Other recommendations. FDA should clearly identify the types of data that industry needs to provide during an outbreak investigation; coordinate traceback investigations and develop response protocols between and among state and local health and regulatory agencies; and offer extensive outreach and education around future regulations and expectations.
Costs and Benefits
The IFT report devotes 57 pages to cost-benefit analyses but determines that conclusions are not possible to draw because the pilots were narrow and represented, by definition, “an artificial view of reality.” Nevertheless, the report described several companies that had instituted traceability technologies. For example, a small produce grower in Mexico who shipped 100,000 cases annually installed a barcode tracking system. First-year costs, including equipment and installation, totalled $5,500. The company estimated ongoing annual costs of about $1,500 plus a half-cent per label. “That’s not bad at all,” says PMA’s Treacy. While other larger growers, producers, and shippers have spent anywhere from tens to thousands to millions of dollars implementing advanced control systems, these are large systems not specifically installed because of FSMA.
Overall, GS1 US, the PMA, and other members of the Produce Traceability Initiative (PTI) were highly supportive of IFT’s recommendations. “Many of us in the grower/packer/shipper community are pleased to see that the IFT recommends a uniform set of recordkeeping requirements, encourages current industry-led initiatives, and suggests the development of standardized electronic mechanisms for the reporting of traceability data,” said Sabrina Pokomandy, marketing and public relations manager for JemD Farms and cochair of PTI’s Communications Working Group, in a statement. “These recommendations are in alignment with the goals and vision of PTI and help us move forward with industry-wide traceability implementations.”
To submit comments on the IFT report, go to www.regulations.gov and enter docket number FDA-2012-N-1153-0002. Comments are accepted by July 3, 2013.
Agres is based in Laurel, Md. Reach him at [email protected].
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