PMA presenttion at FDA hearing - traceability

PMA Slideshow Days 3 and 4

Winding down

Exhibitors are generally happy with the PMA show. Some have noted that buyers have perhaps trimmed down the list of who they sent this year, but exhibitors have seen everyone they wanted or expected to see. One exhibitor said Safeway wasn't too visible... Talk continues about the third day of the show, with one offering if the Friday-Saturday-Sunday format would be best.

Well over 17,000 attended the show from 61 countries, with 3,700 buyers among the throng, says PMA.


One exhibitor said it cost him close to $50,000 to exhibit and attend at the show with his team, but it was worth to him if he gets just one new customer.

How will trade show attendance sort itself out in 2009? Given the current economic climate, look for even more scrutiny of the costs of attending and exhibiting.

PMA Day One

Tom Tjerandsen, marketing director for the Chilean Fresh Fruit Association, Sacramento, Calif., is interviewed by The Packer's Jose Escobedo on Oct. 24.


We arrived in Orlando about 11 a.m. this morning and had time to check into our hotel, deposit our luggage and take the red #1 shuttle to the convention center. Once there, got our badges from Theresa Z. in the press center. The highlight of the luncheon session, of course, was Bryan Silbermann's state of the industry address. Silbermann did give a nod to the traceability issue right out of the gate, including a nice touch of asking Tom Stenzel and Danny Dempster on stage with him so the three of them together could recognize the efforts of Cathy Green, chief operating officer for Food Lion LLC, Salisbury, N.C., and chairwoman of the Produce Traceability Initiative Steering Committee.

As you might expect, Silbermann's address was fairly wide-ranging, taking measure of the economy, the local food movement, organics, the development of young professional talent in the industry, sustainability and more. A theme: finding opportunity in crisis...
One excerpt:

Sometimes it seems we’ve written the words of Robert Louis Stevenson into our business philosophy: “Our business in life is not to succeed, but to continue to fail in good spirits.”

Folks, Stevenson died in 1894! Do we really want to accept those words as guiding principles of our modern, complex 21^st century produce industry? Are we really willing to run our businesses with the motto “It is what it is”, or should we believe “It is what we make of it?”

Bryan Silbermann's prepared remarks for his state of the industry address can be found here.

After the luncheon, I attended a fairly low key workshop on country of origin labeling and later, an interesting meeting of Chilean importers who gathered at the Peabody Hotel. There are important developments in regard to the California grape desert marketing order that I'll talk about later in coverage for The Packer.

At the reception tonight, I talked to one Aussie mushroom industry leader who was stoked to hear more about Monterey Mushroom's Sun Bella Vitamin D infused mushrooms on the show floor tomorrow. He said much of the population in the U.S. and other developed countries has a Vitamin D deficiency and speculated the product could be a winner.

One wrinkle this year for me is that I have a Cardscan business card reader in tow, so I can collect as many business cards in the next couple of days as I may please without having that crushing defeated feeling of knowing I will never get around to transferring contact info. That's the theory anyway.

That's all for now, with a bigger day on tap for tomorrow.

Product Tracing Systems for Fresh Produce - PMA presentation - Oct. 15

PMA comment - reauthorization of child nutrition programs

From Kathy Means of PMA, the association's comment on child nutrition reauthorization:

October 15, 2008

To: Robert M. Eadie, Chief, Policy and Program Development Branch, Child Nutrition Service, Food and Nutrition Service, Department of Agriculture

From: Kathy Means, Vice President, Government Relations and Public Affairs, Produce Marketing Association

Re: Comments on Request for Public Comments for Use in Preparing for 2009 Reauthorization of Child Nutrition Programs and the Special Supplemental Nutrition Programs and the Special Supplemental Nutrition Programs for Women, Infants and Children; FNS-2008-0011-0001

The Produce Marketing Association (PMA) is pleased to submit these comments to U.S. Department of Agriculture (USDA) in response to the May 20, 2008 Federal Register request for comments on the 2009 reauthorization of child nutrition programs.

PMA is the largest global not-for-profit trade association representing companies that market fresh fruits and vegetables. We represent 3,000 companies, from grower-shippers and supermarket retailers, to hotel and restaurant chains and overseas importers. Within the United States, PMA members handle more than 90 percent of fresh produce sold to consumers.

