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Domestic Farm Policy

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Approved December 2010



1 Government Affairs Policies of the USA Rice Federation

2 (USA Rice Producers' Group, USA Rice Millers' Association and the USA Rice Merchants’

3 Association) for 2011





4 I. Domestic Farm Policy

5 Protect farm bill safety net



6 • We oppose efforts to reduce farm program spending or support levels as part of any budget

7 reconciliation legislation or through future appropriations legislation.

8 • As warranted, we support disaster assistance as part of an emergency farm assistance legislative

9 package. Such assistance should be emergency spending and not offset via traditional agriculture

10 spending.

11 • We support a permanent agriculture disaster assistance program as part of the farm bill, as long as

12 the cost of the program is not offset by current agriculture spending and it is designed to take into

13 account the unique nature of rice production where yield losses are typically minor and

14 infrequent.

15 • We would consider efforts to address the landlord-tenant relationship.

16 • We support regulatory changes that would allow producers to collect loan deficiency payments

17 based on actual scale receipts or estimates, and that there be no penalty for under or over

18 estimating delivery.



19 Payment limitations and eligibility provisions



20 • We support eliminating the payment limitation for income support and marketing loan/loan

21 deficiency payments and oppose any further reduction in levels provided under the Food,

22 Conservation, and Energy Act of 2008 (2008 Farm Bill).

23 • We oppose any government policies that target payments or apply a means test for agricultural

24 production payments and specifically oppose any further reduction in the adjusted gross income

25 levels provided under the 2008 Farm Bill.

26 • We oppose efforts to further restrict farm program eligibility by modifying current “actively

27 engaged” provisions beyond those changes specifically required by the 2008 Farm Bill.



28 Farm bill implementation and development



29 We support the following principles of the Food, Conservation, and Energy Act of 2008 (Farm Bill)

30 developed by Congress:



31 • Maintain the rice program levels authorized in the 2008 Farm Bill and oppose reductions in

32 program benefits.

33 • Maintain rice's share of total farm program spending.

34 • Maintain planting flexibility.

35 • Continue non-recourse marketing loan and loan deficiency payments structure and maintain the

36 complete removal of limits on the non-recourse marketing loan program.

37 • Continue to establish loan rates at no less than $6.50 per cwt for each class of rice.

38 • Support an income safety net for producers through a counter cyclical income support program in

39 addition to a direct payment and non-recourse marketing loan program.

40 • Ensure that counter cyclical payments continue to reflect differences in yields that occur in

41 different rice producing regions.



Page 1 of 12

Approved December 2010



1 • Provide for calculation of counter cyclical payments by class.

2 • Compensate producers for current and future conservation/environmental practices that enhance

3 water and air quality and wildlife habitat.

4 • Continue to allow double cropping to be an exception to the policy that base acreage cannot

5 exceed total cropland.

6 • Seek opportunities in future farm programs to reward rice producers for their current sustainable

7 production practices and to provide incentives to implement additional sustainable practices in an

8 economically viable manner.



9 Farm policy development

10

11 • The farm safety net must be strengthened for rice producers by the next farm bill.

12 • ACRE program, or any variant, must effectively serve all eligible commodities.

13 • SURE program, or any variant, must effectively serve all eligible commodities.

14 • The next farm bill must create long-term certainty regarding payment limitations, adjusted gross

15 income requirements, and other eligibility criteria.

16

17 Conservation

18

19 We support the following principles for current and new USDA conservation programs:



20 • Rice producers’ conservation contributions are significant. Rice-production practices, including

21 irrigation, that provide sound, voluntary, science-based conservation benefits should be proposed

22 for cost-sharing authorization in the next farm bill. Rice-specific conservation cost-sharing

23 should not come at the expense of farm safety-net programs.

24 • Support existing programs including CSP, CRP, WRP, WHIP, EQIP, FRLPP, conservation

25 technical assistance, etc. and maintaining existing funding for these programs. However,

26 continuation of CSP and any other new conservation funding should be targeted towards land that

27 is in production or considered in production.

