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Recall Abilities Largely Dependent on Retailers

by Todd Baggett, March 4, 2013

Consumers expect that today's produce industry has the ability to trace back any fresh produce they buy. Is this really the case?

What if a consumer buys a fresh-cut salad blend with romaine grown on one farm, iceberg grown on another, and carrots grown somewhere else? Is it possible to determine where and when each ingredient was grown and processed?

In the case of bagged salad, the value-add processor tracks the source of each ingredient back to the lot(s) from the farm(s) from which they came. They will track the grower and lot number of each item introduced into the production lot. The processor can choose the time frame of the production lot; best practice is not more than one day.

On the retail side, the situation today is not as tightly controlled. The retailer is usually buying a commodity from multiple growers who are constantly shipping from multiple lot numbers. Retailers generally do not track which grower and associated lot numbers are shipped to the individual store level. Until the retailer adopts the PTI, traceability stops at their distribution center.

What does this mean for the ability to trace back an implicated product when there's a problem with a specific commodity? It makes the FDA's current recall process challenging and can result in:

1) Commodity-wide recalls, which fan consumer concerns and penalize the 99% of the growers whose products are not implicated
2) Delays in identifying the responsible product, which can keep an entire commodity out of commerce

Once the FDA identifies a correlation between an implicated commodity and the retailer where an item was purchased, they will ask the retailer for a list of growers they purchased the commodity from within a specified time period. The growers can identify what lot numbers they shipped to the retailer's distribution center or stores, which leads to the identification of the lot numbers that could be implicated. The FDA then investigates to try to narrow down to the specific grower and facilities that were tied to the problem.

This process can take 3 weeks to several months. Depending on the severity of the illness, the FDA may issue a commodity warning, which leads retailers and restaurants not to sell the commodity until the source of the problem has been identified.

So to answer the original question – yes, the ability exists, if all members of the supply chain are PTI complaint. But until the FDA mandates traceability processes, we are dependent on retailer adoption of PTI to achieve complete traceability.


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