Top 10 Produce LLC

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Questions & Answers Courtesy of The Produce Marketing Association 

Topic - Traceability

As part of the Produce Traceability Initiative, an action plan was prepared and endorsed by industry leaders in September 2008 and was launched by PMA, CPMA and UFPA in October 2008. Please refer to the following link for the PTI Action Plan and associated milestones.

1. Who is setting deadlines for traceability implementation?
   The 48 companies that made up the Steering Committee for the Produce Traceability Initiative (PTI). This group included retailers, foodservice distributors, growers, shippers, trade associations, brokers, terminal markets.
   
   
2. Are there penalties for not meeting the deadlines?
   Adhering to these deadlines is strictly voluntary. However, if the industry does not meet the deadlines, the federal government will most likely take this out of the industry’s hands and establish their own deadlines. (See question #18 for further information.)
3. Is the GTIN always assigned by the grower or can it be changed by the distributor?
   The GTIN is assigned by the owner of the brand. If the brand is owned by the shipper, then the shipper is to use their GTIN. If the brand is owned by the foodservice company or retailer, then the GTIN is assigned by them, as it is their brand.
   
   
4. Do you have to order GTIN labels in advance or can you make them on the fly?
   The GTIN and labels are two different things. The GTIN is a number. You can put the GTIN on any label and affix the label to a case. More relevant to traceability, the GTIN (the number for the case) needs to be shown in both human readable form as well as encoded inside the GS1-128 barcode. These two things (human readable information plus barcode) need to be shown on the case. As the barcode used (i.e. the 128 barcode) is read most consistently when printed on a label, it is recommended that the barcode be printed onto a label and then a label affixed to the case. You can pre-print them or print them as needed. However, keep in mind that you also have to include the LOT #, which sometimes is a consideration that would dictate whether you should pre-print labels or print them as desired.
   
   
5. What is the compatibility with COOL? If the state is already printed on the product, do we need to print the country of origin?
   The traceability requirements are completely separate from COOL. Keep in mind, the traceability requirements are at the CASE level only, not at the ITEM level. For additional information on COOL, please refer to the following page on PMA’s website, http://www.pma.com/issues/labeling.cfm.
   
   
6. Does the receiver have to maintain all of their suppliers GTINs and lot number information?
   The receiver must read and store the GTIN and LOT # of every case received. Used with the one-step-up and one-step-down provision is what enables whole chain traceability.
   
   
7. Does all (or any) information contained within the GTIN need to be included on individual packs?
   The GTIN is a number. For traceability purposes, it is the number used to identify the case. If you use a UPC number to identify the items inside the case, then you link the item UPCs to the case GTIN. Example:

CASE GTIN	PACK	ITEM UPC	Case Description
10666666555553	12	666666001237	12-pack Iceberg lettuce
10666666444441	24	666666001237	24-pack Iceberg Lettuce

1. What group is the data synchronization best practices document geared to: grower/shippers or buyers or both?
   Both. Data synchronization is sent from the seller to the buyer. The seller needs to know how to send the information, in what format, etc. The buyer needs to know how to receive it, in what format, and how to store it in their systems. The document is currently being drafted and will be posted on PMA’s website.
   
   
2. How does the traceability initiative apply to customers not connected electronically?
   None of the PTI milestones require companies to be connected electronically. However, the milestones can be accomplished more efficiently, faster and cheaper with electronic connectivity and automation. The degree of automation will be up to each trading partner relationship.
   
   
3. Is there a central data archive?
   No. This would be an extra step for individual companies to have to send a “feed” to a central repository on every transaction. This is NOT necessary at this time, provided that companies follow the milestones and have the necessary information available for the FDA at the time of a recall.
   
   
4. Are lot numbers standardized?
   No. Because of the diverse formats of lot numbers, the only requirement is that the lot number be NO MORE THAN 20 characters long. The characters can be alpha numeric.
   
   
5. Is there any economic benefit from a traceability strategy related to product liability insurance? In other words, do you save by having a strategy (or insurance)?
   This is a question to take up with your insurance carrier or legal counsel as many factors influence insurance rates.
   
