Chat - Ksenia Evdokimova

I was able to chat with Russia market rep Ksenia Evdokimova this afternoon. She is leading a big group of Russian importers to PMA, notwithstanding economic challenges in both countries....

4:08 PM me: Hi Ksenia are you there

4:09 PM Ksenia: Hi, Tom!

me: How are you? Do you have a coupla minutes to talk about the upcoming trip to PMA?

Ksenia: With pleasure

4:10 PM me: Tell me about the group that is coming to Orlando - mostly importers, I presume?

Ksenia: Well, we have recruited over 30 importers to come to PMA this year. I assume we will be the most impressive group from so far abroad.

4:12 PM me: That is a big number -- what's the mood of the import community over there since these big swings in the financial markets

4:15 PM Ksenia: Everyone is more careful with buying, not just from the U.S. but in general. We also expect some affects on the retail market (that was booming for the past years, but is currently facing obstacles with the credits taken for their expansion). More or less nothing serious has happened yet on the market. Probably late October/November will tell us more on how things are

4:18 PM me: Yes, there is a lot of caution it seems in the U.S. as well..how fast the market loosens up is an unknown.... do you think the falling oil prices will make consumers in Russia more price conscious and possibly look to smaller fruit faster than they would have before?

6 minutes

4:24 PM Ksenia: Consumers all over the World will be affected by the results of the crisis and Russian consumers will face same problems. There will be higher unemployment and less spare money. However, good news is that top Russian fruit importers are heading to Orlando next week and this means that they expect the market to stay profitable. Florida has a wonderful climate, but unless US fruits were interesting among the Russian buyers - they wouldn't have decided to come this season.

4:26 PM me: Ksenia, tell me about the logistics of getting such a large group from Russia to Orlando - when will you start and how long will it take? Where will you be staying in Orlando?

4:30 PM Ksenia: Group members are professional travelers, so it is best not to press on anyone with schedules. The plan is for most of the group to take a trip to California to see beautiful table grape vineyards, then head to Orlando, participate in all kinds of retail tours, educational seminars, receptions and after this explore the FL citrus groves.

4:32 PM me: Sounds like a winning plan. What are you personally looking forward to the most in your trip? Is there anything you "dread"?

4:35 PM Ksenia: Personally, I dream about seeing the whole group in one place together. It has been a lot of preparation and to see your group is a reward! Most unpleasant thing is if somebody gets in trouble, sick or lost - this can spoil mood.

4:37 PM me: Ksenia, what's the latest update on your company - what clients do you represent currently from the U.S.?

4:38 PM Ksenia: All the tasty stuff: California Table Grape Commission, Pear Bureau NW, US Apple Export Council as well as several other non-fruit friends

4:39 PM me: Very good. If we are lucky, we will see you and your group from Russia. Safe travels and good luck at the show

4:40 PM Ksenia: I hope so too. Now you know about the group - so won't be surprised where all these Russians come from. Expect them at the show and hopefully this show brings successful business! See you next week!

Comment on traceability - Robert Guenther and United Fresh

Arguing the industry does not need radical intervention in regard to traceability, Robert Guenther testifies at the FDA traceability meeting today.
Passed on by Amy Philpott of United.

