The Packer’s Ashley Nickle's coverage of the E. coli outbreak linked to romaine lettuce from the Yuma region includes a recent piece headlined "Outbreak investigation puts spotlight on traceability."

In the story, Nickle talked about challenges in the traceback investigation:

The FDA has cited the cumbersome process of poring over shipping and receiving documents as the reason that traceback of the chopped romaine is taking more time than people might expect.

“Under (the Food Safety Modernization Act), it’s a one step forward, one step back rule, and so trying to find all those records, whether they be digital records or written records or handwritten records is extremely tough,” Stic Harris, director of the coordinated outbreak response and evaluation network of the FDA, said in a media conference call April 27.

“I think there’s a perception that, when we do traceback, that each leg is just a direct line down, and in this case you’re looking more at a web,” Harris said. “Ideally we’d love to get those mapped out and try and find convergence some place to try and identify that specific cause ... We’re just not there yet, and it’s entirely possible we may not get there — oftentimes we don’t — but we’re continuing to work on it.”

About 60% of produce cases have Produce Traceability Initiative labels, according to the United Fresh Produce Association.

It is expected that such labels, which carry a lot number, barcode and other information, enable faster traceback, though the FDA did not respond to a question about whether that has been the experience of the agency.

Some produce companies have implemented the system proactively, while others have done so at the request of buyers like Walmart and Whole Foods, said Ed Treacy, vice president of supply chain efficiencies for the Produce Marketing Association.

Other companies have not seen the need for them to implement the system yet. There is certainly some initial effort for a company to figure out where and how it will print and apply the labels, but the cost is not prohibitive, Treacy said.


It’s hard to believe it, but PTI was born more than ten years ago. Why is compliance only at 60% after ten years? In October 2008, I wrote this piece about the early plans:

A plan seeking voluntary compliance for standard traceability for the entire produce supply chain by the end of 2012 was announced by the Produce Traceability Initiative.

The initiative is a joint project of the Ottawa-based Canadian Produce Marketing Association, the Washington, D.C.-based United Fresh Produce Association and the Newark, Del.-based Produce Marketing Association. A news release from the group Oct. 7 said 34 of the members of the traceability steering committee (which numbered more than 40) signed the plan.

“This is a great example of the combined efforts and strengths of multiple associations, and I think that the joint members of the associations ought to be very proud of the work that the steering committee has done,” said Bryan Silbermann, PMA president.

 The plan will be presented to all sectors of the produce industry in the coming months, Silbermann said.

“This is just the initial list of people on the steering committee that have endorsed this, and there will be a process that enables other companies to add their names to the list, and that will be updated once the Web site is up and running,” he added.

 Industry leaders said the plan will require expense but it is necessary.

“It is something that has to be done,” said steering committee member Alan Siger, president of Consumers Produce Co. Inc., Pittsburgh.

Siger said the initiative encourages the industry to create efficient traceability solutions for a safe food supply. He said the expense of the initiative will increase further down the distribution chain but there are no solid estimates of the cost of the project.

“This takes us one step further. We have traceability now. This allows us to become more efficient at traceability,” said Amy Philpott, vice president of communications for United Fresh.

Seven steps

 According to the Produce Traceability Initiative, there are seven steps the industry must take to achieve electronic traceability by late 2012:

  • Brand owners obtain GS1-issued company prefixes;
  • Assign 14-digit Global Trade Item Numbers to every case;
  • Provide those GTINs to their buyers by third quarter 2009;
  • By third-quarter 2010, brand owners will begin placing GTIN and lot numbers on case labels in human-readable form;
  • At the same time, they will provide those numbers in machine-readable bar codes;
  • Subsequent handlers scan and store the numbers on inbound cases in 2011; and
  •  Subsequent handlers can scan and store the numbers on outbound cases in 2012.


A decade later, has PTI been a game-changing boom or a underwhelming bust?

I asked the question to the LinkedIn Fresh Produce Safety/Traceability Discussion Group

Produce Traceability Initiative - Boom or bust?

Was the voluntary industry approach the right way to go for PTI? What is the future of PTI and traceability regulations from the FDA?

Here are a couple of responses so far:

JB: In my opinion the voluntary approach when dealing with food safety is always the best approach. And while we may not yet realize it, the standardized labeling systems developed through the PTI (which are currently implemented by a majority of the industry) will be used in whatever electronic systems are developed in the near future for industry use.

As I personally believe that a distributed ledger system (similar to a form of blockchain) will be developed through the land grant universities, we will need some form of standards for anyone to quickly make sense of the data. As the GS1 standards used in PTI provide the needed standards, we are much further ahead than we would have been without PTI.

CC: Based on the long cumbersome process that the FDA is going through to trace recent Romaine outbreaks. You have to question the present value of this voluntary approach.


As Ashley’s coverage shows, the E. coli romaine story has resulted in a renewed focus on traceability.

Frank Yiannas, vice president of food safety for Walmart, tweeted (@frankyiannas) this 30 April with a link to Ashley’s column on the topic:

“Twelve years after 2006 Spinach outbreak, produce traceability still lacking. One step-up & one step-down is outdated for the 21st century. It’s time for end-to-end traceability enabled by #blockchain”

Is blockchain just another unreachable industry initiative, or something more? Does the FDA need to step in and mandate traceability for fresh produce?

What’s your view? Has PTI been boom or a bust, or something in the middle? And more importantly, what is next?