Here is the letter from Joel Nelsen of CCM to United Fresh and PMA about
traceability sent earlier in March. Here
is news coverage
generated from that letter. How does Nelsen's letter
resonate with the broader concerns of the industry about PTI?




March 5, 2010
Mr. Tom Stenzel, President 
United Fresh Produce Association

Mr. Bryan Silbermann, President
Produce Marketing Association

Gentlemen,

Since my last communication dated February 12 I have continued to review the PTI system proposed. How would it be implemented into our industry? Would it accomplish the objective or is there a better alternative? It was an extensive review coupled with a vast amount of reading on the websites speaking to the subject.

I have talked with Tom at his recent GR session and spoke with Terry on the PMA staff. I have read the Steering Committee press release and subsequent trade media articles. I have electronically communicated with several vendors on the subject.

 I have now concluded that the aforementioned proposal would have a tremendous impact on the existing systems within our industry both from an engineering, software and economic perspective without achieving any greater information than what is already available nor in any faster manner.

I have determined that the use of this system will not accomplish the traceability desired at the receiving station for our commodity. I do believe our industry has a system in place that can achieve the desired food safety goal. California Citrus Mutual therefore urges United and PMA to initiate talks with the steering committee to postpone the October 1, 2010 milestone for the fresh produce industry. I offer these brief bullet points as reasons:

Under the proposed system and because the vast majority of our shippers pack 10 sizes, three grades and in some cases different varieties of fruit daily to satisfy retail demand the volume of GTIN numbers demanded by our industry would be staggering. A vertically integrated grower shipper, of which there are five out of 85 shippers in our industry, would at a minimum require 8000 GTIN numbers.

A typical citrus shipper has 100-200 growers, multiple blocks and different varieties of citrus, to monitor in accordance with existing law. They each have a system that can trace back to the block and most are remarkably similar. The GTIN proposal would require each one to have at a minimum 10-15,000 GTIN numbers. Multiply that number by a minimum of 75 shippers.

My earlier estimate of a $25m expenditure for our industry is conservative. There are no guarantees that the data could/would be accepted at receiving point. Already receivers have a one year delay in accepting the data. Already receivers are contracting with single vendors to impose their system. This is not uniformity and in fact is creating another cottage industry similar to the food safety audits imposed on producers. Examine your own publicity. One photo shows a truck of citrus.

The photo is misdirection in that the methodology portrayed is fruit leaving the packing house destined for the juice plant. Our fresh citrus is not handled in this manner and both fresh and processed can be traced back to the grove. All of your publicity depicts bulk product displayed at retail. Where is the identity for the product? A case stamp details the information desired but the product loses it’s identity at retail and at the consumer level under the present system.

The RFID technology only follows the location of the carton/case, not necessarily the product. Why must receivers have this detailed information when in fact their need to know is the origination of where the product was processed? The burden then falls on the shipper to produce, according to existing law, the specific location in which the product was grown and harvested. That data and information flow already exists. GTIN promotion details the savings and efficiencies for “the system.”

The reality is that the program was designed to create more efficient inventory control for the receiver and had nothing to do with food safety. There is an assumption by vendors, consultants and receivers that the GTIN program can be modified into a one size fits all food safety approach for the entire fresh produce industry.

Again, I offer once again, the willingness to sit down and discuss the situation in depth with members of the steering committee. I have suggested that such a discussion take place at the United Fresh meeting in April. But because of pressures by vendors, perceptions by receivers and statements by the steering committee after the Dallas session we urge an immediate announcement that the October milestone be delayed to determine whether the approach is suitable for the entire industry.

Again, we have no problem with the goals and objectives of traceability for food safety purposes. In fact we believe we can show a better way to achieve that objective for this industry.

Cordially,

Joel Nelsen, President
California Citrus Mutual