PMA welcomes the opportunity to submit comments on the upcoming reauthorization of federal nutrition programs, including the Special Supplemental Nutrition Program for Women, Infants and Children (WIC), National School Lunch Program, School Breakfast Program, WIC Farmers Market Nutrition Program. We encourage USDA and will similarly encourage Congress to take an expansive and innovative approach in this reauthorization. The issue of nutrition and the access and quality of the federal programs stand as critical issues to our nation. In the reauthorization, policymakers must address both hunger and obesity and examine the delivery of services through the federal programs.

Congressional reauthorization of child nutrition follows on the heels of 2008 farm bill. PMA joined with a coalition of specialty crop groups to advocate for advances in nutrition and other programs important to our members. In the farm bill, Congress demonstrated its support for increasing consumption of fresh fruits and vegetables in the school lunch and other federal feeding programs by providing for dramatic increases in the Fruit and Vegetable Snack Program and in fruits and vegetables commodity purchases (including via “DoD Fresh”). Congress recognizes that increasing consumption of fresh produce is an important public goal and that focusing nutrition programs on nutritious foods fosters lifetime habits of healthy eating.

The fact that Congress has already endorsed these principles should embolden USDA to develop recommendations that focus on the critical role of fresh fruits and vegetables in a healthful diet. All federal feeding programs must meet the Dietary Guidelines for Americans and the programs should maximize nutrition. There should be additional opportunities to make fruits and vegetables available both inside and outside of the schools. Though challenges exist to make perishable commodities available in schools, the reauthorization process provides the opportunity to address those challenges and increase access. The success of the snack program demonstrates the popularity of fresh fruits and vegetables when they are made available to students and other feeding program recipients.

In addition to improving access to healthy foods, the programs should expand efforts to teach children and feeding program recipients the importance of nutrition. Nutrition education programs can address long-term health issues and work in concert with the feeding programs. WIC is one such program that offers an immediate introduction to fresh and wholesome fruits and vegetables. WIC coupons should encourage the consumption of produce, including white potatoes, while reflecting the cost of today’s food, such as the Institute of Medicine has recommended (which would mean an increase allowances in the fruit and vegetable vouchers). The program, and other feeding programs, meet immediate nutritional needs while also building healthy eating habits.

PMA applauds your efforts to gather public comment in advance of the congressional reauthorization and we look forward to working with you throughout this process.

DataBar explained

As we wait for more hard news on the Produce Traceability Initiative, here is a news release from the Produce Marketing Association about the "DataBar." Come now, it's not that complex...From PMA:


Newark, Del. – The Produce Electronic Identification Board (PEIB) has seen the future of produce product identification coding, and it is the DataBar.

PEIB, the PMA board responsible for creating produce price look-up (PLU) codes and standardized Universal Product Code (UPC) numbers – i.e., those beginning with 033383 – began shifting its focus away from commodity marking for product identification at point of sale (POS). With the emergence of GS1’s new barcode called DataBar, the buying and selling community now has a viable information technology option that will provide a broad range of operational efficiencies as well as enable key information to travel along with produce items.

“With the use of the DataBar, produce companies can now begin enjoying benefits that packaged goods companies have enjoyed for decades,” said PEIB Chairman Mike Agostini, merchandise manager for Wal-Mart. “The DataBar provides product movement data and shrink information for each grower/shipper, while also providing scanning efficiencies and resolving pricing errors caused by price differences between organic and conventional products.”

The DataBar carries the 14-digit Global Trade Item Number (GTIN). Analogous to the ubiquitous UPC, the GTIN identifies the grower/shipper as well as the physical item carrying the mark. This allows the retailer’s POS system to gather product information by grower/shipper, a boon to category management efforts. And because the DataBar is a much smaller barcode than the UPC, it fits on most of today’s produce PLU stickers. Recognizing the transition that will be needed to move from a four- or five-digit PLU number to a 14-digit GTIN, the sticker that will now be affixed to loose produce can bear both the DataBar barcode and the PLU number as a back-up. Having the human-readable PLU number on the sticker will allow a transitional period for retailers who may not be ready to begin scanning the DataBar immediately, as cashiers will still be able to see the PLU number on the sticker. Other information traditionally shown on the PLU sticker, such as country of origin labeling or company logos, can also be included on DataBar stickers.

