LacTracker(TM) - Lettuce Seed Identity Preserved Program

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The LacTrackerٰٰ™ Produce Sustainability and Integrity Program (LacTracker™) - developed and administered by the California Crop Improvement Association (‘CCIA,’ also referred as ‘agency’) -provides a uniform and unbiased quality assurance system and marketing tool for lettuce seed.  The ‘Produce Sustainability and Integrity Program (PSI™)’ logo identifies seed and produce products (vegetables and fruits) that meet specified product quality requirements for growing, harvesting, conditioning, priming, pelletizing, sampling, handling, varietal purity, seed purity, seed germination, product labeling, traceability, and sustainability.  The program provides unbiased, third party assurance of supply chain integrity.  Inspections and audits will be performed to verify compliance with system requirements at specified stages of production.  Enrolled production is traceable between pre-determined points in the production process.

LacTracker™ Consists of Two Tiers:
Tier 1:  Lettuce Seed Integrity and Quality
Tier 2:  Verification of Sustainable Production of Lettuce Seed

Tier 1: Lettuce Seed Integrity and Quality

Participants who produce lettuce seed in compliance with LacTracker™ Tier 1 requirements (outlined herein) shall be eligible to label lettuce seed with the ‘LacTracker™ Produce Sustainability and Integrity Program Tier 1’ logo.


  1. To provide coordinated, professional, third-party unbiased field inspections and laboratory testing for quality control in lettuce seed production, conditioning, and marketing.
  2. To provide an evidence based, transparent record system for use in meeting the requirements of California Seed Law and the Federal Seed Act and to help solve potential problems in seed commerce.
  3. To provide a retail or wholesale marketing image of sound quality control assurance, traceability, and sustainability for selling lettuce seed products in the marketplace.
  4. To provide seed buyers with assurance that lettuce seed enrolled in the LacTracker™ Produce Sustainability and Integrity Program has met quality standards related to a known description to facilitate product identification and quality.

Record Requirements:

  1. Records (as detailed below) shall be kept by applicants for a period of three years following seed lot approval by the California Crop Improvement Association (CCIA).  Records shall be adequate to allow CCIA verification of adherence to required production and processing practices.
  2. The CCIA shall require access to required records for agency inspection.
  3. Production records including proof of seed source, grower information, land history, isolation, grower training, etc. shall be adequate to provide seed traceability throughout the production process.
  4. The name of the individual(s) responsible for creation, retention and control of records shall be documented.
  5. All actions for determining conformance of the seed to LacTracker™ standards including inspection, testing, assessing the production system, and handling of the seed products produced, shall be documented.

System Audits and On-site Inspections:

  1. The CCIA shall perform inspections and/or audits as necessary to verify that the production system is meeting stated product quality objectives.
  2. The CCIA shall establish and document processes for performing audits and inspections including:
    1. Evaluation points in the system.
    2. Identity and qualifications of evaluators.
    3. Inspection/audit methods to be used.
    4. Rules for the selection of samples for testing and evaluation.
    5. Reporting methods and records generated.
  3. For evaluation activities not performed by the agency, the agency shall establish and document the process used to evaluate, approve, and validate the performance of evaluators and the accuracy of evaluation results.

Annual System Review:

  1. The CCIA shall annually review all members utilizing the LacTracker™ program in order to validate the effectiveness of the system in achieving the quality objectives.
  2. Corrective actions shall be required for identified non-conformities within a thirty day period from the date the audit was performed.
  3. Program modifications, if any, shall be submitted to AOSCA for final approval of its Produce Sustainability and Integrity Program.

Certificates/Labels Bearing the AOSCA IP Logo:

The purpose of the Produce Sustainability and Integrity (PSI) logo is to identify products that have met specific requirements designed to preserve the genetic and physical identity of seeds of vegetables and fruits that meet specified product quality requirements for growing, harvesting, conditioning, priming, pelletizing, sampling, handling, varietal purity, seed purity, seed germination, product labeling, traceability, and sustainability.

  1. Use of the AOSCA PSI logo on product labels, certificates, or promotional pieces shall indicate conformity to all program requirements.
  2. All certificates and labels must clearly state the program name.
  3. The CCIA shall require the withdrawal or removal of all PSI tags in the event of product non-conformance.  Tags and certificates that have been removed from storage containers and/or seed packages must be saved for collection by CCIA personnel.
  4. In the event of a revision of the PSI program, the marking must clearly indicate the appropriate edition of the program so that the user is informed correctly of the product requirements.
  5. The CCIA shall perform surveillance to control the use of certificates and labels bearing the AOSCA PSI logo.
  6. In cases of misuse of the AOSCA PSI logo, corrective actions comprising suspension or expulsion from future program participation shall be taken to safeguard its use.

