Saturday, October 17, 2009

FoodTRACE vs. PTI - Dollars and Sense

Why FoodTRACE® vs. PTI?
Here are just a few reasons……..
1. Cost - PTI estimated at 10 to 20 cents per carton---- FoodTRACE® less than a penny per carton
2. No infrastructure changes – companies already have what’s needed
3. Implementation time – PTI, up to 2012 – FoodTRACE® - about 90 days
4. FoodTRACE® addresses imports
5. FoodTRACE® traces to item level
There is much more – email us at info@usfoodtrace.com with any questions or comments!

Review the following article that was in the Perishable Pundit recently as well….


Despite Progress Made, Feedback On PTI Reveals Real Problems

Our coverage of traceability has been extensive, and our recent piece brought much controversy. In fact some of the association folks weren’t all that happy that we ran the piece, expressing to us a wish that we had exercised “more discretion.”

Of course, when a person holding a responsible position in the industry is willing to sign his or her name to a letter commenting on an important industry issue, we would be doing an enormous disservice to our readership, and to the industry at large, to squelch such opinions.
And, in fact, one thing the associations need to look at concerning traceability now and also for future initiatives is how to do things like the Produce Traceability Initiative in an environment in which people feel free to speak the truth throughout the process.

Immediately after we ran Dan Sutton’s letter, we received calls from a number of mid-size shippers that wanted to thank us. The problem they felt is that, in their opinion, they had been de facto frozen out of the discussions. Large companies with prominent food safety experts can speak in these meetings without fear that anyone will doubt their commitment to food safety. So if Alec Leach from Taylor Farms or Jim Lugg from Fresh Express voice a problem with a proposal, it is clear that this is because there is a problem with the proposal.

In contrast, mid-size shippers are all too easily dismissed as not being concerned with food safety. So they tend to clam up in the meetings if they are there at all.

There was a well-attended workshop on PTI at the recent PMA convention. The workshop was supposed to be a kind of “nuts & bolts” how-to, yet the questions from the floor seemed more focused on “should we?” rather than “how-to.”

Now Gary Fleming, Vice President of Industry Technology and Standards at PMA, emphasized that “Should we?” is not really the question as, speaking of PTI, he emphasized that it was definitely happening.

He may be right, especially depending on what definition of “happening” one chooses to adopt.
Still, right or wrong, it is vaguely reminiscent of Richard Nixon declaring, “I am not a crook” — true or not, the fact that Nixon had to say it indicated he was in a lot of trouble.

Our sense is that the Produce Traceability Initiative is in a lot of trouble.

In the first place, the association of PTI with Mom and Apple Pie has simply made honesty impossible for many companies. We had a chance to sit down with several of the signatories to the PTI on the buy side; these were folks who had previously expressed concern about the initiative privately to the Pundit. When we inquired about why they signed, given the reservations they had expressed, we got basically the same answer from each: That their competitors had signed and that they didn’t want to appear not progressive or not caring about food safety and so they signed.

All have some kind of traceability programs right now and are thus in varying degrees of compliance with the initial stages of PTI, but none of them have appropriated the money to conform to the latter stages of PTI and tell us they have no definitive plans to do so.
There are also whole sectors of the industry that seem to have no intention of implementing PTI. Is there, for example, even one terminal market wholesaler who is doing anything to implement PTI?

There is a whole roster of technical issues: For example, some say field packers have problems with it, as do those who sell or receive mixed pallets.

Yet even if the technical problems could be solved, the signatories to the agreement actually spend the money to implement it, and if the sectors not participating in the agreement could be persuaded to join in, there is still a major question necessary to accomplish the realization of PTI: Will buyers constrain their supply chains to PTI-compliant product? No buyer has made a public commitment to do so and few, on either the buy or sell side, seem to believe it likely.
In other words, one can put all the scanners in and rewrite programs to accommodate GTINs but, in the end, if PTI-compliant product costs $8 a case and non-PTI-compliant product costs $7.50 a case, if the buyer purchases the cheaper product, the whole system breaks down.
Although cost is a major issue, there is also a major feeling that the whole thing is unnecessary. Part of it is the sense that those switching over to PTI already have excellent traceability. If one is selling direct to a major retailer, that is a pretty easy thing to trace. In many ways, the PTI is sort of backward, starting with the sectors of the industry that have the best traceability. Maybe we should have started with a bunch of small restaurants and local purveyors and built a system from there.

The other big question, repeated over and over again by shippers of every size, was whether all the specificity that the PTI aims for would actually make any difference. Imagine a shipper who is selling to Wal-Mart, say 10,000 cases a day. This shipper has to call up Wal-Mart and explain that 692 cases, identified with specificity due to the PTI, are possibly laced with E. coli 0157:H7 and are being recalled.