   
6. Will we be able to or how can organic and conventional product be handled together (re: assignment strategy)?
   Refer to the GTIN Assignment Strategy for details.
   
   
7. How do you label product with multiple lots of the same item (i.e. 3 or more different growers/lot numbers) on the same pallet?
   You are required to provide a LOT # for the case, not the pallet.
   
   
8. Can we include marketing information, brands etc. on the case labels?
   Yes, as long as you have the minimal data needed for traceability shown on the case (refer to the Case Labeling Best Practices).
   
   
9. Is there a discount through GS1 for PMA members to obtain a company prefix?
   No.
   
   
10. What is the GTIN assignment strategy for private label? How will the supplier be identified?
    In the situation of a private label product, the buyer is responsible for creating the GTIN number. As the owner of the brand, the buyer can identify the supplier by either (1) using the supplier information shown on the case (see Case Labeling Best Practices) or (2) electronically working with the buyer on a strategy to designate supplier as part of the GTIN or Lot #.
    
    
11. Have we solicited help from FDA and USDA for enforcing the standards?
    FDA is aware of the PTI and supports our efforts. As of now, these milestones are self-regulated between industry partners. Many buyers will be expecting each milestone to be completed and, beginning with Milestone #3, will know when their sellers have not followed the Action Plan.
    
    
12. What steps does a company need to take to determine the total cost to implement GS1 standards into their company?
    There are too many variables to offer an accurate answer. The costs vary by size of company, buyer or seller, whether you use labels, use barcodes, and if your database is equipped to store GTINs.
    
    
13. Is it necessary to use the GS1-128 exclusively?
    Yes. The GS1-128 barcode is a linear barcode that holds up to 48 characters of information. The PTI steering committee agreed on this standard barcode to ensure scanner compatibility, widespread usage, and that it can hold the required data.
    
    
14. The purpose of the traceability initiative is to provide traceability and primarily, in the case of an outbreak, the package or container is discarded so we are depending on the data behind the GTIN – not the number itself – correct?
    The number is used as a reference to get to the case of product that is being discussed. In your database, you can have as many attributes that are linked to the case number as you desire. This number, along with its attributes, would typically be stored in your master database so that when you reference the GTIN number, you do not need to repeat all of the attributes associated with that GTIN. This is critical when using a barcode as we can only fit a few numbers in the barcode, not the descriptors that make up the number.
    
    
15. If you have 10 growers packing a private label on the same product, do you have to have 10 different GTINs?
    The private label brand owner must designate the GTIN. If they choose to differentiate between the different growers by using the GTIN, rather than by other means, they would need to give each grower a different GTIN. If, however, they choose to use other means to differentiate their suppliers (e.g. as part of their Lot #), they can give all the growers the same GTIN number.
    
    
16. If you are a processor and you receive the product from a grower, does the traceability initiative also apply?
    Yes. As a processor, you will be responsible for knowing where the inputs are coming from that created your finished product. You will also be responsible for knowing where you ship it.
    
    
17. When or will the USDA adopt this initiative? Are PMA and the FDA discussing how recalls and traceability are handled?
    PMA and UFPA have met several times with both the FDA and the USDA to educate them on the Produce Traceability Initiative. Both agencies are supportive of our efforts. We continue to meet with these agencies to keep them abreast of our progress as an industry. In addition, we are meeting with them to ensure they have the industry knowledge that would hopefully prevent any more unnecessary massive recalls.
    
    
18. If, as a grower/shipper, we receive the same product from different growers, is a different code needed for each?
    The GTIN on the case should identify the brand owner. If a grower procures product from another grower they do not need to put a new GTIN on the case, unless they plan on packaging it under their brand or altering the case contents. Note, the buyer will need to know that they are shipping them different GTINs so that they can read this information on the case when scanned.
    
    
    
19. Does the GTIN get recorded at the store and restaurant level or only at the distributor level?
    Milestone #6, which requires companies to read and store INBOUND case information, does NOT apply to individual stores and restaurants. The needed information for trace back will come from the distribution center that shipped product to the store or restaurant.
    