Crop Specific Requirements

A. Eligibility Requirements:

Eligibility for participation in the LacTracker™ Lettuce Seed Identity Preserved Program shall be determined by the CCIA.

The following items must be made available to the CCIA by the applicant when eligibility for the LacTracker™ Produce Sustainability and Integrity Program is requested:

  1. The name of the type (e.g. “Lettuce”), cultivar (e.g. “Romaine”), and variety (e.g. “Little Caesar”).  This name must be the established name of the variety in compliance with the Federal Seed Act that has been described and documented.  A copy of a Seed Label, Intellectual Property Registration, PVP Number, or Patent Number.
  2. A statement concerning the variety’s origin and breeding history (if available) signed by the applicant.
  3. A detailed description of the morphological, physiological, and other characteristics of the plants and seed that distinguish the type, cultivar, or variety from other types, cultivars, or varieties.  The applicant should include a statement describing any expected variation of the type, cultivar, or variety.
  4. A statement delineating the geographic area or areas of adaptation of the type, cultivar, or variety.

B. Applicant’s Responsibilities:

  1. Care of Equipment:
    1. Applicants, growers, and handlers of PSI seed are responsible for determining that all equipment used for planting, harvesting, conveying, storing, handling, and conditioning is thoroughly cleaned and free from all contaminants before handling PSI seed.
    2. Planters must be thoroughly cleaned and inspected prior to planting.
    3. Harvesters, conveyance devices, and storage equipment must be cleaned of other seed prior to harvest.
    4. Facilities that perform seed conditioning, priming, and/or pelletizing must be approved or accredited by the CCIA and must be inspected prior to conditioning, priming, or pelletizing PSI seed.
  2. Maintaining Identity of Product:
    1. Each field must be identified with a number or other designation on the field application form and other pertinent documents.
    2. Maps showing field identities and locations must be maintained and provided to crop inspectors.
    3. Field inspected product must be positively identified at all times.
    4. A unique lot number must be assigned and all seed containers (bins) should be properly labeled with the correct lot number.
    5. When seed is packaged, all seed containers (seed count boxes) must be marked with the correct lot number and/or with a tag that is securely fastened to the packaging that shows the lot number.
  3. Record Requirements:
    The following records must be maintained:
    1. Field number
    2. Amount of product harvested
    3. Assigned bin number
    4. Record of any product transfers (see sections C and M below)
    5. Assigned lot numbers
    6. Copies of all completed agency documents

C. Movement of Seed

When seed enrolled in the LacTracker™ Produce Sustainability and Integrity Program is moved prior to tagging, it must be properly identified.  It is the responsibility of the applicant or grower to request a Seed Transfer Certificate form prior to the seed being moved.  This form is for movement of seed Intra-County, Inter-County, or Inter-agency (State).  The form is available to members on the CCIA web site.

The form may be initiated by the Agricultural Commissioner or the applicant/grower. The form must be signed by both parties and copies provided by mail, fax, or email to the Consignee, the CCIA office, the Agricultural Commissioner’s office (both counties if applicable), shipper, and the receiving agency (if out of state).

D. Land Requirements:

Fields eligible for the LacTracker™ Produce Sustainability and Integrity Program must not have grown lettuce the previous year unless the lettuce was the same variety planted (within the LacTracker™ Program) and met field inspection requirements for varietal purity.

E. Application for Field Inspection:

The application must include the following:

  1. Applicant’s address and telephone number (Company name and Individuals name)
  2. Grower’s address and telephone number
  3. Field number
  4. Variety Name
  5. Statement that applicant wishes to enroll this seed in the LacTracker™ Produce Sustainability and Integrity Program
  6. Planting date
  7. Field size
  8. Field location
  9. Previous crop
  10. Seed source identity
  11. Signature of applicant.

F. Establishing Source of Seed:

The CCIA shall be supplied with verification (tags, written statements from breeders, etc.) of the source of seed used to plant each field applied for inspection.