28 • Support funding and maintenance costs not only for practices already being implemented that

29 enhance the environment, but also additional practices that may be encouraged through higher

30 payments.

31 • There should be no payment limitations on conservation program payments and we oppose

32 reductions on current conservation program limits.

33 • Compensation for conservation practices will in no way be a substitute for existing or future farm

34 safety net programs including direct payments, marketing loan gain/loan deficiency payments,

35 counter cyclical program payments, or any other farm income support payment program.

36 • All conservation payment programs should be voluntary and incentive driven.

37 • Any measure of the environmental benefit of conservation practices compensated for under a

38 conservation program should be science based.

39 • Conservation programs should clearly enhance the rural economy and maintain property rights.

40 • Conservation programs should be WTO consistent and should be designed and implemented to be

41 defined as “Green Box” measures.

42 • Conservation programs should be administered primarily at the local level through each state’s

43 agency of preference. Any new conservation program advisory committees should be comprised

44 primarily by agricultural producers.

45 • Idling land for conservation or wildlife habitat purposes should be considered planted acreage for

46 base calculation purposes.





Page 2 of 12

Approved December 2010



1 • Provide additional cost-share assistance for the construction of on-farm irrigation reservoirs and

2 other related irrigation structures.

3 • Funding for continuation of current conservation programs or for new conservation programs

4 should not come at the expense of current or future commodity support programs.

5 • Current and future working lands conservation programs should provide for and encourage

6 enrollment of both landowners and tenants in such programs.



7 Competition and concentration

8

9 We oppose legislation regarding competition in the agriculture sector that would go beyond current law to

10 create new authority for USDA to regulate competition and concentration.

11

12 Crop insurance reform

13

14 We support crop insurance as a supplement but not a substitute for the farm bill safety net, including

15 efforts to improve the effectiveness and benefits of crop insurance programs for rice producers,

16 particularly revenue and cost of production type policies.

17

18 USDA statistics and operations



19 • We support timely and accurate information on U.S. rice stocks, acreage utilization, and FSA and

20 NASS data to better inform the industry of the supply situation.

21 • The World Market Price Subcommittee should continue to provide relevant information to USDA

22 on behalf of the industry and meet quarterly with USDA to discuss the world market price

23 calculation.

24 • USA Rice supports continued improvements in USDA/NASS rice price reporting forms and

25 procedures to improve the accuracy of reported prices and stocks reporting.





26 II. Appropriations Legislation

27

28 • We support maximum appropriations that would be of benefit to the rice industry, including

29 funding for the USDA Food, Consumer & Nutrition Services, including the school lunch and

30 WIC program; the Agriculture Research Service and its Nutrient Data Laboratory; the Southern

31 Regional Research Center; Dale M. Bumpers National Rice Research Center; the Western

32 Regional Research Center; the Louisiana blackbird project; the White River Irrigation

33 Demonstration project; the Bayou Meto project; the Boeuf-Tensas project; continuation of the

34 winter flooding incentives program in Section 3406 (b) 22 of the Central Valley Improvement

35 Act; land grant universities; International food aid assistance programs; the Market Access

36 Program; and the Foreign Market Development Program.

37 • We support appropriations for rice research to develop aromatic rice varieties that are adapted for

38 production in the U.S. with adequate field yields, quality, and milling yields.

39 • We support appropriations for research to develop and expand the knowledge base about the

40 health-beneficial properties of rice.

41

42

43





Page 3 of 12

Approved December 2010





1 III. Other Legislation

2

3 Transportation

4

5 • We support safe, competitive, efficient, reliable, accessible, and fair rail service to the rice

6 industry and its agribusiness suppliers and legislation and administrative practices to make

7 these types of services available.

8 • We support changing the Federal Motor Carrier Safety Regulations’ definition of a

9 commercial motor vehicle from 10,001 pounds to 26,001 pounds to provide uniformity

10 among states and clarity for enforcement officials.

11

12

13 Imported fertilizer

14

15 • Given the significant increases in recent years in the cost of urea and ammonium nitrate to

16 produce U.S. crops and the importance of these inputs in rice productions, we support the

17 Congress and the Administration working closely with agricultural producers to identify and

18 expand access to additional sources of urea and ammonium nitrate at fair and reasonable

19 prices.

