Newark. Del. – The federal government should first look at the produce industry’s existing plan to achieve enhanced product traceability before considering any new regulations, Produce Marketing Association (PMA) told the U.S. Food and Drug Administration (FDA) in written comments submitted Oct. 8. The association’s comments will be reinforced in oral testimony at an FDA public hearing Oct. 16.

Responding to an agency request for information about produce tracing systems, the association urged FDA to consider the Produce Traceability Initiative’s (PTI) recently-announced plan for moving the entire produce supply chain to a common standard for electronic produce traceability as a model solution before considering any further steps. PMA referenced numerous elements of PTI’s plan when answering questions posed by FDA in its Sept. 24 Federal Register notice.

PMA Vice President of Government Relations and Public Affairs Kathy Means will outline the PTI plan and reiterate PMA’s comments when she speaks Oct. 16 in College Park, Md., at the first of two public hearings scheduled by FDA to address tracing systems for fresh produce. Means was invited to present the PTI plan to FDA officials who will be present.

PMA told FDA that PTI’s plan, developed by a supply chain-wide Steering Committee, provides a realistic and achievable plan that would directly address FDA’s desire to enhance product tracing systems for fresh produce. She said it will also improve the agency’s ability to use this information to identify sources of contamination associated with fresh produce-related outbreaks of foodborne illness.

“The industry has already spent considerable time and effort developing a solution that we know is achievable,” said PMA’s Means. “FDA should take advantage of our expertise and experience in this area by thoroughly examining the Produce Traceability Initiative’s plan before blazing any new trails. Anything less would be shortsighted, limiting the produce industry’s ability to safeguard its products and business interests.”

PMA noted that the PTI plan already addresses many of FDA’s questions about tracing systems. For example, responding to FDA’s query whether there should be a produce-specific identifier placed on packages, PMA cited the PTI plan’s requirement that packers obtain a unique company prefix from the GS1 international standards organization. PMA also noted that the PTI plan addresses how to track product that has been commingled, the topic of another FDA query. Regarding FDA’s question about whether a product tracing system should be standardized, PMA pointed to the industry’s recommendations for standardizing product coding, developed by PMA and the Canadian Produce Marketing Association (CPMA) in 2007.

“We also reminded FDA that food companies, including produce companies, have been required to trace product one step forward and one step back since the Bioterrorism Act was enacted in 2002,” added Means. “Enforcing this existing law before any additional legislative or regulatory requirements are imposed is essential.”

The PTI’s plan was approved by the PTI Steering Committee in late August; its approval was formally announced Oct. 7. Already backed by 34 Steering Committee members with other companies signing on daily, the plan was developed over a lengthy and intensive process by the group, which hailed from across the produce supply chain, from field to store to foodservice. Voluntarily established in late 2007 to drive chain-wide, electronic traceability best practices and set goals for their adoption and accountability, PTI is administered by PMA, United Fresh Produce Association (United Fresh) and CPMA.

Visit http://www.pma.com/issues/TraceabilityComments.cfm to view PMA’s Oct. 8 comments to FDA. To view the PTI action plan visit http://www.pma.com/cig/tech/traceability.cfm.