PTI developing responses to traceability report

Two pilot projects to improve methods of food traceability have been completed and available for examination and comment. The Institute of Food Technologists (IFT) on behalf of FDA conducted the project, and its report includes 10 recommendations.

The report, “Pilot Projects for Improving Product Tracing along the Food Supply System,” was prepared as part of the Food Safety Modernization Act (FSMA) revision. A comment period is now open for the report, which will last until July 3. After the comments are received, FDA will submit its findings to Congress and develop a set of traceability rules as part of FSMA.

The Produce Traceability Initiative (PTI) is collecting industry feedback to prepare a response to each of the 10 recommendations. PTI is made up of the Canadian Produce Marketing Association, GS 1, the U.S. Produce Marketing Association and the United Fresh Produce Association. PTI has been working for more than five years to reach its goal of achieving whole chain case-level electronic traceability.

“The produce industry has been looking forward to these traceability recommendations to make sure that we can move confidently with the traceability best practices that we have collectively developed in the PTI,” said Mike Agostini, senior director, produce, Wal-Mart Stores, co-chair of the PTI Leadership Council. “Our industry community is excited to have the opportunity to delve into the details of the report and provide feedback to FDA.”

The pilot projects were designed to explore and demonstrate methods for rapid and effective tracking and tracing of food, including types of data that are useful for tracing and ways to connect the various points in the supply chain. 


“Many of us in the grower/packer/shipper community are pleased to see that the IFT recommends a uniform set of recordkeeping requirements, encourages current industry-led initiatives, and suggests the development of standardized electronic mechanisms for the reporting of traceability data,” said Sabrina Pokomandy, marketing and public relations manager at JemD Farms, who also co-chairs the PTI Communications Working Group. “These recommendations are in alignment with the goals and vision of PTI and help us move forward with industry-wide traceability implementations.”

The IFT pilot projects were designed to explore and demonstrate methods for rapid and effective tracking and tracing of food, including types of data that are useful for tracing and ways to connect the various points in the supply chain, according to FDA.

The 10 recommendations ask FDA to:

• Establish a uniform set of recordkeeping requirements for all FDA-regulated foods, and not permit exemptions to recordkeeping requirements based on risk classification. FDA issues guidance documents defining these requirements.
• Require firms who manufacture, process, pack, transport, distribute, receive, hold, or import food to identify and maintain CTE- and corresponding KDE-related records, as defined by FDA based on input from the food industry. CTE and KDF refer to various points in a supply chain where data capture is necessary to follow product movement.
• Require that each member of the food supply chain develop, document and exercise a product-tracing plan.
• Encourage and support industry-led initiatives for the development of implementation guidelines and seek stakeholder input by issuing an Advance Notice of Proposed Rulemaking or using other input mechanisms.
• Clearly and more consistently articulate and communicate to industry the information needed during a product tracing investigation.
• Develop standardized, structured, and electronic mechanisms for industry to provide CTE and KDE product tracing data when requested during a specific food safety investigation.
• Accepts CTE and KDE data sent in summary form through standardized and structured reporting mechanisms and initiate investigations based on this data.
• If available, request CTE and KDE data for more than one up – one down in the supply chain.
• Pursues the adoption of a technology platform to efficiently aggregate and analyze data reported in response to a specific request from regulatory officials. The technology platform should be available to regulatory counterparts.
• Coordinate traceback investigations and develop response protocols between and among state and local health and regulatory agencies using existing commissioning and credentialing processes. FDA would formalize the use of industry subject matter experts to address general questions about the characteristics of a particular supply chain at the outset of an investigation.

To access the IFT report, go here: 

To comment on the report electronically, go to the federal rule-making portal and follow the instructions.