G. Field Inspection:

  1. Field Inspection Applications will be submitted to the CCIA identifying the field(s) to be inspected. Varieties must conform to the accepted description.
  2. One or more field inspections shall be made by the CCIA when genetic purity and identity or any other factor affecting product identity can best be determined.  The field shall be in such condition to permit an adequate inspection to determine genetic purity and identity.  General field conditions will be reported along with other information requested by the applicant.
  3. After fields pass inspection, a field inspection report will be issued with a unique PSI number assigned by the CCIA.  This number must accompany the seed lot thereafter.
  4. Seed conditioning facilities must be approved or accredited by the CCIA and inspected prior to conditioning seed.  It is the responsibility of the applicant to make sure his/her field has been inspected before it is harvested or eligibility of the field in question to be included in the LacTracker™ program will be denied. 

H. Field Standards:

Isolation -- Fields in the LacTracker™ Produce Sustainability and Integrity Program must be separated from another type, cultivar or variety by a definite boundary of 8 feet or more in width. 

Off-types -- Every field should be rogued to remove any plants of another crop or variety. Varieties cannot always be differentiated at field inspection.  When differences can be distinguished, the maximum mixture of other varieties permitted is as follows:

(1st Generation)
(2nd Generation)
(3rd Generation)
1 Plant:10,000 Plants 1 Plant:5,000 Plants 1 Plant:1,000 Plants

Weeds -- Fields must be free of any prohibited noxious weeds (including noxious weeds that could possibly be separated during conditioning).  Restricted noxious weeds, and common weeds difficult to separate must be controlled.  Prohibited and Restricted noxious weeds are listed in the California Seed Law/CA Code of Regulations/Sections 3854 and 3855.

Diseases -- Fields must be free of the following diseases:

  1. Lettuce Drop (Sclerotinia minor and Sclerotinia sclerotiorum)
  2. Verticillium wilt (Verticillium dahlia)
  3. Downy Mildew (Bremia lactucae)
  4. Bacterial Leaf Spot (Xanthomonas campestris pv. Vitians)
  5. Fusarium Wilt (Fusarium oxysporum f. sp. Lactucae)
  6. Lettuce Mosaic Virus - The crop must be free of lettuce mosaic virus as required by Monterey County Ordinance.  Inspections will be conducted by the Agricultural Commissioner in the county where the seed is grown and copies of the County’s field inspection reports must be supplied to the CCIA .

I. Harvesting:

Harvesting is subject to the supervision of the County Agricultural Commissioner who must be contacted prior to harvest.  Any seed moved out of the county for conditioning must be accompanied by transfer permit issued by the California Crop Improvement Association (see section M).

J. Conditioning, Priming and Pelletizing:

Conditioning, priming and pelletizing of seed within the LacTracker™ Produce Sustainability and Integrity Program may be done only in facilities approved for this purpose by the California Crop Improvement Association.  It is the responsibility of the applicant to determine if the facility is eligible before delivering seed for conditioning.  Conditioning, reconditioning, sampling, blending, priming, and pelletizing must be supervised by the County Agricultural Commissioner.  Conditioning, priming and pelletizing equipment must be free from contaminating seed to the satisfaction of the supervising inspector.

K. Product Handling

The following requirements shall be met:

  1. Facilities shall be available to perform handling without introducing mixtures.
  2. Identity of the seed must be maintained at all times.
  3. Records of all operations relating to the program shall be complete and adequate to account for all incoming seed and final disposition of seed.
  4. Handlers shall permit the CCIA to review all records pertaining to the program and seed.
  5. Approved handlers shall designate an individual who shall be responsible to the CCIA for performing required duties
  6. Approval of handlers shall be on an annual basis.
  7. Approved conditioner guidelines shall be the same as those required for Certified seed production in accordance with CCIA standards.

L. Seed Sampling and Testing

  1. Representative seed samples of each cleaned seed lot must be drawn by Certified Seed Samplers who have been issued a Certified Seed Sampler Certificate from the California Crop Improvement Association and who possess a Seed Sampler ID Card and Number from the Association of American Seed Control Officials (AASCO).
  2. A representative seed sample of 450 grams from the cleaned seed lot will be submitted to an approved seed laboratory and tested for varietal purity, germination, and physical purity by a Registered Seed Technologist in accordance with the Association of Official Seed Analysts (AOSA) rules for testing seed.  Seed purity standards are shown below in Table 1.
  3. The CCIA requires Reports of Analyses for lot approval to be dated no more than a maximum of six (6) months prior to the request for seed tagging with LacTracker™ PSI tags.  Purity Analysis and Germination testing must be conducted on the same laboratory seed sample and those results must be presented in a single Report of Analysis issued by a Registered Seed Technologist.