Will Wal-Mart, or any other buyer, accept the specificity of this case-level initiative? Or will they, to use the phrase ubiquitous in these circumstances, “err on the side of caution” and throw every box delivered that day or maybe every box from that shipper in the dump?
Remember the buyer will bill back any costs related to this recall or dumping to the seller, so what incentive does the buyer have to not be ultra-cautious? But if it doesn’t make a difference and buyers are going to dump everything regardless of the traceability system, then why is it essential to spend a lot of money to get down to the case level?

PTI is far along now and, good or bad, we doubt it will be changed much simply because we could not imagine getting industry consensus on an alternative. The degree to which it will actually “happen” is very dependent on what the government does. If the government leaves many options for companies, we suspect that various companies will use those various options. Big buyers such as Wal-Mart may demand GTINs and such for their own internal systems, but others will be more flexible and whole sectors of the industry will be on different systems.
Our real concern is that this process has revealed a problem that will arise again: The associations try to nudge the industry in a positive direction; the identification of the direction as positive creates PR difficulties for companies concerned about the initiatives, and this shuts off important feedback that the associations need to hear. This limitation of the feedback loop results in less-than-optimal outcomes, including “façade outcomes” in which consensus is thought to exist but actually does not.

How to avoid this is tricky. Clearly a demand for specific commitments that have consequences if not followed could surface some of the hidden problems. For example, the associations could have said, “We can’t ask producers to spend money on PTI unless they have an assurance that those who don’t spend money on PTI can’t under-price them, so we need a commitment from buyers to constrain their supply chain to PTI-compliant product, or we can’t proceed.” Such a declaration would have surfaced the actual willingness of the buying community to commit to PTI. It would have answered the question as to whether buyer commitment was shallow or deep. After all, a public commitment to vendors could result in lawsuits if the buyers renege later, so it would be a real measure of seriousness.

Beyond demanding commitments with consequences, there may be methodological initiatives that could help surface real feelings. Although meetings, e-mails and conference calls can seem to be good exchanges, perhaps methodologies need to be developed for people to submit anonymous feedback, even if for credibility sake we restrict the anonymity to members of a task force or board. Perhaps even votes on whether to propose something should have to pass an anonymous vote.

As an industry, we may want to consider consulting some game theorists to discuss how these negotiations can be designed to not only get an agreement, but to sustain complete and honest input throughout the process.

Another update soon as we finish gathering the results of our very successful test of the FoodTRACE® system!

Thursday, October 1, 2009

FoodTRACE Press Release

The following press release was issued on October 1, 2009 by FoodTRACE.


October 1, 2009
PRESS RELEASE – Condensed
FOR IMMEDIATE RELEASE


HEADLINE
FoodTRACE® launches electronic true traceability solution for the Produce Industry.

SUMMARY
FoodTRACE® announces the availability of its true traceability solution to the produce industry. The industry, the government and the consumer are all concerned over the continuing problems with food safety and now it is addressed in a more efficient and effective way.

BODY
ALM, Alternate Logistics Marketing ( www.almconsult.com ) and DRS&T, Del Rey Systems and Technologies ( www.delreysys.com ), both in San Diego, California, have completed two years of development collaboration, and testing resulting in the announcement of a critical application designed to address the two areas that need to consistently operate more efficiently in the case of a food borne illness event; traceability and epidemiology. The companies have created FoodTRACE® (www.usfoodtrace.com).
FoodTRACE® addresses these issues with their program that is currently being launched. The issue of traceability is addressed in the Bio-Terrorism Act of 2002 but those criteria have proven inadequate by themselves. However, companies currently complying with the Bio-Terrorism Act of 2002 already have everything in place in order to utilize the FoodTRACE® program and become part of an instantaneous traceability network. Companies can submit that data, electronically and automatically to FoodTRACE®. That's it. Whatever information a company is currently maintaining, in whatever format that it is in, FoodTRACE® can accept that information and create a single language for all. There is no software, hardware or numbers to buy, there is no additional personnel required, simply a low cost monthly fee, and FoodTRACE® does the rest….and all for much less than one cent per carton. FoodTRACE® also makes available at little or no cost, various custom designed reports to provide exception reporting and other trace-back or informational capabilities. This is especially valuable to smaller companies that can benefit from a variety of professionally designed traceability reports. Most importantly, in the case of an event, FoodTRACE®, within 24 hours of awareness of an event, will advise companies if they are potentially implicated, absolutely implicated, potentially exonerated or absolutely exonerated regarding all of the products that have been reported into the system.
"Other programs being offered to the industry currently require another number to be applied to every carton of product that is packed" stated Mike Domingos, President of ALM. "This is extremely cumbersome, expensive and difficult to maintain, ours is not”. John Granich of DRS&T commented, "Our program is affordable to all size companies and no infrastructure needs changing with ours. All companies have the capability of utilizing only our system or ours as an enhancement to other systems. Based on our conversations on the hill, with the FDA, CDC and others, we believe we exceed all current and anticipated coming requirements of the Government”.
FoodTRACE® is U.S. based as opposed to some others that are being offered. Summarily, it creates electronic traceability for food products, fully up and down the chain from any point in the chain, addresses epidemiology and works to protect both the consumer and the industry.