Most POS scanners manufactured after 2002 already have the ability to read the DataBar with a flip of a switch, reports Produce Marketing Association Vice President, Industry Technology and Standards Gary Fleming. To be able to read the codes, retailers will need to modify their item information databases to include the 14-digit GTIN, if they do not already do so. In addition, growers/shippers will need to provide their GTIN numbers to their buyers in advance, so that retailers can add them to their POS databases before product is scanned at POS, says Fleming.

The PEIB recommends that growers/shippers assign GTINs at the same level of granularity that exists for PLU numbers – that is, by commodity, by variety and by size group. This will now mean that retailers will have to store a unique 14-digit GTIN for each supplier from whom they buy each commodity. Most likely, the retailers will link the PLU number to each of the supplier’s GTINs that supply the commodity, says Fleming.

“The benefits of having product movement data by grower/shipper will be advantageous for both the buying and selling community,” said Tim Gagnon, PEIB vice chairman and director for C.H. Robinson Company Worldwide. “Growers and shippers will now be able to measure the success of their products at POS versus their competitors, and thus target marketing and demographic campaigns. Buyers will now be able to move away from commodity-based category management and toward unique product category management akin to packaged goods.”

Fleming noted the movement toward the DataBar is beginning to gain momentum, with rollouts from Wal-Mart and Loblaws leading the way with over a dozen fresh produce suppliers, and other rollouts just around the corner. The vendor community has already anticipated the transition to the DataBar, including scanner manufacturers, software vendors, labeling vendors and scale manufacturers. The DataBar is also getting traction in the other fresh food sectors, as the technology recommended by seven different fresh food associations referenced in the document entitled “Industry Roadmap: The Fresh Food Supply Chain of the Future.” In addition, the coupon industry is also beginning to transition to the DataBar, with its increased capability to hold more data.

While the transition from PLU codes to DataBar is ongoing, the PEIB is encouraging retailers to accept product stickered with both the DataBar and PLU codes, even though they might not yet be scanning DataBars at point of sale.

“The needs of the marketplace are changing, including the need for more information and the ability to track product to a specific grower,” said PMA’s Fleming. “The DataBar allows for exactly this, while minimizing the impact a new technology can have on members of a supply chain. Chances are, you have probably already seen the DataBar on some apples, bananas, avocados, peppers, tomatoes and other commodities. If you haven’t, don’t be surprised because you soon will.”

Questions regarding the DataBar can be directed to any member of the PEIB, or to PMA’s Gary Fleming (gfleming@pma.com) or Director of Voluntary Leadership and Industry Standards Alicia Calhoun (acalhoun@pma.com).

PMA Comment on COOL - Sept. 17

From www.regulations.gov, the comment on COOL by the Produce Marketing Association:

September 17, 2008

To: U.S. Department of Agriculture, http://www.regulations.gov

Subject: Docket No. AMS–LS–07–0081

Mandatory Country of Origin Labeling of Beef, Pork, Lamb, Chicken, Goat Meat, Perishable Agricultural Commodities, Peanuts, Pecans, Ginseng, and Macadamia Nuts

The Produce Marketing Association (PMA) is pleased to submit these comments to U.S. Department of Agriculture (USDA) regarding its request for comments on mandatory country of origin labeling (COOL).

PMA is the largest global not-for-profit trade association representing companies that market fresh fruits and vegetables. We represent 3,000 companies from grower-shippers and supermarket retailers, to hotel and restaurant chains and overseas importers. Within the United States, PMA members handle more than 90 percent of fresh produce sold to consumers. PMA and our members are committed to improving food safety practices for produce, domestic and imported, to further enhance the safety of our food supply.

We have been actively engaged in COOL for many years, and we appreciate the efforts of the Agricultural Marketing Service on this important program designed to convey information to consumers about the origin of fresh produce and other items. In most cases, the agency has aligned the consumer’s need for information with the practical realities of industry operations. An example of this is the agency allowing the name of the country/state/region with or without the phrase “product of” (§65.400). Another example is the agency’s ruling in §65.300 and §65.400 that a single commodity from multiple countries of origin that is commingled can be labeled by listing each of the countries involved. We particularly applaud the agency’s decision to allow state and regional designations for perishable agricultural commodities as compliance with the Interim Final Rule (§64.400).

We offer the following suggestions as ways to enhance and clarify the specifics in the Interim Final Rule. In one case, we suggest a change to language in the Interim Final Rule.