Table 1.  Seed Standards for the LacTracker™ Produce Sustainability and Integrity Program

All seed lots must be sampled and tested after conditioning and the seed lot must meet or exceed LacTracker™ Produce Sustainability and Integrity Program standards.  Seed must be well screened and graded, bright in color, of good appearance and meet the following standards:

Seed Purity Standards Standards for Each Class
Quality Factor IP-1
(1st Generation)
(2nd Generation)
(3rd Generation)
Pure Seed (minimum) 98.00% 98.00% 98.00%
Inert matter (maximum) 2.00% 2.00% 2.00%
Weed seeds (maximum) 0.05% 0.05% 0.10%
Noxious weeds None None None
Total other crop seeds (maximum) 0.05% 0.10% 0.20%
Other varieties (maximum) 0.05% 0.10% 0.20%
Other kinds (maximum) None None 0.01%
Germination (minimum) 80.00% 80.00% 80.00%

FINAL LOT APPROVAL AND LABELING -- If the seed sample meets all standards, a seed inspection report will be issued.

M. Transfer of Product Prior to Labeling:

The following transfer options are available:

  1. Intra-County (for transfer between two facilities within a single county in California)
  2. Inter-County (for transfer between two counties in California)
  3. Intra-State (within the state) - an affidavit of seed transfer stating the number of pounds or ‘seed count boxes’ transferred must be provided before labels can be issued.
  4. Inter-State (for transfer between two states)
  5. Inter-Agency (for completion of the LacTracker™ Produce Sustainability and Integrity Program between states, contact the California Crop Improvement Association for Instructions).

N. Carry-Over Product:

All eligible product not used in the crop year of production must be reported to the agency to maintain eligibility for future labeling.

O. Labeling:

Seed meeting specific program requirements may be labeled using the LacTracker™ Lettuce Seed Produce Sustainability and Integrity Program logo.

  1. PSI tags will be printed and issued by the CCIA for seed lots meeting the LacTracker™ Produce Sustainability and Integrity Program field and laboratory standards for purity.
  2. The tags shall be green in color and have printed on them the AOSCA PSI Logo (a registered trademark), the phrase “Produce Sustainability and Integrity Program,” and “Member of the Association of Official Seed Certifying Agencies.”  The tag must also show the name of the PSI program (LacTracker™) Produce Sustainability and Integrity Program Program).
  3. The PSI tag will be imprinted with crop kind, type, cultivar and/or variety, and generation number (IP1, IP2, or IP3).  The tag will also contain the lot number and the assigned LacTracker™ PSI number.
  4. Upon request, analysis information may be printed on the tag.

Tier 2: Verified Sustainable Production of Lettuce Seed

Participants who produce lettuce seed in compliance with LacTracker™ Tier 2 requirements (outlined below herein) shall be eligible to label lettuce seed with the ‘LacTracker™ Produce Sustainability and Integrity Program Tier 2’ logo.

Participants in the LacTracker™ Tier 2 Program shall demonstrate continuous and measurable efforts to improve sustainability in the areas of nutrient management, soil health, water quality, water conservation, air quality, greenhouse gas emissions, packaging, pest control, crop and landscape diversity, and human wellbeing. 

The term ''sustainable agriculture'' (U.S. Code Title 7, Section 3103) means an integrated system of plant and animal production practices having a site-specific application that will over the long-term:

  • Enhance environmental quality and the natural resource base upon which the agriculture economy depends.
  • Make the most efficient use of nonrenewable resources and on-farm resources and integrate, where appropriate, natural biological cycles and controls.
  • Sustain the economic viability of farm operations.

Science-Based Sustainability Measurements

The Lactracker™ Tier 2 program will address sustainability utilizing science-based measurements.  Participants shall keep written or electronic records of all activities as specified below.

1.  Nutrient Management and Soil Health
     A.    Soil Conservation: Participants shall employ one or more of the following soil conservation methods to help prevent loss of soil caused by wind and water erosion:
             a.    Strip cropping
             b.    Reduced tillage or no-till 
             c.    Cover Cropping. Participants shall grow plants such as rye, clover, or vetch after harvesting a grain or vegetable crop or intercropping them in order to provide weed suppression, erosion control, improved availability of soil nutrients, and improved soil quality.

