Another excerpt from the transcript of the Dec. 9 FDA-USDA traceability hearing. Elliott Grant of YottaMark says the PTI is farm to forklift:  item level traceability can finish the journey to the fork.

Next, we have Elliott Grant from YottaMark. Mr. Grant.

Thank you. Good afternoon. My name is Dr. Elliott Grant.  I work at Harvest Mark.We know a lot about food traceability. We've added traceability to over 1 billion items of food in the U.S. this year. If you've eaten strawberries, raspberries, watermelon, bagged salad, yams, onions, or grapes this year, there's a very good chance that you have had product with the Harvest Mark on it.

We have deployed more and case level traceability solutions in food than any other company in the U.S. combined. We're already in hundreds of farms across North America. Mr. Craig Wilson mentioned earlier today that Costco has consumer level traceability on melons, grapes, and strawberries.

We are very proud to be the primary provider of that solution to Costco, its suppliers and, of course, its members. And recently Kroger selected Harvest Mark for all their private label produce. Kroger knows a thing or two about what consumers care about. We even have an app for that.

We have an app that allows consumers to trace food right there in the store. So what? We believe at Harvest Mark that case level as described in the PTI and supported by IFT is a workable framework. However, we think that case level is not necessarily sufficient.

Case level is not farm to fork. It is farm to forklift. The FDA asked where the gaps are in the current guidelines. One, case level does nothing for the consumer's peace of mind for the consumer in their home. Secretary Vilsack recently exhorted consumers to know your farmer, know your food. Case level cannot achieve that because it doesn't reach through to the consumer.

In the event of a recall, item level ommunication can communicate food safety status to consumers who are concerned and can provide additional data to regulators. The data collected by item level traceability can be extremely helpful. And just turn your attention if you would to the screen. I pulled a little bit of data from a point this summer which shows consumers tracing product across the U.S.

Bear with me a second. It's a little large. But if you play this, what this is is a snapshot of some of the data that we collect. Every one of those lines is a consumer tracing a product with the Harvest Mark code on it. Every time a consumer checks, we know where it was harvested, where it went, how long it took to get there, and what the product was.

As you can see from this map, we have thousands and thousands of data points, and when anyone asks, well, do consumers really care, I simply show them this to say absolutely. Imagine how helpful this data would be in the event of a recall trying to find out where product was shipped and critically where product was not shipped. We have this data.

It's interpretable, and it's all in a standardized format. In sum, case level traceability as defined by the PTI is very good, but we think it's not sufficient. We know the overwhelming majority of consumers want to know more about where their food comes from and they want to know it's safe. We believe that item level complements case level traceability, and it's very simple to deploy. It can, as you can see, carry data that the

FDA wants, date, lot, location, for example, and we can provide it in a standardized format to make it interpretable. In closing, I urge the FDA not to ignore the consumer and the power of item level traceability, and we encourage consumer level traceability where practicable. Thank you very much.