    
20. If product gets reworked because it does not meet quality standards, does a new GTIN need to be assigned?
    The general rule of thumb is that whenever the case configuration or contents of the case are altered in any way, it requires a new GTIN.
    
    
21. Who polices the traceability initiative and enforces the milestones/action plan? Are there any consequences when someone doesn’t comply?
    Currently, the milestones of the PTI are self-regulated by industry members. However, individual buyers will begin checking for conformance once Milestone #3 begins, as it is the first milestone that requires their participation as well.
    
    
22. Who mitigates disputes/issues?
    As this initiative is self-regulated by industry members, there is no official source that will help mitigate disputes.
    
    
23. Is there an endorsement or mandate from the FDA re: the traceability initiative?
    There is no FDA mandate currently in place. Lacking industry progress, FDA may establish far more burdensome mandates.
    
    
24. How do we have transparency from the packer in the fields through to the consumer (i.e. bagged salads)?
    The PTI was not organized to develop greater transparency for the consumer. The purpose of PTI is to enhance traceability within the supply chain so that product can be traced quickly and efficiently.
    
    
25. How can bulk product be traced when there are no barcodes available at the shelf?
    The PTI is focused at the CASE level. There are other initiatives that are focused on item level identification.
    
    
26. Will the GTINs be placed on the bill of lading?
    Ideally, yes. If the buyer orders using the GTIN, then the bill of lading should have the list of GTINs that were ordered for the purpose of reconciliation. However, there is no mandate that requires this.
    
    
27. What happens once your product is no longer in its original packaging – repacking or processing?
    The repacker gives the “new case” a new GTIN and Lot #. They will then have to link this new number to the old number coming from each of the inputs that made up the new item.
    
    
28. Will the information need to go back to the bag level (i.e. how does an illness get from the bag to the case)?
    Ideally, you would have a number on the ITEM (a UPC or item-level GTIN) that would link back to the CASE number. However, if the number on the item is not available, the buying location involved in the recall will use their purchase orders to determine which cases of product were sold during the recall period. They will then know which GTIN and Lot #s were potentially involved.
    
    
29. Why did the produce industry take so long to react to the spinach/tomato outbreak and develop a traceability initiative?
    The industry has been working on common coding standards for many years. Many companies have developed their own traceability programs. What has become evident is that we need to link those internal traceability programs with an external traceability program – the PTI. This is part of the ongoing evolution within the industry to improve and enhance food safety and traceability efforts. What’s important here is that this has been developed by and is being driven by industry.
    
    
30. What other traceability solutions are available?
    There are NO other industry-led initiatives for traceability. Individual vendor solutions require everyone to use (or interface with) their proprietary system. The PTI allows companies to have their own internal traceability systems. It also allows for connectivity through the use of standards without having to send transactional feeds to a central repository.
    
    
31. Is 2012 a realistic deadline?
    YES, according to the 48 companies involved in the formation of the milestones and timelines.
    
    
32. How does a retailer track bulk items?
    The PTI is focused at the CASE level. There are other initiatives that are focused on item level identification.
    
    
33. How will local growers track their product?
    The PTI milestones apply to the entire industry
    
    
34. How will non-GS1 codes be handled?
    The standard is a GTIN at the CASE level. The PTI does not recognize non-GS1 codes.
    
    
35. What steps are needed once I have registered for a GS1 company prefix?
    Refer to Milestones 2 – 7. The milestones are in the order by which they should be implemented.
    
    
36. If we have a pallet code and an item code (i.e. code on the clamshell), do we need a case code as well?
    Yes. A pallet code, or more specifically the Hybrid Pallet Label, will give you information on all of the cases residing on a single pallet. However, once that pallet is broken down and mixed with other cases of product on a mixed pallet (i.e. at most distribution centers), the case information will need to be scanned to know when that case of product left that facility. They will not be able to get this information off of the pallet (as they have created a new pallet) or the clam shell (as they will not be opening the case at the distribution center).
    
