Updates on the Produce Traceability Initiative
The Produce Traceability Initiative (PTI) recently released an updated guidance document on labeling titled Harmonized Case Label, an update to the guidance document on sharing Advanced Ship Notices labeled Why and How to Use EDI 856 Advance Ship Notes/Manifest Transaction Set (ASN) and a template for sharing traceback data with regulators. Each document includes important updates and recommendations for improving traceability in the fresh produce industry.
Harmonized Case Label
As PTI became a reality in businesses, and implementation began, PTI saw creep as to what was being requested to be on the case label. In a recognition of challenges happening within the fresh produce supply chain, the industry came together to look at the case label and truly understand what needs to be on the label for both traceability and business cases. The following changes are an outcome of that understanding.
- Regulated font size
- UPC and PLU inclusion
- A recommendation that both French and English be used on the label
- Inclusion of specific Grown In information for single commodities vs. multiple ingredients
More specific guidance and information can be found in the Harmonized Case Label document.
Why and How to Use EDI 856 Advance Ship Notice/Manifest Transaction Set (ASN)
PTI recently released updates to the document labeled Why and How to use ED 856 Advance Ship Notice/Manifest Transaction Set (ASN). The revisions and changes were made to reflect changes made in environmental standards, and the document is now aligned with the standard for the Uniform Communications Standard, with edition number 7050.
PTI Traceback Template
Understanding the struggles that the FDA experiences in understanding and validating key data elements in the paperwork they receive during a foodborne illness outbreak investigation, the fresh produce industry came together to find a way to readily and clearly communicate those data to the FDA. This came about via an Excel spreadsheet where all participants involved in an investigation can input their data in a uniform and consistent manner and forward it to investigating regulators. The template includes three tabs for receiving, shipping and transformation, which are reflective of the data that the FDA asks for during a traceback investigation and a 4th tab with the attribute definitions. The template is now available for download on PTI’s website.
FDA’s Updates on Leafy Greens
In addition to the PTI activity, the FDA released their report titled Factors Potentially Contributing to the Contamination of Romaine Lettuce Implicated in the Three Outbreaks of E. coli O157:H7 During the Fall of 2019 as well as the 2020 Leafy Greens STEC Action Plan - both documents have recommendations to the industry on how to improve traceability.
Factors Potentially Contributing to the Contamination of Romaine Lettuce Implicated in the Three Outbreaks of E. coli O157:H7 During the Fall of 2019
The recommendations in the above report include language were mirrored in the New Era of Smarter Food Safety Blueprint as well as the Leafy Greens Action plan. Those recommendations include:
- Increase the digitization of traceability interoperability and standardization of traceability records to expedite tracebacks.
- Include broader, more consistent implementation of voluntary source labeling on packaging.
2020 Leafy Greens STEC Action Plan
With respect to promoting tech enabled traceability, the FDA made the following recommendations in the 2020 Leafy Greens STEC Action Plan:
- Issuing the proposed rule of FSMA 204 records requirement for tracking and tracing designated foods, which is on schedule to be sent to the office of federal registrar on September 8.
- Prioritizing work with leafy greens stakeholders to design and initiate a pilot on concepts needed for traceability to further scale such as testing interoperability of tracing systems and public/private data sharing.
In response to the 2020 Leafy Greens STEC Action Plan, the industry continues to focus on boosting work for traceability around key data, the interoperability and the public/private data sharing. The industry has collaborated with six industry organizations (FMI, IFDA, IFT, PMA, United Fresh and GS1 US) announcing an industry led leafy green traceability pilot program to respond to FDA’s traceability recommendations and to test the utility of the produce traceback template.