Statement by
Robert L. Guenther
Senior Vice President, Public Policy
United Fresh Produce Association
U.S. Food and Drug Administration Public Meeting on
Product Tracing Systems for Fresh Produce
College Park, Maryland
October 16, 2008
Hello, my name is Robert Guenther, senior vice president of public policy for United Fresh Produce Association (United Fresh). United Fresh is an international trade association representing the fresh fruit and vegetable industry in managing critical public policy issues; shaping legislative and regulatory action; providing scientific and technical leadership in food safety, quality assurance, nutrition and health; and developing educational programs and business opportunities for members to better meet consumer needs for increased consumption of fresh produce. Founded in 1904, United Fresh represents the interests of member companies from small family businesses to the largest international corporations throughout the global fresh produce supply chain, including growers, shippers, fresh-cut processors, wholesalers, distributors, retailers, foodservice operators, industry suppliers and allied associations.
What I will focus on in today’s discussion is how traceability works today, and the strengths and weaknesses of the current product tracing systems in the produce industry. I also want to thank FDA for giving us the opportunity to present our views on the current traceability outlook in the produce industry.
Let me begin with a basic principle that I believe is shared throughout the produce industry – This industry is committed to being able to effectively and efficiently track the source of our products from retail stores and restaurants back to their original farm source.
It is well know, that the Bioterrorism Act requires mandatory record-keeping ‘one-step-up’ and ‘one-step back’ of all foods, with the ability for each person in the supply chain to provide such records within 24 hours. The industry is committed to full compliance with these requirements, and urges FDA to rigorously enforce this law. We know of no instances where FDA has taken any regulatory action to cite a produce company or its customers for failure to provide adequate records as required by the Act. Rather, we hear generalized concerns about the inadequacy of records, without specific examples. The produce industry stands ready to work with the Agency to ensure full and total compliance with these requirements.
Through the Bioterrorism Act the industry is also required by FDA regulation to maintain records that demonstrate the source – transporter and non-transporter – of all raw materials used in the production of foods ultimately offered for consumption. These records must include the material description, the supplier lot number, quantity and date received. The same law requires the industry to maintain records that demonstrate the recipient – transporter and non-transporter – of all outgoing products, including the material description, lot number, quantity and date shipped. The existing regulation exempts farms and restaurants, but the first commercial recipient of produce from the farm is required to maintain these traceability records, as are companies distributing produce to restaurants and other consumer points-of-purchase. As an industry, we support this regulation.
Packaged produce with brand names and lot numbers, such as bagged salads and branded cut fruit, are the most visible examples of fresh produce traceability. Lot codes may be proprietary company codes or serve double duty as "use by" or "sell by" dates, but all retail-available, branded, packaged produce is expected to have lot coding information clearly printed on the package, traceable back to specific lot information. That lot information is expected to include the source and lot numbers of the product’s ingredients, just like other formulated and commercially- available food products. We are unaware of any instances in which public health investigators, having a package in hand, have been unable to quickly and efficiently reach the company that packaged the product and obtain information about the product’s component ingredients. In a blended product, like a salad, it is likely that investigators will not know which ingredient is of special interest, and so would need to obtain source and lot code information for all ingredients; but that need for multiple commodity traceback is often unavoidable in an investigation and not unique to produce.
Repacking operations have been noted by FDA to be a special problem for produce traceability; however we do not believe that to be the case today. Repackers may receive fruit or vegetables, like apples or tomatoes, from several growers or packinghouses. Each incoming produce lot, because it is harvested at the same time, is likely to contain items of different sizes, colors, shapes and stages of ripeness. Repackers’ customers, on the other hand, want the produce to be the same size, color, shape, et cetera. This reduces waste, and storage by the customer, and is more cost efficient and actually safer for consumers than for retail or foodservice operations to receive and process single-lot product themselves. Repackers uncase incoming produce, sort, commingle and re-case the produce to meet customers’ orders. However, this is not unlike the blended product example I just referenced, with different suppliers of a common ingredient instead of different ingredients. Repackers are still expected to provide the outgoing cases with lot code information that is internally traceable to the produce lots used in that case. In the industry-developed 2nd edition Commodity Specific Food Safety Guidelines for the Fresh Tomato Supply Chain, recommendations to repacking facilities specify that "if incoming lots are mixed/commingled, then documentation shall be maintained to identify all included sources."
So, whether we are discussing packaged or whole commodity produce, the industry has procedures in place that provide traceability information from the farm to consumers’ points-of-purchase.
We expect that FDA finds diversity in traceability sophistication and compliance among produce facilities, just like it does in other practices across the food industry. Some companies have exquisite traceability programs, providing consumers with Internet-accessible information about a product’s grower and lot-specific analyses. Less sophisticated traceability programs may still utilize paper-based receiving and shipping records. Depending on the size of the facility, the complexity and volume of its distributions, such a program may be adequate for the facility and compliant with the regulation.
However, we do recognize that there are potential issues and opportunities for improvement in current produce traceability practices.
Common Language and Standards