    
37. What are the guidelines that we should follow for creating the product catalogs?
    You can use the Data Synchronization Best Practices once they are completed.
    
    
38. How would shippers communicate to buyers (retailers and foodservice)?
    The PTI does not prescribe how shippers communicate with their buyers. Trading partners can use various methods to share GTIN information. The Data Synchronization Best Practices are being drafted and will provide additional guidance.
    
    
39. How will the traceability standards affect the smaller shipper?
    If a shipper does not already use case labels, pallet labels and/or barcodes, they will need to begin doing so. The PTI milestones apply to the entire industry.
    
    
40. If I don’t re-label or repack, what are my obligations under the traceability action plan timeline?
    The PTI encourages all supply chain partners to meet the various milestone deadlines. Please refer to the milestones and deadlines outlined in the action plan.
    
    
41. What are the storage requirements of the data at each level?
    ACTION: The PTI agreed to use the same retention requirements as that of the Bio Terrorism Act.
    
    

Topic - DataBar

1. What percent of retailers have the capability of scanning DataBar?
   PMA recently conducted a survey of all US retailer members. 57% of US retail members are either scanning DataBar now or are accepting DataBar, but have not fully implemented yet. The exact percent of retailers capable of scanning DataBar is not known.
   
   
2. What will happen if the scanner isn’t capable of scanning DataBar – will it reject the scan?
   Yes. They will essentially get a “Not on File” read.
   
   
3. Will DataBar benefit the consumer? Will product be able to be traced back using DataBar?
   Product would only be able to be traced back using DataBar if the consumer kept the label after consumption. Otherwise, retailers can proactively contact consumers using a frequent shopper card to let them know if they had purchased a GTIN coming from a specific grower/shipper that is being recalled.
   
   
4. What is the timing for DataBar becoming a common standard used for produce?
   As the DataBar is not an industry-led initiative for implementation, the implementation will be handled trading partner by trading partner. To clarify, the DataBar is not a standard, but a barcode. It will be up to the marketplace on how fast it will be adopted.Whose responsibility is it to link the PLU to the GTIN?
   Those who create their GTINs.
   
   
5. When UPCs are scanned at retail, they identify the supplier. What about private label – whose GTINs are used?
   The owner of the private label.
   
   
6. What happens if the consumer puts multiple apples in a plastic bag with different DataBar labels - will the cashier accurately collect the information from each apple?
   Cashiers will likely have a similar practice with DataBar as they do with PLUs. Currently they enter the PLU and key in the quantity. With DataBar they will likely scan one and then key in the quantity. Cashiers will need to become more aware of the possibility so that correct information is captured.
   
   
7. Is the GTIN on the case the same GTIN that is used on the item? Are there best practices or guidelines established?
   Although the GTIN at the case level and the GTIN used in a DataBar at the item level have the same format/protocol, they are NOT the same number. One number represents the case, one number represents the item. A subgroup under the Produce Electronic Identification Board (PEIB) is creating Best Practices on using the DataBar at the item level. The GTIN Assignment Strategy has already been created for the use of assigning GTINs at the case level.
   
   
8. Does the DataBar contain all of the same information as the GTIN used for traceability at the case level? If not, what is different?
   Remember, the DataBar is a barcode. The GTIN is a number. The DataBar used for produce can only hold 14 digits and is designed to hold the GTIN number (which is 14 digits long). The GTIN is used to (1) link the brand owner to a specific product, as well as (2) to identify something (e.g. a case, an item, etc.). So where the GTIN is used to identify a case, it is also used to identify an item when using the DataBar on the item.
   
   
9. Does the DataBar refer you to the GTIN which contains additional information? Are they one in the same?
   The DataBar is just a barcode. The GTIN is a number (similar to the UPC). The number is the reference used to identify a product having unlimited information tied to that number.
   
   
10. Would DataBar take the place of a pre-printed UPC (i.e. wrapped lettuce, romaine hearts?
    As long as you are using your GS1-issued Company Prefix as part of the UPC, you do not need to change anything. The DataBar is meant to be printed on items that currently have a PLU sticker on them. If you have enough room to put a UPC on the item, that is perfectly acceptable.
    
