ability to do this, while allowing each company to maintain its own internal traceability processes. It simply requires companies to augment their systems to include both
the GTIN and the lot number, which most already record, and to electronically store
this data in their internal systems.
The PTI action plan outlines seven key elements and milestones for implementing
the whole-chain traceability process. The associations also commit to providing information and educational resources to help industry members achieve the plan’s milestones by 2012.
1. Complete by Q1 2009 – Brand owners must obtain a GS1-issued company prefix.
2. Complete by Q1 2009 – Brand owners must assign 14-digit GTINs to all case configurations. The steering committee highly recommends that companies use the
number assignment strategy already created by the trade associations to minimize
the number of GTINs created and to
allow for consistency across industry segments.
3. Complete by Q3 2009 – Brand owners
must provide and maintain their GTIN
information (and corresponding data) to
their buyers.
4. Complete by Q3 2010 – Those parties
packing the product are responsible for
providing the GTIN and lot number in a
human-readable form on each case.
5. Complete by Q3 2010 – Those parties
packing the product are responsible for encoding the GTIN and lot number in a
GS1 128 barcode.
6. Complete in 2011 – Each handler of the case must read and store the GTIN and
lot number for every inbound case they receive.
7. Complete in 2012 – Each handler of the case must read and store the GTIN and
lot number for every outbound case they ship.
through and connect the dots between
multiple traceability systems of multiple
produce companies throughout the supply chain to make sure that all the details—such as number of boxes, brand
names, lot codes and ship/receive dates—
correlated exactly on invoices, bills of
lading and other such documentation.
While the grocery industry has had
electronic traceability for many years, for
a number of reasons, that has been more
difficult to achieve in the more diverse
“The [Produce Traceability Initiative] (PTI)
action plan…outlines
seven key elements and milestones for
implementing the whole-chain
traceability process.”
Another Foodborne Illness Outbreak
A year and a half after the spinach outbreak—and while the PTI steering committee
was elbow-deep in its work devising the aforementioned chain-wide traceability plan—
another foodborne illness outbreak made the news in May 2008, this time involving
Salmonella Saintpaul. Based on the Centers for Disease Control and Prevention’s
(CDC’s) in-house epidemiological investigation, FDA implicated certain types of
tomatoes. Eventually more than 1,400 people across the United States and Canada
would be sickened as the outbreak’s investigation dragged on for months before the
source—raw jalapeño peppers—was properly identified.
As the investigation spiraled, speculation surfaced regarding industry’s apparent inability to trace back produce as being behind the ineffective investigation. In reality,
FDA’s use of the industry’s trace-back information effectively traced tomatoes eaten by
sick consumers back to the farm. The problem was that those trace-backs kept pointing
to different farms, and failed to identify a common point where all of those tomatoes
could have been contaminated, whether at the farm or in repacking at the wholesale
level. In essence, trace-back worked; it just wasn’t confirming the tomato hypothesis
that the CDC had advanced from its initial epidemiological investigation.
Having said that, the industry’s traceability system was not entirely without problems. Because chain-wide electronic traceability has yet to exist, the FDA, in attempt
to follow a product through the supply chain from company to company, had to
translate each produce company’s proprietary tracking system and try to make it correspond to other companies’ proprietary tracking systems. Given that the Bioterrorism
Act does not mandate electronic record keeping and that FDA consequently is not
equipped to process trace-back records electronically, all trace-back records were requested and submitted on paper. Horror stories exist of field staff faxing hundreds of
pages of printed electronic records to FDA headquarters for someone to try to read
world of fresh foods such as produce.
However, the reality of today’s food
safety environment demands that the
produce industry move from paper
traceability systems to electronic systems. In order for traceability to work effectively as an outbreak management
tool, it remains imperative that a tracking system possess the ability to quickly
and accurately identify the product, locate the source, determine the amount
of implicated product and which shipments contained the implicated product
and then notify those who received the
implicated product—all within hours.
Still, while technology provides a
means toward that end, it is only a facilitator, not an end in itself. Both flawed
epidemiological marching orders at the
onset—an approach that relies on the inexact science of consumer recollection,
local health officials’ speculation and
federal protocol—and a bottlenecked
paper trail proved not to be conducive
to protecting public health.
Investigating the
Investigation
Nonetheless, in the summer of 2008
as the investigation into S. Saintpaul
lengthened, rumblings cropped up in
Congress and the agencies that the federal government should step in to man-