     B.    Nutrient Management: Soil testing shall be conducted and documented annually to ensure optimization of manure, nitrogen, and other plant nutrient applications to improve the soil and protect the environment from overuse of fertilizers. Use of on-farm nutrient sources, such as manure or leguminous cover crops, is encouraged to reduce purchased fertilizer costs.

     C.    Compost:  Periodic applications of compost (every two to three years) are strongly encouraged to improve soil structure and to help control soil borne diseases.  Compost applications must be documented and records shall be maintained for a period of seven years.

     D.    Crop Rotation:  Participants shall practice crop rotation to foster soil health, reduce weeds, and reduce the build-up soil pathogens.

2.  Water
Water conservation and protection are an important part of agricultural stewardship.  Participants in the LacTracker™ Tier 2 Program shall use irrigation water efficiently via drip irrigation if possible.  Samples of irrigation water and “tail-water” (if any) shall be collected monthly and tested for chemicals, pesticides, and fertilizer contaminants to ensure that these pollutants are not adversely impacting soil, groundwater, wetlands, lakes, rivers, or oceans.  Records shall be kept for a period of seven years.  Practices such as planting riparian buffer strips are encouraged to improve the quality of drinking and surface water and to help protect wetlands

3.  Packaging
Seed must be packaged utilizing sustainably designed packaging that can be recycled.  Packaging must be constructed of sustainably produced or recycled raw materials (cardboard, plastics, or metals).  Cardboard packaging vendors shall be ‘Sustainable Forestry (SFI) Certified.’  Waste should be minimized through design modifications that reduce the weight of packaging materials.  Reusable pallets and reusable plastic containers should be utilized whenever possible.

4.  Pest Control
Participants shall practice Integrated Pest Management (IPM) which is an approach to managing pests by combining biological, cultural, physical, and chemical tools in ways that minimize economic, health and environmental risks.  Records of all pest control measures and pesticide applications (including insecticides, herbicides, fungicide, rodenticides, and soil fumigants) shall be kept for seven years following the time of application.  Pesticide applicators shall use coarse spray droplets when applying pesticides and shall avoid applying pesticides during windy conditions or during temperature inversions that would foster spray drift.  Pesticides should not be applied at any time when bee pollinators might be killed.

5.  Air Quality and Green House Gas Emissions
Participants in the LacTracker™ Tier 2 Program shall utilize best management practices to improved air quality and reduce Greenhouse Gas Emissions.  Measures shall include use of electric water pumps (as opposed to diesel powered pumps) and use of dust control measures on roads.  Participants should utilize electric and/or LP powered forklifts whenever possible in order to reduce greenhouse emissions.  Participants shall keep records of fuel, electricity and water usage as well as dust control activities undertaken for a period of seven years. 

6.  Crop/Landscape Diversity
Participants in the LacTracker™ Tier 2 Program are encouraged to grow a variety of crops to help reduce risks from extremes in weather, market conditions, or pests.  Increased diversity of crops and other plants, such as trees and shrubs, can also contribute to soil conservation, wildlife habitat, and increased populations of beneficial insects.

7.  Human Wellbeing
Participants in the LacTracker™ Tier 2 Program shall:
     A.    Respect Human rights, show consideration for workers, and allow meaningful opportunities for workers to be heard.
     B.    Comply with all applicable laws and agreements regarding compensation and working hours.
     C.    Provide a safe and secure work environment and enforce a written safety program.
     D.    Allow freedom of association and the right to collective bargaining by employees.
     E.    Ensure freedom from workplace abuse.
     F.    Provide a fair and inclusive work environment and prevent discrimination and harassment.
     G.    Foster diversity, inclusion, and gender equality.
     H.    Combat forced and underage labor including debt bondage and human trafficking.
     I.    Protect vulnerable migrant workers through responsible recruitment.
     J.    Foster long-term employment.
     K.    Work to enhance farm-worker access to medical technologies such as medical and dental health plans as well as offer 401K retirement plans for employees.
     L.    Actively participate in local boards and non-profit organizations that contribute to the construction of youth sports facilities

Records of these activities shall be kept for seven years and shall be made available for inspection by CCIA auditors upon request.

Audits by the CCIA:

The California Crop Improvement Association shall conduct annual audits of all participants in the Lactracker™ Tier 2 Program to verify and assess efforts by participants to comply with the provisions of the LacTracker™ Tier 2 Program as specified above.

Draft 5 July 5, 2021