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OVERVIEW OF COMMENTS: mpXML received comments of one form or another from approximately ten sources, with most
comments pointing out document inconsistencies or possible technical issues. Several comments did raise a significant concern about the
purpose of the document and if that purpose was being achieved. The comments suggested that existing business practices are not
sufficient to effectively trace product and keep recalled product from reaching consumers, that achieving a minimum level of consumer
protection requires moving to a fully electronic supply chain, and that the purpose of the traceability document is to lay out the electronic
supply chain that will be necessary to achieve minimum traceability. More specifically, the comments suggest the following must be
implemented to have achieved minimum traceability:

* Retail packages must be labeled with a databar, either by the suppliers or for store processed, by retailers.
* The databar needs to contain the lot/batch/serial number in addition to the GTIN
* Retailers need to be able to electronically track cases from the DC to the store.

mpXML as an organization does support the implementation of databar as a means of improving data flow through the supply chain and
use of the databar is suggested as a best practice. However the meat and poultry supply chain includes a diverse array of participants
from farmers growing livestock to vertically integrated suppliers and from “Mom and Pop” retailers to global retailers. Many of these
have significantly different business practices and levels of technology implementation. Defining use of the databar as a minimum
standard would mean suggesting that the meat and poultry supply chain cannot at this point in time adequately trace products and protect
consumers, and further is many years away from being able to protect consumers. mpXML believes that this is not the case, that while
the current business practices are not ideal they are more than sufficient to adequately trace product throughout the supply chain and so
protect consumers. mpXML believes that the purpose of the traceability document is to detail how existing business practices (including
a combination of electronic and human processes) can be used to achieve minimum traceability now as well as detail best practices for
traceability, with best practices providing a possible upgrade path.

mpXML welcomes comments from its members on this very critical issue. Use of the databar as well as other questions raised are
addressed in the grid below, with draft mpXML comments. As part of the review process we need to decide whether or not to adjust the
document to address the comments, and if not a response back to the commenter on why the proposed modification or change was not

Thank you again for everyone's participation in drafting the traceability document.


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SECTION        COMMENTS                                                                         DRAFT RESPONSE
Minimum        COMMENTER 1                                                                      mpXML believes that its members can
Traceability   Remove or change all the sections that make reference to “minimum                today trace products within the supply
               requirements” that do not include the GTIN and Batch/Lot/Serial                  chain with human readable information
               number as a requirement for traceability. The rational for this:                 contained on the consumer package back
                                                                                                to actual production detail information for
               1) Does not meet the definition of traceability. The definition of               the producing plant. Data used in this
               traceability is the ability to trace the history, application, or location of    process include the USDA plant number
               that which is under consideration. I submit that you can’t trace                 and the sell-by/best-by dates.
               products without having consistent data elements that are
               electronically stored in supplier and retailer systems. The UPC-Type The purpose and intent of the Meat &
               2 bar code does not contain consistent data elements that can be usedPoultry Traceability document to to
               to trace products through the supply chain. Human readable           provide supply chain members a road map
                                                                                    to adopt business processes to provide for
               information is not a practical or cost-effective way to trace products.
               Can mpXML provide a schematic of how this can be accomplished?       traceability. As we have a diverse array
                                                                                    of supply chain partners that range from
               COMMENTER 2                                                          farmers growing livestock to vertically
               In our opinion, minimum requirements that do not include the GTIN    intetrated suppliers and from “Mom and
               and Batch/Lot/Serial Number are not consistent with the Industry     Pop” retailers to global retailers, we
               Roadmap document that was developed by the Fresh Foods Trade         cannot define one path to a successful
               Associations (FFTA) participants and published in 2004. We believe process. We must provide a roadmap that
               this sends an inconsistent message to the industry on our            allows everyone to support traceability for
               recommendations for key drivers to accomplish our goals for meat and meat and poultry.
               poultry product traceability in the future.

               Traceability requirements based on data elements being used today do
               not provide a robust system for removing suspect products from the
               supply chain. New regulation is currently being debated that narrows
               the time frame for removing suspect products from the supply chain.
               Suggesting that today’s business practices will meet those
               requirements is not practical and does not consider the long term
               health and best interest of the industry.

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Use of Databar     COMMENTER 1
with               2) Does not encourage the adoption of a systematic way to trace               mpXML has stated that the adoption of
Lot/Batch/Serial   products. To have a reliable food safety system, suppliers and                the databar bar code format will enable
                   retailers must build the GTIN and Batch/Lot/Serial number data fields         our industry to electronically capture
                   into their systems. Minimum requirements that do not include the              information for traceability in a more
                   GTIN and Batch/Lot/Serial number, conveys the message that                    timely and accurate fashion than a manual
                   retailers are tracing products with today’s technology.                       process.

