February 2022 - 26

TRACEABILITY
CONTINUED FROM PAGE 24
they would have said, 'We've assessed
it, it's too expensive. We're not even
going to talk about it.' At the same
time, there were a lot of other problems
they were trying to solve that were
pretty directly related to having better
processes in place for allocating product
to stores. What I mean by that is we've
had customers tell us that 'our fresh
problem is really an inventory problem,
because we don't have good visibility
into expiration dates, harvest dates and
how long something is going to be good
for, so we're not making the optimal
decision on what to move to stores. I
am a believer that this problem - and
I won't say 100% solved - but it is a
problem of allocation, and that's based
on accurate data coming into the retailer
or foodservice restaurant on product
coming in and where to slot it.
Athanassiadis: There are two basic
ways we're working with our customers
on this. We are working with our retail
customers to track lot-level detail out
of their DCs and into their stores using
our Insights Quality platform without
requiring additional IT investment at
their end. We have thousands of loads
of products going into our various
customers' distribution centers. We then
use our system to evaluate the quality of
the product they're receiving. That's the
first step in order for them to know what
product is coming, track through the DC
and then onto the store. Alternatively,
and perhaps more applicable to those
companies that don't use our platform,
we're working with them to familiarize
on how to use the voicepin code - the
four digits on the lower right of the
harmonized PTI label - as an alternative
means for lot-level tracking to an
individual store without having to scan
cases. ... Inventory pickers can use these
four digits, well, actually probably just
the first two digits, to quickly ensure
they're picking the correct produce,
therefore, enabling the inventory
management system to continue to
track lot-level detail for traceability and
advanced inventory rotation. ... We, as
software companies, need to work with
our customers to help them realize the
full value of the tools that they have.
Baggett: We've been working with
the PTI leadership team for a long
time. What we've seen from the growth
side is that they have the information,
they're recording it, they're preparing
to do it. It's been at the retail side
where we've had the breakdowns.
Some of the work we've done has
shown that some of the retailers are
still using POs and other means of
tracking, when the G10 has been out
there now for 10 years. While some
of them are slow to get there, I don't
want to dismiss that they've had the
time to get there. Now they have a date
they have to hit. Now they're going to
get serious about it because the FDA
is going to be coming down on them.
In some of the romaine recalls, they
didn't do it as a recall but an advisory,
so that shifted who paid for it. I think
that woke up the retailers.
Audience question: How
long will it take until we're all
speaking the same language and
using the same format on (the
data that needs to be shared)?
Todd, do you think PTI will
develop a standard for those data
elements in this?
Baggett: Given that the FDA has
said they're not going to give us the
very specifics, we've already done
some of that in a technology working
group. We did an experiment where we
tried a traceability Excel spreadsheet
looking at that as the easiest level that
all sizes of growers could accomplish.
I think the good news is that we will
be able to comply with this and we
will be able to get the data elements.
It will be something, as an industry,
we need to agree upon. One thing we
heard from the FDA loud and clear
is when they get the data in multiple
formats, the processing time goes up.
When there is food that is potentially
harmful, we need to get that out of the
market as quickly as possible. Equally
as important is that we have that level
of specificity so that we're not recalling
a whole commodity of product, that
we're to the point where we can say,
it's one, two, three or four of these lots
FDA's Food
Traceability List
(FTL)*
* Cheeses (other than hard
cheeses)
* Shell eggs
* Nut butter
* Cucumbers (fresh)
* Herbs (fresh)
* Leafy greens (fresh, including
fresh-cut)
* Melons (fresh)
* Peppers (fresh)
* Sprouts (fresh)
* Tomatoes (fresh)
* Tropical tree fruits (fresh)
* Finfish (including smoked)
* Crustaceans
* Mollusks
* Ready-to-Eat Deli Salads
*Also includes foods that contain
any listed
that came from one or two of these
growers. Otherwise, the burden on
these growers is just too big. We've
seen the stats that the average recall
costs $10 million.
Information on the proposed FSMA
204 can be found at fda.gov/food/foodsafety-modernization-act-fsma/fsmaproposed-rule-food-traceabilty.
FGN
26 | FruitGrowersNews.com

http://www.fda.gov/food/food http://www.FruitGrowersNews.com

February 2022

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