"It's not my fault and I can prove it"

Thoughtful testimony at the Nov. 13 traceability hearing in Oakland from Richard Ross of Tracegains Inc.....



FDA Product Tracing Systems for Fresh Produce
Oakland, California
November 13, 2008

Let me introduce myself. I’m Richard Ross and I’ve been in the agricultural commodity business for thirty years and managed 14 food businesses while with Archer Daniels Midland and ConAgra. I’ve been through recalls and I know your pain.

I have listened to FDA inspectors after each of these high-profile food recalls, and what they hear from grower-packer-shippers is “it’s not my fault.” Wouldn’t these same FDA inspectors like to hear “it’s not my fault and I can prove it!”? The grower-packer-shipper community has within their grasp the ability to make this type of “get out of jail free” comment. Given today’s technology, this goal isn’t out of reach, and I’ll get to that in a moment.

I brought this spinach from my hotel kitchen. I asked the person responsible for receiving shipments into the kitchen what box it came from and who delivered it. The response was, “I don’t know”. I asked, how many deliveries of vegetables the hotel got a week and he said every day, but he didn’t know which day this spinach was delivered. With multiple deliveries, unmarked boxes, comingling and the anonymity of the grower-packer-shipper, we have in place a dangerous, slippery slope. One way to get more traction is to really enforce the Bioterrorism Act. Really enforce the requirement that each member of the supply chain be able to know with certainty from where they received a specific product. The ability to truly understand this information is available today using the services of private companies such as mine, TraceGains.

How is that achieved you ask? Our solution is unique in three distinct ways:
1. You know that traceability is more than slapping a label on a box. You can track and trace rework, repack and reboxing. These are the main difficulties of the investigation of the tomatoes and peppers this summer costing an estimated $150,000,000 or more to the Florida growers.
2. Second our software has the ability to make traceability not only pay for itself, but add profits to the grower-packer-shipper. Traceability must be a profit center, not a cost.
3. And most importantly, you could have answers in seconds. As you have discovered, produce is not a supply chain, it is a supply network. The interoperability of TraceGains would allow you to traceback quickly, letting you save time, money and potentially lives.

Speedy, complete traceback, making more money and allowing companies that have full traceability systems to stay in commerce, that’s the best answer I’ve heard.

“It’s not my fault and I can prove it!”
Would you be interested in accomplishing your work doing something like this?

Richard Ross
Director of Industry Relations
Tracegains Inc.