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Pundit’s Mailbag — CPMA & PMA To Lead Industry Closer To Global Traceability

Few issues will wind up being more important to the produce trade than traceability, because nothing else holds the promise of containing food safety or food security issues so that the impact on the trade is minimized.

As such, we have devoted substantial attention here at the Pundit to the issue, including pieces such as these:

Much of the trade’s actual knowledge about traceability in the produce industry and the specific problems the trade has relates back to a joint endeavor by the Produce Marketing Association and the Canadian Produce Marketing Association, which was published as a Traceability Best Practices document for the North American fresh produce industry.

So we were especially pleased to receive this letter from an important executive at CPMA:

Over the past few months, we at CPMA have noted the marked increase in the focus on traceability within industry press and have applauded the Perishable Pundit’s efforts in this area to ensure readers are kept abreast of this important issue for our sector. In addition, we applaud the increased efforts by individual companies to facilitate traceability implementation as a tool to support overall food safety efforts. The purpose of this letter is to provide information to your readers on current efforts to ensure a global traceability standard and implementation guidelines for the produce sector.

To address the need for a standardized approach to traceability, industry stakeholders brought together first under the CPMA/PMA Traceability Task Force, and then internationally through the International Federation for Produce Standards (IFPS), have spent the past few years determining guidelines to assist industry in implementation. Additionally, we have participated in the global effort, under the auspices of the global supply chain standards body, GS1, to create the generic Global Traceability Standard which ensures consistency across international borders; especially important for our very global industry.

We are happy to report that CPMA and PMA, representing both our stakeholders and the five other international produce associations of the IFPS, recently met with GS1 to begin work to establish a global traceability fresh produce implementation guideline compliant with the Global Traceability Standard, robust enough to address the main international regulations and flexible enough to be adaptable to local regulations as well as all fresh produce categories. The basis for this effort is the PMA/CPMA Fresh Produce Traceability Guide to Implementation, which is harmonized already to the Global Traceability Standard and has been endorsed by the produce associations within the IFPS.

This Guide to Implementation is exactly that: a guide to implementing an effective traceability solution. While including best practices that allow for traceability, it also focuses on the core element needed to track an item: a standard product identification number. This number comes in the form of a GTIN (Global Trade Item Number). Once the GTIN is established, the industry will have a number to reference what is being tracked or traced. The Guide also addresses other key elements needed for effective traceability. As an example, if you are a primary producer, the data to capture, store and share with your supply chain partners includes:

Buyer/Receiver ID
Lot Number
Product Description
Product ID
Unit of Measure
Shipment ID
Vendor/Supplier/Sender ID
Date of Receipt
Ship From Location ID
Ship To Location ID
Shipment Date

N.B. It should be noted that if the primary producer is the first participant in the supply chain, some of these data elements will not be applicable to them (i.e. Receipt Date).

As you’ve noted, PMA and CPMA are also leading efforts around standardized product identification and other areas, including determining the industry realities; necessary information to identify implementation pathways. Later in the summer, the results of a recent survey executed by PMA and CPMA will be released. The following are some points of interest from that survey that indicate the state of the industry relative to traceability:

Out of 128 produce suppliers participating in the survey:

  • 77% indicate they can track one step up the supply chain and one step back YET

  • 53% do not even have a number on their cases,

  • 33% use a generic number on their cases that will not uniquely identify them from another supplier,

  • only 2% use a standard GTIN number on their cases,

  • 39% do not have a number on their packaged items, and of those that do have a number on the item, only 46% use a number that would allow the buyer to trace back the item to a particular grower.

It is safe to draw the conclusion from this snapshot of industry that although some organizations have very robust traceability systems in place, there is still a great deal of work to be done to ensure a functional traceability capacity across the entire supply chain.

This is a critically important issue requiring an industry-wide solution. We encourage industry to look further into their current traceability programs to ensure their effectiveness throughout the supply chain. With a Canada/U.S. standard established, and the development of a global produce standard/guideline well in hand (working with additional industry associations and GS1), we are equally encouraged that others are working with industry to ensure and support implementation.

As we move forward we will continue to support implementation via educational opportunities and applaud the Pundit’s efforts to bring clarity to this very complex issue.

— Jane Proctor
Director, Industry Technology & Standardization
Chair, IFPS
Canadian Produce Marketing Association
Ottawa, Ontario, Canada

We appreciate Jane’s kind words regarding our coverage of this matter and we pledge to fight the good fight on this one. Alas, the results of the survey Jane mentions are most distressing, especially considering that in the U.S., at least we have a bio-terrorism law that legally mandates traceability. The fact that more than two-thirds of the industry either does not have a number on each case or uses a number that will not uniquely identify the supplier is almost inconceivable.

And the survey results, depressing as they are, are the least of it. One thing we have learned is that many who may have the “form” of traceability in place do not have the “substance.” For example, it is all terrific to be able to identify a source of product by a lot number, but if that lot number represents a consolidation of product from five different fields, its usefulness is limited.

Even being able to trace back to the precise moment a processed item came off a line is of minimal use, especially if the line isn’t stopped and sanitized periodically so that the knowledge of when an item came off the line also establishes a time stamp on the product that might be implicated.

We also have learned that collecting all kinds of data, important as that may be, doesn’t count for much if we don’t know exactly where that data is and if it cannot be easily accessed upon demand.

One wonders, also, if the survey results aren’t excessively optimistic in that many packers and processors may require their growers to sign documents attesting that the grower will maintain documentation and have it available within 24 hours if needed. So the survey respondents may think certain information is available, yet no drills or other tests are being performed to ascertain if these warranties are actually being done.

Outside of the big fresh-cut processors in Salinas that have gotten deadly serious on these issues, we still hear of many growers who sign what they need to in order to sell their product, and their record retention policy is a weekly prayer that their number doesn’t come up.

The fact that CPMA and PMA are working to see published a “global traceability fresh produce implementation guideline compliant with the Global Traceability Standard” is very important news.

Shippers have complained to the Pundit that the CPMA/PMA Best Practices document, valuable as it is, doesn’t go far enough. These shippers have asked for a document that they can hand to their technical staff and say, “program for this.”

It sounds like we might be on the verge of coming to that place. If so, the industry will owe a great deal to Gary Fleming and Jane Proctor, and to PMA and CPMA, for supporting this vital industry effort.

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