20

21 • We support legislation to lift antidumping orders and import restrictions on Russian and

22 Ukrainian urea and Russian ammonium nitrate (AN).

23

24

25 IV. Environmental Issues and Pesticide Availability

26

27 EPA's water quality regulations

28

29 • We support regulations for safe water quality based on sound science with all contributing

30 sources being considered.

31 • We support voluntary Best Management Practices for nonpoint sources to address water

32 quality concerns in situations where standards are exceeded.

33 • We support funding and educational programs for producers that improve water quality.

34

35 Drift policy

36

37 • We vigorously support the use of statistically sound science-based product drift definitions in

38 setting USEPA drift policy.

39 • We support the differentiation between waters of the U.S. and irrigated aquatic production

40 systems.

41

42 Endangered Species Act (ESA)

43

44 • We support the development and use of scientifically sound procedures for determining

45 whether, and under what situations, a biological entity is threatened or endangered.

46 • We support more accurate peer review and public hearings for determination and

47 identification/description of the ranges of threatened or endangered species.







Page 4 of 12

Approved December 2010





1 • We urge modification of the ESA to ensure a more efficient process wherein species which

2 are no longer endangered or threatened are expeditiously removed from the endangered or

3 threatened species list.

4 • We support agri-chemical manufacturer efforts to comply with existing ESA requirements in

5 a manner that does not unduly limit producers’ access to products or inadvertently create

6 additional ESA compliance requirements.

7

8 Crop protection tools



9 • We support clarifying the implementation of the Food Quality Protection Act to make it more

10 transparent and streamlined with the goals of:



11 • Basing decisions on sound science

12 • Supporting industry participation to help EPA refine their assessments in order to ensure

13 a quick and efficient reassessment process

14 • Establishing reasonable and cost-effective label language; and,

15 • Ensuring the availability of effective pest control products.



16 • We support USEPA Section 3 pesticide registrations, Section 18 emergency exemptions and

17 24(c) special local need registrations as appropriate for the benefit of the rice industry.

18 • We support the continued use and adequate supply levels of methyl bromide and other pesticides

19 until proven alternatives are available.

20 • We support the continued use of unused stocks of crop protection products that may remain in the

21 channels of trade beyond the existing stocks time frames established when the registration is

22 canceled, suspended, withdrawn or revoked, either voluntarily or involuntarily, for a reasonable

23 period of time. We also support the concept that leftover stocks in producers’ possession and ag-

24 trade channels that are not to be used on crops continue to be classified as a crop protection

25 products (and not as hazardous waste) after the registration cancellation or until approval of

26 disposal arrangements, site and transportation have been accomplished.



27 Climate change

28

29 • We support the voluntary development of cultural and management practices along with

30 research that may result in reductions of potential contributing factors.

31 • We support a voluntary emissions credit-trading program.

32 • We oppose passage of mandatory climate change legislation due to the projected impact on input

33 costs and minimal expected benefit to be realized from an agricultural offsets program.

34 • Regarding climate change legislation, if such a bill is pursued in Congress, we support the

35 following provisions being included:

36 o Broad agricultural offsets program that is flexible and administered and overseen by

37 USDA;

38 o An express exemption for the agricultural sector from the greenhouse gas emissions

39 reduction requirements of the climate change legislation and the underlying Clean Air

40 Act.

41 o Definition of “agriculture sector” for the exemption should be clarified to include

42 production through the stage of processing ordinarily necessary for the commodity to be

43 widely marketed in commercial channels.

44 o Establishment of a program using the funds and authorities of the Commodity Credit

45 Corporation to compensate producers for increased input costs.



Page 5 of 12

Approved December 2010



1 o Increased funding for research programs and activities by USDA and land grant

2 university system to develop improved production and management practices to help

3 agriculture sequester greenhouse gas emissions.

4

5 Energy policy/renewable fuels



6 • We support a comprehensive national energy program with incentives to achieve self-sufficiency

7 through research, conservation, and increased use of renewable agricultural resources such as rice

8 and rice byproducts.

