The name is absent



tomato juice cocktail drink was in conformity with a new agency
interpretation of labeling standards for this product.

The agency’s new objective was to assure that any dehydrated
ingredients added for flavoring would be prominently identified as
such. Also that the labels applied to our product and the labels’
vignettes would not include the word “juice” if any dehydrated
ingredients were used in the manufacturing process.

This is a relatively small volume product for our company. It is
produced principally to accommodate the assortment needs of our
private label customers. Thus, our problems in responding to these
new labeling requirements were compounded not only by the
necessity to advise customers of label changes, but also because of
our inability to fulfill a substantial volume of orders on hand which
include this product as a minor component of each ordered
shipment.

More than a month’s time was required to clarify our situation,
to notify customers of necessary label changes, and to resume
shipments. Even more significantly, we lost hundreds of thousands
of dollars in sales because of our inability to fill orders during the
involved period.

We remain perplexed as to why we were selected for this
attention from among a large group of manufacturers of this
product. We are especially curious as to why the manufacturer of
the principal advertised brand — which is estimated to supply more
than 75% of national consumption — apparently has not been
required by the agency to change its labeling practices as we were
last year.

Why, indeed, would an insignificant producer like Tri-Valley be
so forcefully brought into compliance with the new requirements?
Was it a form of bureaucratic retaliation for our public
announcement of the reason for the elimination of 1,800 jobs in
Modesto? We don’t know.

What we do know is that two days into our resumption of
canning operations this past summer, after an 11-day strike by
cannery workers against industry employers, back to our cannery
came an agency inspector for meticulous and time consuming
examination of our past year’s compliance with the labeling
practices uniquely enforced on our firm’s tomato cocktail drink.
This was at a time obviously when all plant and technical
management were heavily absorbed in the incredibly difficult tasks
imposed by this loss of critical production time.

71



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