; $800 to renew it yearly; $10,000 for new computers, printers and software; $18,000 a year to print the labels and a full-time staffer salary of at least $40,000.

“The last few years, my customers have been demanding to pay less. They are not going to agree to pay more for traceability,” Fritz said. “I can see the writing on the wall, and if PTI must move forward, its cost burden must be lessened.”