9 • We urge that environmental regulations be reasonable, practical and consistent with the nation’s

10 need to develop and conserve all energy resources.

11 • We encourage Federal renewable fuel initiatives that have clearly identified benefits for

12 producers, such as rice, rice straw-based, and rice hull-based ethanol and energy plants as part of

13 the development of the cellulosic ethanol industry.

14 • We support including rice straw and hulls as eligible biomass resources in the 2008 Farm Act’s

15 Biomass Crop Assistance Program.

16 • We support encouraging the U.S. government to use renewable fuels in government vehicles and

17 in other appropriate applications, and to use rice byproducts, including rice straw and hulls, for

18 such applications as ethanol production, paper products, building materials, livestock feed and

19 environmental mitigation.



20

21 V. Biotechnology

22

23 • We support the development of genetically modified rice varieties that provide benefits to the rice

24 industry and consumers, but do not support their commercial release prior to science-based

25 regulatory approval and consumer acceptance (i.e., no negative impact on commercial sales of

26 rice).

27 • We support efforts by the U.S. Government and the biotechnology industry to gain regulatory and

28 consumer acceptance of genetically modified rice products for food and feed use based on sound

29 science.

30 • We do not support the use of genetically engineered rice for the production of pharmaceutical or

31 other non-food and feed products.

32 • We support efforts in the CODEX ALIMENTARIUS to establish a global low-level presence

33 (LLP) policy for genetically modified traits that have been approved in some but not all countries,

34 such as LibertyLink 62.

35 • We support the establishment of an LLP policy in the EU for certain Liberty Link traits, including

36 the LL601 trait, that have been identified in the U.S. commercial supply but for which the

37 developer of such traits is not seeking regulatory approval in any country.

38 • We urge swift regulatory action by USDA to implement administrative changes in connection

39 with USDA oversight of plant genetic engineering as identified by USDA in the October 5, 2007,

40 “Lessons Learned” portion of the Liberty Link report.

41 • We support and recommend rice-producing States' adoption of measures to regulate genetically

42 modified rice varieties/germplasm that have the potential to have an economic impact on the rice

43 industry.

44 • We support development of tests to determine the presence of all genetically modified events

45 prior to commercialization, identity protection protocols, maximization of tolerance levels, and

46 the development of credible certification systems.





Page 6 of 12

Approved December 2010





1 • We recognize the right of consumers to choose between genetically modified and non-GM foods

2 through voluntary labeling.

3 • We oppose legislation that would require mandatory labeling of genetically enhanced foods that

4 are substantially equivalent to non-genetically modified products.

5

6 VI. Taxes

7

8 FARRM accounts

9

10 We support enactment of Farm and Ranch Risk Management (FARRM) accounts or similar tax-

11 advantaged farm savings accounts without reductions to any other programs.

12

13 Estate tax reform

14

15 We support permanent elimination of estate tax laws.

16

17 We support bills to eliminate or reduce estate tax burdens on farmers, ranchers, and other agricultural

18 property owners.

19

20 Tax on non-profit income

21

22 We oppose proposals to tax non-profit associations' investment income greater than $10,000.

23

24 Broadband internet access



25 We support legislation which would provide ten and twenty percent tax credits respectively for

26 investment in current generation broadband access for residential and business users in rural and low

27 income urban areas and to accelerate deployment of next generation capability. Such legislation would

28 benefit agricultural producers and related businesses in rural areas.





29 VII. Trade Policy and International Food Aid

30

31 We will continue participation in coalitions with other agricultural organizations as a means of

32 heightening appreciation of producers and U.S. agricultural production, and increasing understanding on

33 key agriculture-related issues; including the importance of fair trade and the FAS market development

34 programs to the health of the industry.

35

36 Trade sanctions reform



37 • We support continued trade sanctions reform, especially improving the U.S. government's

38 procedures for approving export licenses for agricultural products, in addition to that signed into

39 law by the President on October 28, 2000.