As noted by PMA, produce companies today often use proprietary codes and labeling practices that fit well with their internal traceability and inventory control practices, but which are different from the codes and practices used by their suppliers and their customers. As a result, codes must be "translated" as they move from one point in the supply chain to the next. In the event of a traceback, investigators must move along the supply chain in a linear and sequential fashion, relying on each point in the supply chain to accurately translate the customer’s codes into the suppliers’. Late last year, our Association along with Produce Marketing Association and Canadian Produce Marketing Association co-launched the Produce Traceability Initiative. The goal of this Initiative is to agree to one language and set of standards to be used to label cases of fresh produce. With uniformity in external traceability practices, translations between customer and supplier codes become unnecessary and multiple points in the supply chain can be made aware, at the same time, whether or not and when they "touched" a particular product and lot number.
Inclusion of Industry in Traceback Investigations
Even when the Produce Traceability Initiative has been fully implemented, investigators will still need to understand the internal traceability and recordkeeping practices in place at each company visited. These practices will vary greatly from facility to facility in order to meet the needs of the company’s culture and other practices. We have heard that investigators sometimes struggle to understand these practices, abandoning or sidestepping the company’s official program, relying on other supply chain records to determine the sources of materials of interest and copying and searching through reams of paper to understand from where and when materials were obtained. This approach could result in missed or misunderstood trace records and therefore delay the traceback. Such delays do not help the investigation nor the companies involved, let alone public health. To speed the investigation, we encourage FDA to find ways to work with the facility’s personnel to understand their internal traceability program, or at least work with industry to understand and overcome obstacles to this approach.
Imports
We believe that imported produce be held to the same requirements as domestically sourced produce. Food safety has no state or international boundaries when it comes to protecting consumers. Therefore any application related to traceability must be consistent and applicable.
"Cash and carry" Operations
While the vast majority of the produce supply chain operates as I have already described, there are still situations where produce is transacted on a "cash and carry" basis, such as at farm markets and discount retail markets, where records assuring traceability may not be kept. These are typically operations close to the consumer points-of-purchase end of the supply chain. These types of operations tend to be local, a minor part of the overall produce supply chain and not representative of current industry practices. However, we also believe that these operations should be required to maintain records demonstrating the source of the ingredients they use. As noted earlier, the recordkeeping required at such operations need not be sophisticated – purchase records may suffice – but they should be adequate to assure traceability to their point of purchase. Again referring to the industry-developed 2nd edition Tomato Food Safety Guidelines, recommendations for retail and foodservice operations specify that "direct-to-consumer retail and foodservice operations shall maintain purchase records that will facilitate traceability. Each facility’s ability to comply with [this requirement] shall be verified at least annually. A record of this verification shall be kept on file [and] all records recommended in this section shall be maintained for at least six months and be readily available." This requirement we believe can be translated across the produce supply chain as it will be for tomatoes.
Relabeled Cartons
We also recognize that a common practice among whole produce handlers is to reuse produce cartons. This practice has provided significant cost savings to handlers and, ultimately, to consumers. However, this practice must be controlled by the handler to ensure, first, that direct food contact cartons do not pose a contamination risk to the produce they contain and, second, that labels on the carton are accurate to their contents. Again referring to the 2nd edition Tomato Food Safety Guidelines, the recommendation to packing operations specifies "Used boxes may only be used as primary containers for mixed/commingled lots if they are clean, sanitary and the original identification information on the box is still accurate to the original source of all of the tomatoes in the box."
Invisible Ingredients
Finally, we encourage the Agency to remember that traceability can only be performed if product of interest has been specifically and accurately identified. Tracebacks cannot be used as a substitute for case control and other epidemiological studies, just as epidemiological conclusions that are not supported by traceback investigations should not be assumed to be accurate. Using this summer’s Salmonella Saintpaul outbreak as an example, while a "fresh salsa" may seem to an adequate food description in an epidemiological study, the primary ingredient may not be the product of interest. Such products can have many ingredients, some of which may be invisible or unrecognizable to the average consumer. Ingredients may be unrecognizable even to investigators. For example, while long-shelf life salsa products typically contain heat processed ingredients to reduce their spoilage potential, it is possible to have unprocessed peppers, diced and invisible to the consumer. It is important for investigators to test their assumptions about products, and a close working relationship with industry during an investigation, as noted earlier, can help to avoid epidemiological misdirections.
In summary, the produce industry today, as a whole, has practices that comply with FDA’s recordkeeping regulations to provide traceability "one step back and one step forward" in the supply chain. If FDA is aware of facilities required to follow this regulation, and are not, we support FDA taking action consistent with the regulation. If there are gaps in the current regulation inhibiting FDA’s ability to perform tracebacks during an investigation, we encourage FDA to clearly identify the root cause of those issues and fix those, rather than reinvent a system that is already working. And finally, while the Produce Traceability Initiative will enhance the supply chain’s traceability practices, it is not a "cure all" or silver bullet. Many details remain to be worked out, and the industry is in the best position to help determine those details, to ensure they achieve their objectives within the cultures of the various facilities and in a manner that is efficient and cost effective, providing security and the best value to consumers.
Thank you for your attention and the opportunity to present these views.

