HOW FAR do crop producers have to go to prove the corn, soybeans or hay growing in their fields is safe for animals or people to eat? Today the U.S. Food and Drug Administration's trace-back requirements for field crops and hay are relatively simple to follow, but some officials predict more detailed records could be necessary in the future. Although you aren't required to tag every single hay bale yet, it might be a good idea to start moving toward collecting more detailed information about that grain or hay crop.
According to the Public Health Security and Bioterrorism Preparedness and Response Act of 2002, if animals or humans get sick due to contaminated food or feed, and the feed ingredients may have originated on your farm, an FDA agent may come knocking at your door. Food safety is the goal behind the requirements agricultural producers need to meet in order to comply with the Bioterrorism Act.
Right now, grain handlers, feed mills and processors bear the major responsibility for tracking grain or hay. Most producers will only need to be prepared to provide information on the grain and hay they sell, showing “one step up and one step back,” according to industry officials. This means being able to show where the grain or hay came from and where it was sold.
What is “compliance”?
There is some confusion among producers regarding just what “compliance” means in regard to the Bioterrorism Act, what action needs to be taken, and even questions about who is required to provide what information. The FDA provides answers to many of the questions on Web sites such as www.fda.gov/oc/bioterrorism/bioact.html. However, just sorting through all the jargon to get to the agricultural information is challenging.
According to FDA officials, some producers think they don't have to keep records simply because they have heard that farms are exempt from the Bioterrorism Act requirements. But that is not necessarily the case. It is crucial to read the definition of “farm” closely. As FDA officials point out, the Recordkeeping Final Rule (Title 21 of the Code of Federal Regulations (DFR), Part 1, Subpart J) does exempt “farms” from all record-keeping requirements. Keep reading! It is important to pay attention to the details of the definition, because “farm” is defined as a “facility in one general physical location devoted to the growing and harvesting of crops, the raising of animals (including seafood), or both. The term ‘farm’ includes: 1. Facilities that pack or hold food, provided that all food used in such activities is grown, raised, or consumed on that farm or another farm under the same ownership; and 2. Facilities that manufacture/process food, provided that all food used in such activities is consumed on that farm or another farm under the same ownership.”
So if you sell what you grow, and you don't own the buyer's farm, you may have to provide information for the transfer of records.
Information to the elevator
“The farmer is not exempt from providing the information to the elevator regarding where that crop came from, for example,” says Howard Shepherd of the Iowa Grain Quality Initiative, a program of Iowa State University. When a producer delivers his grain or hay, he has to pass on information regarding who he is, what the farm address is, and his telephone number, e-mail address and/or fax number. This is required when the producer decides to market the grain to another buyer, whether it comes right out of the field, into the wagon, into the truck and into town, or whether it goes into a bin before going into town.
“As soon as that grain goes out of the gate from the farm facility to another buyer, the information needs to go along,” Shepherd states. “Once the transfer is complete, the scale ticket from the elevator can serve as documentation that the grain has been shipped and received. The recipient, such as the elevator, alcohol plant, etc., has to keep the records about where that crop came from. The load has to be tagged with the recipient information by the elevator.”
If a third-party transporter, such as a contract trucker, delivers the grain, the transporter is also responsible for getting the information about where the crop is coming from. It is the transporter's responsibility to make sure the elevator gets the necessary information. “Today, most elevators are going electronic, so they want to set up a delivery ticket process, and the farmer will probably have called in to tell the number of loads that will be brought in,” Shepherd says. “Usually the elevator knows their clientele; however, if the elevator does not get the information they need, they could refuse the delivery. The farmer needs to understand that the load can be refused if the necessary information is not clearly passed on to the recipient.
“Most people won't have to drastically change their record-keeping practices, but from a biosecurity perspective, additional information would be helpful,” Shepherd continues. “I believe even though the producer is exempt, he needs to keep better internal records for himself, just to protect himself.”