40 • We support restoration of normal commercial relations and travel between the United States and

41 Cuba.

42 • We support removal of the OFAC cash payment in advance rule for agricultural sales to Cuba.



43

44

45

Page 7 of 12

Approved December 2010



1 Authorization and full appropriation for export promotion

2

3 • We support authorizing and appropriations legislation which would fully fund the Market Access

4 Program and Foreign Market Development Program at the following levels:



5 MAP FMD



6 $200 million $34.5 million



7 Imports

8

9 We support having the same standards applied and enforced on imported rice as those imposed on

10 domestic rice, including government efforts to regulate the safety of imported food.

11

12 Protection of the U.S food supply

13

14 We support the administration’s efforts to respond to possible terrorist actions against the safety of the

15 U.S. food supply. U.S. actions should be developed in consultation with U.S. agriculture; be transparent

16 and targeted; and apply to imported as well as domestic foods.

17

18 Trade Promotion Authority

19

20 We support a conditional extension and reauthorization of Trade Promotion Authority contingent upon

21 maintaining a strong farm safety net for rice, commitments from U.S. trade officials not to unilaterally

22 disarm U.S. agriculture in trade negotiations and to provide a strong defense to any potential WTO cases

23 brought against rice.

24

25 Multilateral, bilateral & regional trade negotiations

26

27 • Maintain support for a multilateral trade agreement that provides for real, meaningful and

28 significant improvements in market access for U.S. rice in foreign markets while maintaining the

29 appropriate safety net for U.S. producers. Any reductions in trade-distorting domestic support

30 programs must be balanced and offset by actual gains in market access and within equivalent time

31 periods.

32 • We do not support multilateral disciplines on non-trade distorting domestic supports.

33 • Support aggressive enforcement by U.S. Government of existing trade agreements.

34 • Support regional and bilateral free trade agreements that advance market access for U.S. rice.

35

36 Overall, we support:



37 • Comprehensive agreements where rice market access liberalization is included;

38 • Equal market access for all types and forms of rice;

39 • Immediate and substantial reductions, leading to eventual elimination, of import tariffs;

40 • Elimination of export subsidies;

41 • Tighter disciplines on trade-distorting domestic subsidies;

42 • Reliance on scientific standards and an assessment of commercial impact when evaluating new

43 technologies;

44 • Reliance on scientific standards when implementing sanitary and phytosanitary measures;

45 • Enforcement of SPS import restrictions on the basis of sound science only;





Page 8 of 12

Approved December 2010



1 • Tighter disciplines on the administration of tariffs and tariff-rate quotas to eliminate the

2 discriminatory effect of price bands, import licensing regimes, and reference price regimes;

3 • Tighter disciplines on the operation of state-trading enterprises, particularly import STEs, in order

4 to increase transparency; increase participation by the private sector in import and export

5 transactions; and ensure that importing STEs provide access to all segments of commercial

6 demand in a market;

7 • Increased food security for importing nations by obtaining a commitment among WTO members

8 not to restrict or prohibit the export of agricultural products.

9 • Negotiation of export credit disciplines that preserve a GSM program supportive of U.S. rice

10 exports.

11 • Preservation of existing U.S. government food aid programs, including the continuation of in-

12 kind food aid and government-to-government food assistance.



13 With regard to trade policies of specific countries or regions, we support the following:

14

15 European Union

16

17 • Concentrated effort by the U.S. government to assist in the restoration of competitiveness and

18 marketability of U.S. long grain rice in the EU following the Liberty Link rice crisis. This includes

19 establishment of a low level presence policy for unapproved GE traits in U.S. rice.

20 • The 2005 bilateral agreement between the EU and the U.S. concerning EU brown rice import duties

21 must be renegotiated and replaced with a fixed duty import regime. In the meantime, market access

22 benefits for U.S. brown rice in the 2005 bilateral agreement must not be impaired by subsequent EU

23 agreements with other rice suppliers.

24 • EU import duties on rice should be reduced to zero, and existing EU import duties should be uniform

25 across all types and forms of rice as well as uniform from all export origins.

26 • EU export subsidies must be eliminated.