                   3)    Inconsistency between the requirements for case level                   The response here is that the consumer
                   traceability requirements and consumer level traceability. Why                items within the case all fall within the
                   should case level requirements have a higher traceability expectation         case level data which can be electronically
                   than consumer level? I find this ironic because the meat and poultry          captured today. Once the case is broken,
                   supply chain’s final arbiter is the consumer.                                 the consumer items are in the display
                                                                                                 cases and there is no electronic data
                   4) Obscures the true purpose and intent of the goal for traceability.         capture at this point of the process until
                   If the industry is to have a reliable food safety system, traceability has    the product reaches point of sale.
                   to have a higher level of requirements than what we are doing today.
                   The lowest and least requirements will not provide the impetus to    Section6.6.2, P3-batch lot number has
                   move the industry to the GTIN and Batch/Lot/Serial number.           been recommended as one of the 4
                                                                                        application identifiers for the data bar.
                   Section 6.6.1, paragraph 3 – Remove the paragraph. Note that the use The batch/lot value provides partners a
                   of the Batch/Lot Number, (AI-10) in the DataBar is not recommended. distinct value that can be acted upon
                                                                                        rather than an intelligent value that varies
                   Why would we recommend that we limit the use of data elements that from supplier to suppler. The batch/lot
                   will provide the best way to trace products?                         value would require some type of look-up
                                                                                        table to enable a retailer to act upon that
                   How does a sell-by-date provide retailers more reliability than a    value.
                   Batch/Lot/Serial number?
                                                                                        Might capture more than is absolutely
                   COMMENTER 2                                                          necessary, but will insure all is captured.
                   We do have some thoughts on the traceability implementation guide    Further, if trying to recall by Lot/Batch.
                   though regarding the minimum traceability requirements for variable  While in theory a single lot might be
                   weight consumer items (Section This same issue shows up in recalled, almost certain to be many lot
                   Section under Minimum Requirements for Variable-Weight       numbers - many suppliers re-set lot every

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Consumer Items. The issue involves not requiring the inclusion of the hour. Would be a significant lookup table
GTIN and Batch/Lot/Serial Number in the minimum requirements              if trying to catch lot at point of sale. Far
standards, but instead allowing other elements to be used (i.e., sell by  easier to look up
date, supplier company name and consumer item product description, Reality is no standard lot batch,
USDA establishment number and sell-by or use-by date, etc.).              consequently batch lot can be as straight
                                                                          lot one per day, down to a unique lot
LETTER CONTAINED TEXT FROM FOLLOWING SECTIONS:                            batch per production minute per plant.
Section Minimum Traceability Requirements for Consumer
Items (Pg 21); Section Minimum Requirements for Variable-        Most batch lot do link production facility
Weight Consumer items (Pg 39 - 41); Section 6.6.1: Best Practices for to production time.
Consumer Item Traceability, Paragraph 3 (Pg 43)

In the first example above (Section and, you provide
recommended alternatives to the use of the GTIN and/or
Batch/Lot/Serial Number while also stating that “the accuracy of
tracking the specific traceable items is much less successful and often
lends itself to retrieving a greater quantity of product during the trace
process.” In the second example (Section 6.6.1) you also state that
“the use of the Batch/Lot Number, (A1-10) in the DataBar is not
recommended.” We have significant concerns with these statements.

Furthermore, traceability requirements that support the use of current
data elements do not encourage the adoption of data elements that are
needed to have a strong food safety system or a systematic way to
trace products. Minimum requirements that do not include the GTIN
and Batch/Lot/Serial number convey the message that suppliers and
retailers are tracing products effectively and efficiently with today’s
technology. We do not believe this is the case.

We request that you adjust the traceability document to require the use
of the GTIN and Batch/Lot/Serial Number at all levels of traceability
for meat and poultry products. Encouraging the adoption of these new
technologies will provide long-term benefits to the meat and poultry
supply chain including lower cost distribution systems and the
potential for increased sales of products. As importantly, it provides
peace-of-mind from the threat of food tampering in the supply chain.
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If we could scan the Databar in the stores and we have say GTIN,
DATE, Weight and Price I am wondering how we could set our POS
up to prevent that item from scanning. Now I know I can load GTIN
and DATE but I could exclude some good product.

-      If the supplier had 4 LOT produced in a day and only one was
a problem
-      If a supplier had two plants and only on Plant had a problem
o     In reality that would likely also be a different LOT.

This is why I think DataBar will need to have the GTIN and LOT in it.
This will pose challenges on both Supplier packaged and Retailer
packaged product. It would mean a lot more discipline are production
and labeling time.

