One produce industry participant in the FDA-USDA traceability hearing on Dec. 9 was Greg Fritz of Produce Packaging Inc., Cleveland Ohio. Here is the transcript of his remarks, with Greg "keeping it real" about PTI.

MS. McGARRY:  Next is Gregory Fritz from Produce Packaging. Please come to the podium.

MR. FRITZ: Good afternoon. My name is Greg Fritz, and I'm the fourth generation in my family selling wholesale fresh produce in Cleveland, Ohio.

My company, Produce Packaging, Incorporated, is a tomato repacker and fresh cut processor. Since we serve national chain restaurants such as the Cheesecake Factory, Panera Bread, and Applebee's, our customers demand a very high level of food safety, including traceability.

We undergo many food safety audits annually and are constantly working to improve our plant and processes. Being a tomato repacker, our company suffered significant sales and profitability losses when tomatoes were wrongly implicated in the Salmonella scare last year.

The purpose of my coming to this meeting is to make sure you understand the impact to small businesses and a major potential fallout pending traceability legislation. As Dr. Gombas just mentioned, our produce industry associations have adopted the produce traceability initiative, or PTI, in an effort to have a uniform national traceability system. In my humble opinion, the PTI is a boondoggle.

However, earlier this year, one of my largest customers told me to comply with the PTI. So we've been working diligently to do so. Our company has always had its own traceability system in place which allowed quick and accurate one up, one back traceability at the case level. With PTI, we essentially are doing the same thing, but we've had to additionally do the following:

 Earlier this year, we purchased a manufacture number from GS1 that cost $8500 and then has to be renewed each year for $800. We purchased two laptops, printers, software, installation, and training at a cost of $10,000, and printing the new PTI compliant labels will cost our company an extra $18,000 a year just for the labels.

Over the next few months, we're going to begin work on implementing the final milestones of PTI, the scanning and record keeping portion. I estimate that will cost another $20,000 in up front costs. On top of all this, compliance with PTI is going to require a full-time equivalent employee to administer at a cost of at least $40,000 a year from now on.

For the last few years, my customers have been demanding to pay less in order for me to retain their business. They're not going to agree to pay more for traceability. They're basically demanding that I do it for nothing. I advocate the status quo, that is the simple requirement of one up, one back traceability that's essential and cost efficient. However, I can see the writing on the wall, and if PTI must move forward, its cost burden must be lessened. My company employs about 120 people whose livelihoods obviously depend on my company being profitable and competitive.

The way traceability legislation seems to be going, the harder it's going to be for smaller companies like ours to survive. Only the big boys will have the capital to invest and the ability to absorb all the extra costs. Another major flaw in new food safety legislation might be exemptions from traceability compliance. If a farmer company is too small or local to be required to comply with the traceability standard, that is if it claims compliance with PTI would be overly burdensome, should they be permitted or trusted to offer their product to the public at all?

If the spirit of the national traceability standard is to protect the public from contaminated food, why should anyone be exempt? Traceability either has its merits or it doesn't. If it does, then everyone must comply as any food safety incident, be it limited or widespread in the scope, impacts our whole industry.

 If my company has to be forced to spend relatively exorbitant amount of money to comply with the national traceability standard, when we already had an excellent one in place, then all produce suppliers and receivers, be they farmers, repackers, wholesalers, retailers, restaurants, whatever, should have to do the same regardless of their size.

Again, food safety incidents and scares, be they real or imagined, affect our whole industry. The Government must not consider any produce traceability standard that would exempt any size company or farmer whose contaminated product could harm anyone and affect the whole industry. Thank you.