27 • Maintain full market access concessions from the Uruguay Round

28 • U.S. negotiators must ensure that the EU’s Everything But Arms policy for imported products from

29 developing countries does not effectively diminish access for U.S. rice

30

31 Taiwan and Korea

32

33 • Reform of Taiwan’s ceiling price policy for rice imported by the public sector so that this policy

34 reflects commercial realities of the global rice market and operates in such a way as to facilitate U.S.

35 sales of rice to Taiwan.

36 • Full and accelerated implementation of Korea’s headnote for rice as a result of the extension of WTO

37 Special Treatment negotiated between Korea, the United States and major rice suppliers.

38 • Seek and obtain compensation for the U.S. rice industry due to the exclusion of rice market access

39 from the U.S.-Korea Free Trade Agreement.

40

41 Latin America

42

43 • Support continued reform of U.S. laws regarding trade with Cuba with the goal of obtaining normal

44 commercial relations between the United States and Cuba.

45 • Support congressional approval of the U.S.-Colombia Free Trade Agreement.

46 • Support distribution of the U.S. share of quota rents under the U.S.-Colombia Free Trade Agreement

47 to rice research boards in the six rice production states based on each state’s share in U.S. rice

48 production.





Page 9 of 12

Approved December 2010



1 • Support the negotiation of bilateral and regional free trade agreements that lead in a timely fashion to

2 the elimination of duties on all types and forms of rice imported from the United States, and which

3 provides equal access and tariff treatment to all types and forms of U.S. rice.

4 • Ensure effective and full implementation of existing free trade agreements in the region – NAFTA,

5 CAFTA-DR, and the U.S.-Peru agreement

6 • Support the elimination of price bands

7 • Improve operation and transparency of TRQ administration and licensing, including the

8 administration of sanitary and phytosanitary (SPS) import certificates.

9 • Increase U.S. government trade policy action to counter the use of SPS-based actions by countries in

10 the region as a non-tariff trade barrier. Seek harmonized solutions across the region to avoid as much

11 as possible different SPS requirements across countries for the same or similar rice pest.

12 • Support U.S. government engagement with Peru’s plant health authorities to press for completion by

13 Peru of an ongoing pest risk assessment of imported U.S. rice

14

15 Japan

16

17 • Substantial reduction in Japan's within quota mark-up and out of quota duty on rice.

18 • Improved access for rice exporters to end users in Japan

19 • Substantial reductions in Japan's allowable levels of trade-distorting domestic supports.

20 • Continue historical level of U.S. rice exports to Japan (50 percent).

21 • Seek continual liberalization of the SBS component of minimum access to assure that free market and

22 commercial objectives are met.

23 • Establish a country-specific TRQ for U.S. rice.

24 • Urge the U.S. government to counter policies of the Japanese government that result in import

25 substitution of any U.S. rice- containing export.

26 • Require an increase in Japan’s total rice imports in exchange for Japan requesting sensitive

27 designation for rice in the Doha Round negotiations.

28 • Seek a reduction in the amount of testing on U.S. rice for chemical residues to bring the number of

29 chemicals tested for in line with actual use in the United States.

30

31 China

32

33 • Work with the U.S. government to obtain phytosanitary approval by China of imports of U.S. rice.

34

35 Food aid

36

37 We aggressively seek inclusion of rice in Federal trade and aid programs.



38 • We support food aid and rice for food aid being allocated a fair share of U.S. funding.

39 • We oppose the use of USDA P.L. 480 Title II funding for the purchase of emergency food

40 aid overseas. We also oppose the Local and Regional Purchase pilot program to purchase and

41 study the effectiveness of buying emergency food aid overseas using U.S. funds.

42 • Food aid should only be provided in commercial U.S. rice export markets in times of food

43 security emergencies.

44 • Federal food assistance programs using taxpayer funds should use value-added products, which

45 benefit not only producers and millers, but also related businesses in the state and local

46 economies.

47 • Increase rice food aid by enhancing efforts to educate and inform both donors and cooperating

48 sponsors.

49 • Research and develop new rice-based food aid commodities/products.