So want is my point? Well I am not sure if the discussion is not
complete. If RETAILER is going to invest in doing to Databar I
would think that we would want to get to a LOT level. If we are
producing in the store (cutting) we would already have to take the
GTIN from that CASE and the PRODUCTION DATE from the case
and transfer that to the Package. I am thinking we would not have

CARGILL BEEF GTIN 1012345000123 è Safeway t-bone GTIN
SWIFT BEEF GTIN 1054321000223 è Safeway t-bone GTIN

We would have
CARGILL BEEF GTIN 1012345000123 è Safeway t-bone
(EXCEL) GTIN 1000123444311
SWIFT BEEF GTIN 1054321000223 è Safeway t-bone (SWIFT)
GTIN 1000123444351

If we did not assign GTIN by Supplier then we are no better off the
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SYSTEM-2 UPC. If have to remember the Supplier for the item we
cut then it may not be a stretch to also remember the LOT as well.
When we wrap we could record both on the DataBar

Now this would be a long term goal and I do not know if it is
achievable. I just do not want to have the DataBar fallow the GS1-128
path on the case where other business process used up the space and
we could not get to the LOT if we really needed to.

So just a forward thinking view. I was never convinced that GTIN and
DATE was a good tracking approach for the packages. It just seemed
glossed over by the suppliers.

Our general idea was once a package got out of the case you could not
trace it back to that case. I think that that is still a valid statement. But
I do not se that as a reason we can not make the identification of a
package more granular than Date. For example Tyson has 9 PORK
plants. Would it make sense for RETAILER to stop selling a GTIN in
all areas of the country based on one date of production?

-     What if only the Logansport plant is implicated?
-     What if Safeway did not even receive any product from

If anything Tyson could simply add a RETAIL LOT to the package
that is simply Julian Date and EST Number. Now GTIN and RETAIL
LOT can be loaded into Store controllers and stop the sale but allow
the sale of 8 other plant produced product.

I can understand the where Supplier do not want the reasonability to
record which packages got into which boxes but I think the RETAIL
LOT would be a way to track the sale of Retail Product to a Supplier,
Plant, Day where a BOX GS1-128 can get you to a Supplier, Plant,
Day and Raw material used.

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Use of Supplier      REPEATED COMMENT FROM ABOVE                                                    Just to clarify, a retailer processing
GTIN by              … So want is my point? Well I am not sure if the discussion is not             primals cannot just transfer a supplier
Retailer for Store   complete. If RETAILER is going to invest in doing to Databar I                 GTIN to a retailer package. If the product
Processed            would think that we would want to get to a LOT level. If we are                is modified in any form from its original
                     producing in the store (cutting) we would already have to take the             state a new GTIN must be assigned by the
                     GTIN from that CASE and the PRODUCTION DATE from the case                      retailer, not use the GTIN of the supplier.
                     and transfer that to the Package. I am thinking we would not have

Inclusion of         TEXT INCLUDED FIGURE 11 GS1 DATABAR WITH GTIN,                                 In some ways this is a more general
Weight in            PRICE WEIGHT AND DATE.                                                         discussion of what data elements need to
diagrams                                                                                            go into a databar. While an important
                     I can understand                                                               business discussion it falls beyond the
                                                                                                    scope of the traceability document.
                     -      GTIN – Identify the item                                                Weight was included in the databar
                     -      Price – How much does the product cost                                  example because at this point supply
                     -      Date - Is the product still good to sell                                chain participants expect it to be there.
                     o     This is not use for Tracking or Recall really                            Databar is an evolving standard and
                                                                                                    recommendations will likely change once
                     I do not understand Weight. This really does not need to be there in           it is implemented in the supply chain.
                     my view. Now the weight is needed to be on the label but I do not see          However again, that discussion is beyond
                     the need to have it in the scan bar. I would replace that with a LOT.          the scope of this document.
                     Now maybe this is something like a VENDOR RETAIL LOT that
                     adds to the Date and not the serial number of the case.

                     Anyway I am not sure why the retailer needs to capture the weight of
                     the retail unit (useless it is for inventory control at a weight level) but
                     this can always be calculated by Package Price / Price per LB. Our
                     Retail POS systems need to have the Price Per LB even if it is labeled
                     by the Vendor.

                     Anyway it would likely be years before this comes up but I just
                     wanted to understand the reasons behind weight.

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Recall Section     GENERAL COMMENTS FROM GROUP                                                  New pdf - critical tracking events 2009-
                   Possibility of diagram showing critical tracking events?                     11-25
Does not include   It’s obviously limited to traceability from processor forward, which is Commenter is correct, this does not
the Farm           a different segment than what we traditionally think about with              extend back to the farm. It does however
                   traceability to the farm. It needs to be highlighted that this is the case, detail the data elements a supplier will
                   so is limited in its scope. I think it could be a much smaller, simplistic need to establish an upstream link for
                   document. And it does refer the reader to GS1 for a lot of additional        product received for processing.
                   information. I think the length is problematic for the general               SUGGESTED CHANGE: Add a
                   audience, a clearer concise version, maybe and industry piece would          clarifying sentence to the scope section to
                   be more useful.                                                              note that the farm is out of scope.

