National Editor Tom KarstIf necessity is the mother of invention, then Twitter will eventually give way to publishing by brain waves. This would make putting together a blog quicker, if no more useful for readers. That is, unless my very thoughts could be transmitted to your brain… hmm.
In the meantime, follow me on Twitter @tckarst.
Check out a new poll at the Fresh Produce Industry Discussion Group:
Out of stock is one answer listed, but not the leading vote getter so far.
I had a good visit the other day with Elliot Grant, founder and chief marketing officer for YottaMark, Redwood City, Calif., on the subject of the Institute of Food Technologists Pilot study on food traceability.
After our phone conversation(which I used in Packer coverage), he was kind to summarize his thoughts in written form in an e-mail to me. With his permission, I’ve reprinted his thoughts below:
From Elliot Grant:
COMMENTS ON IFT’s RECOMMENDATIONS TO FDA
First of all, the IFT did a masterful job of corralling and executing such a complex project and delivered a clear, erudite and thoughtful report. HarvestMark was pleased to be selected as one of the few collaboration platform providers in the IFT study, and several of our customers participated as suppliers in the tomato program.
The pilots focused on the current state of traceability in the food supply chain – its speed and accuracy. While they found some companies had advanced traceability solutions, the pilots also observed sophisticated growing operations with shipments tracked by pen and paper. The IFT clearly demonstrated why external traceability is important even when companies claim to have internal traceability. The data collected in the pilots was inconsistent, incomplete, sometimes unreadable, incorrectly entered, incorrectly translated, and so on – slowing down tracebacks and undermining confidence in the results.
In our opinion, the most significant recommendations (of the top 10) for grower/shippers were that the FDA require standardized recordkeeping for all participants in the supply chain – with no exceptions for risk classification. These records would include Key Data Elements (KDEs) such as harvest date, SKU, and so for that each Critical Tracking Event (CTE) such as processing or packing. These recommendations are closely aligned with the PTI in our reading, and the IFT strongly urges the FDA to embrace the work already done by the industry. This is good news for suppliers who embraced the PTI early, and a welcome validation for all the companies and individuals who have contributed to making PTI a reality.
The recommendation stopped short of electronic recordkeeping, and instead concluded that the FDA will have to implement an electronic mechanism to acquire these CTEs and KDEs from participants in the event of a traceback investigation. This seems suboptimal to us – but we interpreted it as the IFT being constrained by FSMA’s allowance of paper based record keeping.
The IFT tackled cost-benefit. The costs reported were all over the map because they often mixed in RFID, ERP upgrades, and even warehouse expansions. We generally agreed with the assessment of growers who cited total costs of approx. 2 cents per case to implement PTI. Inexplicably, some pilot participants reported costs 50 times more expensive than others for the same solution. Guess it pays to shop around for a solution provider! (by the way … HarvestMark starts at $1500 a year).
This wasn’t a big surprise – but it was good to see it spelled out: there will not be a giant Government database in the cloud that everyone needs to send all their data to! “IFT does not advocate the establishment of a common “cloud”-based repository as a continuously standing collection of all CTE and KDE data captured across the supply chain. The information system envisioned here would be managed and hosted by FDA and collect only CTE and KDE data related to past or current outbreak investigations.”