Definition of processed product: We recommend that any fresh-cut produce item, even those not combined with another substantive food item or other covered commodity be included in the definition of “processed product” (§65.220). By taking a raw agricultural commodity, washing it, then cutting it, a company does change the product from a raw agricultural commodity to a ready-to-eat food item – similar to cooking changing a raw meat product to a ready-to-eat food.

We applaud the agency’s decision to exclude items in which two or more covered commodities are combined. We ask the agency to offer more clarity about combinations of covered commodities in the definition of processed product. When speaking about generic categories of products (lettuce, melons, etc.), different varieties within those generic categories are distinctly different. We appreciate the dilemma in determining differences. This is a rule designed to convey information to consumers, and consumers clearly perceive these differences. Because consumers go to the store to buy specific varieties within generic categories (they seek a honeydew melon or romaine lettuce or a Gala apple), we know that the consumer appreciates and values these differences. A consumer is clearly aware that frisee is not the same as Iceberg lettuce, that butter lettuce is different from red leaf lettuce, that a honeydew melon is not the same as a cantaloupe, even that a Granny Smith apple is different from a Red Delicious apple. We recommend that the agency designate that items with distinct varietal names within a generic category of products be deemed different products and excluded when two or more are combined.

Abbreviations: We appreciate the agency’s recognition of the need to abbreviate the names of some countries (§65.400) using abbreviations from U.S. Customs and Border Patrol. We would ask that the language in section (e) be reworded to remove the first sentence (“In general, abbreviations are not

acceptable.”). The available space on a product labels (e.g. price look-up [PLU] sticker) or a bill of lading is scarce. It is important for industry to be able to convey origin information on both of those vehicles for several reasons. Information on the product itself (through a PLU sticker, rubber band, twist tie, tag, etc.) is particularly important because it informs the consumer at point of purchase and moves with the product to the home. When industry can include the information on a bill of lading, it allows companies to use existing records as the statute requires. However, the agency should remove the requirement that a key to abbreviations be included with documents (each time or even once) as the industry is well aware of the abbreviations used and their meanings.

Industry needs more guidance on what abbreviations will be acceptable. We recommend that the agency specify approved abbreviations. A standard ISO list exists and would be consistent with other uses from Customs and Border Protection (CBP), as the agency mentioned in its Interim Final Rule. (To find them from the CBP site, type in country abbreviations in the Search box, then select Export Reference Tables from the results list. On the next page, select “Schedule C: Country and Territory Designations by Code (Census Bureau).” This link will take you to an exit page that refers you to http://www.census.gov/foreign-trade/schedules/c/country.txt. The country abbreviations listed here are the two-character ISO codes.) Having standard abbreviations for use in commerce will make labeling more efficient and cost-effective.

Define “majority”: The agency understands that when fresh produce is stickered with origin information, every product may not bear a sticker for a variety of reasons (e.g. stickering efficacy is not 100%). The agency has said that a majority of the product should have stickers. We ask that the agency define “majority” as it applies to bulk display stickering for perishable agricultural commodities as 50% plus one so that the industry has a specific understanding for compliance.

Retailer recordkeeping: The agency has offered simple, effective rules for recordkeeping by retailers. We seek greater clarity on this issue. In §65.500(c)(1), we suggest that the agency put the last sentence of the paragraph first (“For pre-labeled products, the label itself is sufficient evidence on which the retailer may rely to establish the product’s origin.”). We also ask the agency to state specifically that retailers need not maintain any new or additional records documenting origin for those products that are pre-labeled on the product itself or on the box/container (when the box/container is visible to consumers, such as when it is used as part of a retail display). Then follow with the first sentence in that section amended to read:

Records and other documentary evidence relied upon at the point of sale to establish a covered commodity’s country(ies) of origin must be provided to any duly authorized representative of USDA in accordance with § 65.500(a)(2), and records for product that is not pre-labeled be maintained for a period of 1 year from the date the origin declaration is made at retail.

Effective dates: USDA states that the requirements of this rule do not apply to covered commodities produced or packaged before September 30, 2008. Many in the industry procure packaging materials for a year’s worth (or more) of production. Given the short amount of time between the release of the Interim Final Rule and the effective date, we ask that companies subject to the rule be given a year from the effective date to use up existing packaging inventories, provided those packaging inventories were acquired prior to the effective date of the rule.

Kathy Means

Vice President of Government Relations and Public Affairs

Produce Marketing Association