                   Section 5.8 deals with the live animal provider. This looks very
                   simplistic and limited.
Use of Barcode     This document relies almost entirely on the bar code, and the GS-1          We have tried to provide guidance that
vs. human          system, and given that this is a GS-1 document, you would expect            would support not only electronic data
readable.          that. It seems that the missing part is how to manage all the data.         capture but also human readable element
                   This is the heart of the issue. It’s easy to get bar codes, GTIN            that could be captured to support
                   numbers etc. and put them on all your product, but managing all that        traceability. We agree that the industry
                   information is the key. Moving towards the GS1 data bar will help,          needs to keep human readable information
                   but that’s a long term process of adoption. But keeping basic human         on packages.
                   readable information is also key, especially in consumer recall
                   situations.                                                                 In reference to the length, we have
                                                                                               attempted to keep the document as short
                                                                                               as possible while repeating some key
                                                                                               sections and concepts to improve the
                                                                                               readability for supply chain members that
                                                                                               will focus just on one section, for instance
                                                                                               the Retailer section.

6.6.1 - Sell by    In 6.6.1, the sell-by-date is talked about. I know this is controversial,   The document is targeted at the U.S. or
date               and there are other descriptions that’s might be more acceptable            possibly North American supply chain,
                   internationally, such as “best if used by”, or actual pack date, need       not the international meat market. As we
                   more work and definition here.                                              work to promote adoption into a global
                                                                                               solution we will add additional attributes
                                                                                               where it makes sense. See section 5.1.3

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                                                                                   for guidance on data types.
5.8                                                                                Not in scope, variety of practices.
                                                                                   Highlighted critical data to be captured by
                                                                                   supplier, at point which scope begins.
        In looking at the IFT report, I think this document and GS1 address        Agreed - data storage will be critical to
        many of the Core recommendations and best practices in the IFT             the process. However the document does
        document, including the standardization of key data elements.              not discuss strategies for data storage,
                                                                                   which is out of the scope of the document.
        But again I think the key is reading, interpreting, and storing the
        information, which requires huge logistics and capital improvements.
        Also, there could be more of an educational component to this,
        potential scenarios, examples, etc.
Cover   This is the first time that this document has been presented with a        Agreed, already adjusted.
        cover & I must say that I don’t think that it’s appropriate. This makes
        it look like it’s a GS1 document instead of an mpXML document. I
        believe that mpXML should be on the cover. I don’t object to GS1
        being on the cover also but it should be in a much less dominant
5.7.1   Paper Bills of lading don’t normally include the details included in       Open for more discussion. Some
        section 5.7.1. Most suppliers only include the item/product code,          feedback that the data elements laid out of
        quantity and weights, but do not include GTINs, batch/lot, serial          the paper bill of lading are greater than
        numbers if used, or production/sell-by dates, USDA plant numbers,          what's provided on today's paper bill of
        etc. This information is provided in electronic ASNs, but there is not     lading, and while the info is normally
        enough real estate on a paper bill of lading to include.                   included in the electronic document there
                                                                                   was a concern with the additional paper
                                                                                   required to provide the additional data
7.0     Clarify/change the use of recall versus market withdrawal in 7.0 Use       Need to get USDA definition for recall
        the USDA definitions. Recall is the removal of product for food            and note difference between recall and
        safety hazards versus withdrawal for non-food safety issues.               market removal. Edit Recall section to
                                                                                   note this difference but that the Recall
                                                                                   section covers both situations.
3.0     Section 3.0. This will require us to keep transactional data longer.       Yes, it is true. Maintaining the link
        Should we agree to keep everything at the same level, i.e. case?           between flow of products with info about
                                                                                   them should be tied to the lifecycle of the

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                                                                              product. Thus for frozen, with longer
                                                                              shelf life, participants may need to expand
                                                                              their storage of transactional data to
                                                                              support that timeline for the lifecycle.

                                                                              If the supply chain were to look at
                                                                              consumer separate from case participants
                                                                              have added a lot more data and will have
                                                                              to keep longer depending on the storage
                                                                              type to insure it got through the supply
                                                                              chain. mpXML's recommendation is to
                                                                              store data at the case level.

You should include an example of fixed-weight along with the                  Agreed.
variable-weight example GS128 (the barcode in figure 18 shows one).
Although it is shown later in the document, I noticed it was missing in
this part and didn’t find it until much later. I know it’s hard to believe
but not everyone will read the complete document

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