United comments - child nutrition reauthorization

United's comments to the USDA on child nutrition reauthorization.



Mr. Robert M. Eadie
Chief, Policy and Program Development Branch
Child Nutrition Division, FNS, USDA
3101 Park Center Drive, Room 640
Alexandria, Virginia 22302-1594
Dear Mr. Eadie:
Thank you for the opportunity to provide USDA with recommendations for improving the nutritional quality of school meals through the 2009 Child Nutrition Reauthorization Act.
The following recommendations offered by the United Fresh Produce Association, if adopted, would increase children’s access to and consumption of fruits and vegetables in school meals, improve their overall eating habits, reduce risk of obesity and overweight, and promote good health.
Increasing the amount of fresh fruits and vegetables in school meals, serving fruits and vegetables in ways (fresh, fresh-cut and salad bars) that result in kids actually eating more and promoting evidence–based school strategies (salad bars) will improve the nutritional quality of school meals and increase children’s consumption of fruits and vegetables, consistent with the 2005 Dietary Guidelines.
By law, the School Lunch Program and School Breakfast Program must be consistent with the latest Dietary Guidelines for Americans. However, school meals currently contain fewer fruits and vegetables than recommended. To meet 2005 Dietary Guidelines:
• School Breakfast should include at least 2 servings of fruit and/or vegetable. This means adding 1 more serving
• School Lunch should include at least 3 servings of fruits and/or vegetables per day. This means adding at 1–2 more servings
Additionally, America’s children currently eat, on average, less than half of the fruits and vegetables recommended by the 2005 Dietary Guidelines. Improving school meals is a critical first step.
United Fresh Produce Association recommends the following priorities for the 2009 Child Nutrition Reauthorization:
1. The USDA Secretary should promote a "Salad Bars in School Cafeteria" Policy.
School Salad Bars are an evidence-based strategy to increase student’s consumption of fruits and vegetables. Salad bars, one of the simplest and most direct ways to increase student’s consumption, provide a wide variety of fresh fruits and vegetables and build on student’s independence and desire to make their own food choices. Understanding that it is not possible for all schools to implement a salad bar, we are not recommending that this policy be a requirement, but rather a policy that encourages USDA to aggressively promote "Salad Bars in Schools". With a national goal in place, the USDA should encourage and promote school salad bars, provide incentives, build on their "Fruits and Vegetables Galore: Helping Kids Eat More" Salad Bar Guide first published in 2004, and prove training to schools to implement salad bars.
2. Provide schools with $10 million funding per year for non-food assistance grants that will allow them to purchase food preparation equipment (such as refrigeration, salad bars, and etc.) to improve their kitchen facilities to provide meals consistent with the Dietary Guidelines and food safety practices, and support their ability to prepare and serve more fresh fruits and vegetables in school meals.
Many schools wish to serve meals more consistent with the Dietary Guidelines, including more fresh fruits and vegetables, but lack basic kitchen equipment, like adequate refrigeration, and lack the financial resources to purchase needed equipment. The non-food assistance grants could be targeted to low-income schools and should be easy for school to apply for. For example, $10 million per year would enable 1000 schools to purchase walk-in refrigerators and 2500 schools to purchase salad bars.
3. Double the funding for the DOD Fresh Program to $100 million/year.
The Department of Defense (DoD) Fresh Program is an effective and easy way for schools to purchase a wide variety of fresh fruits and vegetables at the lowest cost delivered directly to the school. The current funding of $50 million/year allows only a limited number of schools in each state to participate. Doubling the funding for the DoD Fresh Program, or its equivalent, to $100 million per year would increase the number of schools in each state that could participate in the program and result in more fresh fruits and vegetables being served in school meals.
4. Encourage AMS to significantly expand its commodity purchases of fresh and fresh-cut fruits and vegetables for schools.
Schools are asking for more fresh and fresh-cut fruits and vegetables as part of commodities. However, last year only 3% of all fruit and vegetable commodity purchases made by USDA/AMS were for fresh, resulting in a big gap between what schools are asking for and what AMS is purchasing.
The 2008 Farm Bill almost doubles the annual funding for commodity purchases of fruits and vegetables under Section 32 to the following amounts: FY’08 $390M; FY’09 $393M; FY’10 $399M; FY’11 $403M; and FY’12 $406M. Of these available funds, the FNS should be strongly encouraging AMS to expand its purchases of fresh and fresh-cut fruits and vegetables for schools as a strategy to increase student’s fruit and vegetable consumption.
The AMS is commended for planning to pilot a fresh-cut sliced apple purchase program for schools. However, as of this date it has yet to be implemented. Once effectively implemented, the AMS should be urged to expand the fresh-cut sliced apple program nationally and expand to other fresh-cut fruits and vegetables that are well liked by students and readily available in the market place. Children like fresh-cut fruits and vegetables and it is an evidence-based strategy to increase their consumption of fruits and vegetables.
5. Increase the current reimbursement rates for all school meals to reflect rising food, labor and transportation costs and to meet current nutrition standards and the Dietary Guidelines.
6. Support Congressional requirement that USDA publish proposed and final rules updating nutrition standards for the school meals programs within 12-15 months and 24 months, respectively, following publication of Institute of Medicine’s Report.