END

Contact: miked@almconsult.com (831-229-2331) jgranich@delreysys.com (703-851-0986)

Sunday, September 27, 2009

TRACEABILITY UPDATE

The following article was in the Packer last week...... The headline states that the FDA is waiting on more input...and they refer to the IFT report as part of that input.... If you are wondering what direction to go on traceability for the food industry, FoodTRACE is the only complete package available at a reasonable price to meet all current and expected government criteria. We continue to communicate with the FDA and others and our confident that we are ready to announce and release our program very soon.

Top Stories
FDA awaits more input on traceability solutions
Published on 09/21/2009 10:52am By Tom Karst

COLLEGE PARK, Md. — While praising the industry’s efforts on the Produce Traceability Initiative, Food and Drug Administration officials told the Washington Public Policy Conference that the agency continues to study the issue as it considers future guidance.

The FDA is trying to be more proactive in working with industry to determine distribution patterns of fresh produce items potentially linked to foodborne illnesses.

"We’ve had some real issues with traceback,” said Sherri McGarry, food safety official with the Center for Food Safety and Applied Nutrition. One specific challenge is trying to “connect the dots” of all the handlers throughout the distribution chain, she said. “Very often, growers will say when they know what we are receiving and what we send out, but we can’t link the
shipments up,” she said.

The FDA began talking with the industry in 2008 about product tracing technology. In addition, the FDA has contracted for studies on traceability, including one soon to be released report that examines industry practices regarding traceability.

That report will look at the costs and benefits of traceability, and McGarry said that study from the Institute of Food Technologists is expected to be issued sometime in September.
“Essentially, we really need to improve product tracing,” she said. McGarry also briefed attendees on the nature of produce outbreaks since 1996. From 1996 to 2008, she said that the FDA investigations have counted 77 foodborne illness outbreaks related to fresh produce and another 27 outbreaks attributed to fresh sprouts. Among other FDA-regulated food, that
compares with 207 outbreaks associated with eggs, 21 linked to dairy products, 37 tied to processed food and 114 connected with seafood.

The U.S. Department of Agriculture regulates meat and those statistics were not included in the FDA presentation. Meanwhile, McGarry said the FDA has estimated that fresh produce has resulted in the most confirmed illnesses during the 1996 to 2008 period. With 9,000 attributed illnesses, fresh produce compares with eggs (6,609), dairy (349) and processed foods (3,684) among FDA regulated foods.

Overall, fresh produce accounted for about 16% of foodborne illness outbreaks among FDA regulated products, but 39% of illnesses. Fresh produce accounted for 15 deaths from 1996 to 2008, she said. She said sprouts accounted for 5.7% of the outbreaks and 6.3% of the illnesses.
Among fresh produce commodities, she said leafy greens accounted for 34% of the outbreaks, tomatoes 17% and melons 16%.

For additional information regarding the FoodTRACE system...please email us at info@usfoodtrace.com.

Wednesday, September 16, 2009

DOLLARS and SENSE

There have been more questions than answers to this question and searching for an accurate answer is not easy but it is possible. There have been two publicly made statements regarding the cost of traceability with regard to the PTI.

One was made by the PMA in their submission to the FDA in early 2008. This refers to the cost to the industry as "hundreds of millions" of dollars and the submission indicated years to implement.

More recently on a webcast by Redline solutions, a major grower shipper representative indicated that the Redline solution would work and he estimated the cost of compliance to the PTI would be between $0.10 and $0.20 per carton.

That same company using the FoodTRACE system would pay LESS than 1/2 cent per carton for full compliance.

Although the PTI initiative won't be implementable for quite some time, FoodTRACE next week is running a live test for the purpose of final preparation of readiness for implementation. We will be tracing electronically product from Mexico, across the border into a U.S. facility, to a distribution center and on to stores.

Tuesday, August 18, 2009

FoodTRACE UPDATE

FoodTRACE currently keeps dozens of companies updated via email on a regular basis regarding traceability and the FoodTRACE program. If you would like to be added to the list, please email us at info@usfoodtrace.com. The following is an update that was sent out today to give you an idea of the type of information that is included in our updates which go out on the average of one to three times per month depending on the level of activity happening in traceability.

