Grain quality is a broad term, one that means many different things given the context of the evaluation. Regardless of whether you’re looking at the physical attributes of the kernels or monitoring moisture levels, the ultimate goal is the same: money. Once the level of quality has been determined — and hopefully maintained — using grain traceability as a jumping-off point for other process improvements will allow elevators to maximize returns from both a market and a management perspective.
In the United States, grain handlers were introduced to federally imposed grain traceability systems, the tracking of the flow of grain and grain product attributes in the supply chain, as mandated by the FDA in Section 305 and 306 of the Bioterrorism Act of 2002. While Section 305 prompts elevators to register, Section 306 requires registered locations to maintain records, which identify the immediate previous sources and the immediate subsequent recipients of the grain.
“Traceability is a foundational risk management activity,” explains Dr. Tim Herrman, professor and director, Office of the Texas State Chemist, Texas A&M System. “From a regulatory perspective, if you’re going to engage in a recall, you need to be able to trace product one step forward, one step back. Once you look forward to access and manage risk in distribution and draw conclusions, then you’ll likely want to go back from what you’ve identified to the point of contamination and to identify the source.”
In recent years, the government’s regulatory focus has again been drawn toward food tracking and safety — specifically Senate Bill 510, the FDA Food Safety Modernization Act. The committee has recommended the bill be considered by the full Senate.
Under the Bioterrorism Act’s definition of traceability, handlers are not required to track intake down to the field level, and should the FDA visit a premises registered under Section 305, it would not be able to access the records a company keeps in compliance under Section 306 without cause. Once in the elevator, the preservation identity of the grain has not been mandated up to this point. As it stands, Senate Bill 510 could change this.
“Some of the wording is a bit onerous,” says Randy Gordon, vice president, communications and government relations, National Grain and Feed Association (NGFA).
The grain handling industry’s fear is that the bill would not only bring added cost to the agricultural system, but may seriously disrupt the commingled raw commodity handling, shipping and storage system. Most notably, the bill may impose stringent traceability requirements, basically identity preservation in storage and record keeping, with the goal of tracking individual shipments back to individual farms or at least a reasonable number of possible sources.
As is the nature of bulk materials, grain moves through the system as a series of “small sublots” with little identity. Once in the system, it is constantly commingled into larger and larger lots. Making it to the level of traceability proposed by the bill would be a difficult — and potentially costly — endeavor. Ag organizations, like the NGFA, are pushing amendments to the bill, hoping to preserve the economic cost-benefit model currently fueling the grain handling system.
“Senate Bill 510 is an aspiration goal set by Congress that I believe the industry will eventually be able to achieve, but we’re not there yet,” Herrman says. “Yes, at some point we’ll be able to trace grain from any point in the market system to the field(s) of origin — in real time — but I don’t know that it’s realistic within the time frame that is proposed by the Senate bill.”
No doubt the grain industry will push back on wide-sweeping umbrella regulation; however, one should consider that it may only be a matter of time before a major end user requests a level of tracking similar to what has been required in other industries.