Respectfully submitted,

Lorelei DiSogra, EdD, RD
Vice President – Nutrition and Health
United Fresh Produce Association

Headline roundup - the economy, Costco, EU and bananas and other notes

Here is a roundup of news snatched from the Web this morning. Note that Commerce Department indicated grocery store sales in September were $44.4 billion, down slightly from $44.5 billion in August. Foodservice and drinking places showed sales of $38.2 billion, off from $38.5 billion in August.


September retail sales down 1.2% From Thompson Financial

US retail sales fell in September at their fastest pace in three years as auto sales slowed again and sales dropped in nearly every major retail category, the Commerce Department said today.

Commerce said September retail sales fell 1.2%, the largest drop since August 2005 and much worse than the 0.7% decline predicted by economists polled by Reuters. Retail sales have now fallen for three consecutive months.

Sales at furniture stores fell 2.3%, the largest monthly decline since February 2003. Sales fell 2.3% at clothing stores, 0.4% at general merchandise stores, 0.5% at food and beverage stores, and 0.6% at building material and supply stores.

Quebec produce growers attack Costco From The Gazette:

Criticizing a customer in public might not seem like an overly astute business move.

But the head of the Quebec Produce Growers Association figures his members have nothing to lose - and everything to gain - by calling retail giant Costco to task for failing to buy more of the fruits of their labour.

"They've been giving us the runaround for two years and we're sick of it," Plante said as he described a letter his association sent to Costco last month - which also is being sent to Quebec media outlets - complaining about the lack of Quebec-grown produce in its stores.

"Our produce is good enough for all the major grocery chains in Quebec, so what's (Costco's) problem?"

Plante, whose group promotes and markets fresh produce on behalf of its 300 members, said Costco has repeatedly promised over the past two years to display more Quebec-grown fruits and vegetables in its stores.

EU fines Dole, Fresh Del Monte over banana price-fixing claims From the LA Times

Dole Food Co. and Fresh Del Monte Produce Inc. were fined 60.3 million euros ($82 million) by European Union regulators over claims that the banana importers fixed prices in eight countries from 2000 to 2002.

Dole was fined 45.6 million euros and Fresh Del Monte is jointly responsible for a 14.7-million-euro fine along with Internationale Fruchtimport Gesellschaft Weichert & Co., the European Commission said in Brussels. Chiquita Brands International Inc. avoided a penalty of 83.2 million euros because it told regulators about the price-fixing cartel.

Expect changes to Canada's organic standard From Alberta Farmer

Canada's organic farmers will want to watch for revisions to the planned "Canada Organic" standard between now and its delayed implementation at the end of June next year.

Hugh Martin, organic crops production program lead for Ontario's ministry of agriculture, food and rural affairs (OMAFRA) in Guelph, said in a newsletter to organic producers this week that efforts have been underway to revise the standards, including "many edits and clarifications within the standards and some additional substances within the permitted substances list."

Joe the plumber - McCain's comeback

I think John McCain's will get a surge after last night's debate, thanks to Joe the plumber. Here is a link to the transcript of the debate.