Page 10 of 12

Approved December 2010



1 • Establish working relationships with Private Voluntary Organizations (PVOs), World Food

2 Program (WFP) and commodity groups to increase the use of rice in food aid programs.

3  Support reauthorization and appropriations legislation that would fully support

4 and fund all U.S. food aid efforts as provided for in the 2008 Farm Act.

5  Title I: Maintain full authority

6  Title II: 2.5 million MT

7  Food For Progress: 400,000 MT

8  McGovern-Dole Food for Education: Maintain full authority

9  Section 416(b): Maintain full authority.

10  Preserve the rule under the Title II program that 75 percent of commodities

11 programmed by USAID shall be value added, and continue to monitor the use of

12 other commodity products in food aid to assure compliance with the value added

13 rule.

14  Support regulatory reform to streamline and standardize PVO applications and

15 requirements across food aid programs to avoid delays in commodity

16 procurement that hamper U.S. rice industry business cycles.

17  Support earlier programming of food aid by USDA agencies and USAID/Food

18 for Peace.

19  Continue to press the WFP on tendering transparency issues in cooperation with

20 other food aid commodity groups and U.S. PVOs.





21 VIII. Food Safety

22 • Fully enforce Federal food safety laws for domestic/imported food, whether through a single or

23 multiple U.S. food safety agency(ies).

24 • Modernize Federal computer systems to prevent port shopping.

25 • Require Federal intra-agency international trade data sharing capability.

26 • Increase frequency of FDA’s food/feed facility inspection, including the use of:

27 o Science-based analysis and need

28 o Facility’s compliance history

29 • Improve FDA’s inspection-data collection and analysis to operate risk-based system.

30

31

32 Testing

33

34 • Accelerate FDA labs’ rapid food/feed ingredients pathogen-detection test development.

35

36 Recall

37

38 Authorize FDA to:

39 • Implement mandatory FDA recall when company refuses voluntary recall and significant public

40 health risk exists.

41 • Have more control over timing and size of all product recalls.

42

43 Enforcement

44

45 • Ensure full Federal food-safety compliance through prompt, appropriate FDA action.

46

47

48

Page 11 of 12

Approved December 2010



1 Certification

2

3 • Develop FDA mandatory foreign supplier quality-assurance program.

4 • Develop voluntary qualified importer food-safety program to certify importers sharing additional

5 testing/program data.

6 • Voluntary additional data sharing should be a border inspection priority.

7 • Accredit highly-qualified, independent third parties to inspect and audit labs and food/feed facilities.

8

9 Imports

10

11 • Require all importers to adopt foreign supplier quality-assurance program to ensure all imported

12 ingredients and products meet FDA requirements.

13 • Oppose expedited entry for low-risk imported products.

14

15 User Fees

16

17 • Authorize FDA to collect importer user fees to implement mandatory foreign supplier quality-

18 assurance program.

19

20 Funding

21

22 • More Federal funds are needed for FDA mission implementation, enforcement, testing, and

23 personnel.



24 IX. Other

25

26 We support recognition and protection of generic rice varietal names such as American basmati rice and

27 will work with the appropriate federal agencies on this matter.

28

29

30

31

32

33 The USA Rice Federation's members include the USA Rice Millers' Association, the USA Rice

34 Producers' Group, the USA Rice Merchants’ Association and the USA Rice Council. Advocacy

35 positions are developed by the USA Rice Millers' Association, which includes the U.S. rice milling

36 industry and associated businesses; the USA Rice Producers' Group, which is the only national rice

37 association composed entirely of rice farmers and solely representing rice farmers, with

38 membership including producers in Arkansas, California, Louisiana, Missouri and Texas; and the

39 USA Rice Merchants’ Association, which includes rice merchandisers and related businesses.

40 These policy positions are then considered by the USA Rice Federation's Government Affairs

41 Committee for the rice industry; final positions are approved by the USA Rice Federation Board of

42 Directors. The USA Rice Council’s mission is to promote the use of U.S.-grown rice in domestic

43 and international markets on behalf of its state, producer, miller and other industry members.

44 December 2010

45









Page 12 of 12



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