    
11. Once DataBar is fully implemented in the industry, will the PLU be eliminated?
    The answer to that is unknown at this time. More immediately, the PLU will act as a backup in the event the DataBar does not scan. In comparison, the UPC has the 12-digit human readable version underneath the UPC barcode, to act as a backup if the UPC does not scan. The sticker used to print the DataBar does not have enough room for the 14-digit human readable to show underneath the barcode in the event the DataBar does not scan. As such, our vision is that the PLU will remain for quite some time.
    
    
12. Is DataBar being accepted in the foodservice industry?
    There is no need for the DataBar to be accepted in the foodservice industry as it is designed to be affixed to an item that will be scanned at point of sale (which is in retail, not foodservice).
    
    

Topic - RFID

1. What is it about RFID that doesn’t work today?
   RFID does work, but it has challenges around water and metal.
   
   
2. What is the cost of using RFID?
   There are too many variables to cite an exact cost. On average, the cost of a passive RFID tag is between 15 and 30 cents and the cost of an RFID reader is between $1500 - $3500. But then you have systems costs and middleware costs, all of which vary tremendously depending on your existing systems and other factors.
   
   
3. How much will the cost of tags decrease? And when will they decrease?
   A lot of R&D is being done to make RFID more viable and affordable. No one can accurately predict how fast the cost will decrease.
   
   
4. Is there an industry definition for shrink that can be used to help validate the internal traceability value of RFID across companies?
   There is no standard definition for shrink. However, RFID, if implemented correctly across the supply chain, can certainly help reduce shrink by measuring dwell times and temperature behaviors that can adversely impact shelf-life of product.
   
   
5. What solutions are there for water/metal barriers?
   Currently, there are semi-passive or semi-active tags that can address some of these problems, but the cost of these tags are significantly higher than passive tags.
   
   
6. What is on an RFID chip?
   The most fundamental part of an RFID tag is an inlay. An inlay has a chip and added circuitry. An active or semi-active tag also has a battery (hence, why they are more expensive). This inlay needs to be embedded on some form of substrate (e.g. a label, directly into corrugated, etc.), which is an additional cost.
   
   
7. Are there other frequencies being used beyond the applications being used today?
   There are “frequency wars” going on between countries and standards organizations. Although making headway, it is a very difficult process to land on a standardized frequency to be used for RFID around the world.
   
   
8. What are the downstream recyclable issues with the tags?
   There are tags that are read/write capable that could be recycled. However, it depends on the format by which the inlay is embedded. For example, if embedded into an RPC, the tag would also be reusable. However if the inlay is embedded into corrugated cardboard, it will probably have only one use. Also a consideration would be the life of the battery on the tag. Once the life of the tag has expired, it would be difficult, but not impossible, to extract it from the case just for recycling.
   
   

Topic - Data Synchronization

1. Where do we get assistance on data synchronization?
   The PTI Data Synchronization Best Practices document for case synchronization is currently being drafted and will be available on PMA’s website.
   
   
2. Are retailers willing to bypass B2B platforms for data synch?
   That will depend on the retailer.
   
   
3. Who is the primary beneficiary of the initiative? In what specific situations will this solve an issue?
   Both the buying community and the selling community will benefit. Here are some benefits:
   
   

For the buyer:

• Can track consumer purchases by grower/shipper
• Can track shrink by grower/shipper
• Can accurately ring up conventional vs organic
• Added traceability

1. What’s the most mature industry using the GDSN (Global Data Synchronization Network)?
   The packaged goods and retail apparel industries.
   
   
   
2. What other data pools are available?
   Refer to the GS1 website www.gs1us.org for information on data pools.
   
   
3. Can you provide more information on the data sync subgroup?
   The PTI Synchronization Subgroup will address Milestone #3 in the PTI Action Plan. It recognizes the inability to use GS1’s GDSN for bulk products not having a unique UPC or GTIN at the item level, as well as the reliance produce companies have on third party service providers.