Traceability meetings - FDA and "challenges" with fresh produce

A United Fresh member communication published this link to an FDA document detailing upcoming traceability meetings. Go to the link to see more detail on the meetings, which will occur Oct. 16 in College Park, Maryland and Nov. 13 in Oakland, Calif. Here is an excerpt from the FDA notice about the "challenges" of fresh produce:



D. Challenges Associated with Traceback Investigations of Fresh Produce
The supply chain for a given type of fresh produce may be very complex. For example, several growers might supply their produce to a packer or distributor, and there may be multiple distributors who receive the product before its sale to or use by the ultimate consumer. Growers may send their 10 produce to several packers or distributors, and suppliers may obtain produce from several packers or distributors as well as directly from growers. Parties in the supply chain may be within the United States or abroad; thus, produce might be imported into or exported from any point in the supply chain one or more times. Other parties in a food supply chain may include processors of fresh produce, who may chill it, cut it into smaller pieces, or combine pieces of fresh produce with other foods to make another food product (such as using lettuce to make a salad). Contamination can occur at almost any point in the fresh produce supply chain. In some fresh produce supply chains, produce from multiple sources may be combined or commingled during packing or processing operations. This practice can complicate or even frustrate efforts to trace fresh produce throughout the supply chain. For example, a packing firm may buy a particular type of vegetable from multiple farms, and then sort the vegetables by size, color, quality, or some other attribute before packing into containers. As another example, a large truck may collect loose produce from multiple farms and then deliver the collected loose produce to a single processor or distributor. Even if we could trace a contaminated product back to the processor or distributor, or, in the second example, back to the packing firm, the commingling of loose produce before it reaches the processor or distributor or at the packing firm makes it difficult or impossible to distinguish which farm is the source of the contaminated produce. The complexity increases if the truck delivers the loose produce to more than one processor or distributor. An additional challenge associated with a traceback investigation for fresh produce is that the produce may not always retain the same description as it moves through the supply chain. For example, one party in the supply chain 11 may describe its fresh produce as "red round tomatoes," while the next party in the supply chain may describe the same fresh produce as "cooker tomatoes." Different descriptions for the same produce can make it very difficult or impossible to determine whether two records refer to the same or different products or shipments. Another challenge associated with a traceback investigation for fresh produce is that there may be no identifier on the produce, its package, or its case, and in associated records. Moreover, there currently is no industry-wide or sector-wide standardization of the information captured in the documentation. This lack of standardization makes it difficult and time consuming to cross-reference information currently available in product tracing systems.