FoodTRACE® Update


The FoodTRACE® traceability program has made much progress since the last update.

There was obviously a flurry of news as the Food Safety Enhancement Act of 2009, called HR2749, was being discussed and finally passed through the House of Representatives. It will be brought up in the Senate probably sometime in September or October but as we all know the health issue has taken main stream currently.

To our knowledge, FoodTRACE® is the only traceability system that fully complies with every nuance that is currently written into HR2749 with regards to section 107 of the bill which addresses traceability.

Additionally, on July 7, 2009, during a press conference on food safety in Washington D.C., Kathleen Sebelius, Secretary of Health and Human Services (the cabinet department which oversees the FDA) made the following statement:

"In the next three months the Food and Drug Administration will issue draft guidance on steps the food industry can take to create tracing systems that will allow us to more quickly detect the sources of contamination and more quickly remove the unsafe food from store shelves".

Also, the IFT (Institute of Food Technologists) is close to their deadline coming up in September in which they are to submit a report to the FDA following a one year project to inform the FDA of various traceability systems available and supply their recommendations based on their study.

There continues to be recalls in produce as many of you are aware. In several cases, the recalls were initiated by the source as opposed to the government. In those cases, it is good to note that all the products that were recalled were done so timely and to the best of our knowledge accurately and efficiently. In 2007, the PMA surveyed 128 growers, shippers and 58 retailers…I was reading an old article in the Perishable Pundit that referenced a letter from CPMA that referenced that survey and a portion of that indicated that 77% of the companies surveyed CAN CURRENTLY track one step up, one step back on their products. That is an amazingly high percentage that should be used as a base and built UP from, not discarded to start a new program for every company in the United States for traceability.

Also, various estimates indicate that approximately 15% of the nations supply of fruits and vegetables are imported and on some fruits that number is in the 50% to 60% range. Vice President of the United States, Joe Biden, stated in the same press conference referenced above the following:

"The truth is it’s not unusual for us to snack on vegetables from South America, then pick up some fruit from the South Pacific and then go have a dinner with beef from Brazil”.

The message here is that when we consider traceability on fruits and vegetables consumed in the United States, we have to have a program in place that will accommodate imports as well as domestic products. FoodTRACE® addressed and resolved this issue in the initial development of our system. 100% of the bananas and pineapples for example are imported and they need to be traced just as importantly as does iceberg lettuce from California.

FoodTRACE® has collaborated with the University of Georgia to do a case study on the Salmonella Saint Paul event of 2008 which cost the tomato industry estimated losses of between $100 million and $250 million. The case study has been underway for several weeks at this point and we will update you when we have more definitive information on its finalization as well as the results.

Additionally we are scheduling a source to shelf real time trace back/trace forward project to trace product from a foreign country to a U.S. supermarket.

As a reminder, here are just a few of the highlights of the FoodTRACE® system….

· A centralized data base
· 24 Hour Traceability
· Department of Defense Security Levels on data
· Anomaly Detection
· Event Prediction
· Event Forecasting
· Access to your information in a variety of queries reporting levels
· Assistance with mock recalls
· Notifications of government requirements, guidelines, fees
· NO internal changes to your software
· NO hardware to buy
· NO numbers to buy

Easy to understand cost formula……..
1. A setup fee equal to your monthly fee
2. Monthly fee structure based on your annual sales
· Annual Sales <$5,000,000 $100 per month
· $5 to $10 Million $200 per month
· $10 to $25 Million $400 per month
· $25 to $50 Million $600 per month
· $50 to $100 Million $800 per month
· Annual Sales >$100 Million $1,000 per month

Reporting Locations over 1 @ $25.00 per month each

We will update you again soon …… Don’t forget to keep up to date as well with our blog -- www.usfoodtrace.blogspot.com
Feel free to leave comments on our blog or via our website www.usfoodtrace.com or simply by email to info@usfoodtrace.com.

Saturday, August 1, 2009

Food Safety Bill Passes on Second Round

One day after the food bill was brought to the floor of the House of Representative with a 2/3 required majority vote that failed.....it went again to the floor under a rules so that a simple majority was needed to pass the bill and it did pass. Now it will be on to the Senate, more committees, more hearings, more adjustments and the talk on the "hill" is that it might be up for a vote by the Senate possibly in late September but that is just talk. We'll follow it and update as it moves thru committee.

Wednesday, July 29, 2009

SPECIAL UPDATE: HR2749 Fails to Pass Today

The House of Representatives voted today on H.R. 2749, The Food Safety Enhancement Act of 2009 by 6 votes. The vote was as follows:

The electronic vote was: Yes: 280 No: 150 Not Voted: 4


The vote required at 2/3 majority which would have been 286 votes.
Further updates will follow as things progress.