By Jackie Roembke
Grain Traceability = Good for Business
Taking a systems-based approach to traceability and quality management
rain quality is a broad term, “Traceability is a founda- a company keeps in compliance
one that means many differ- tional risk management activity,” under Section 306 without cause.
ent things given the context explains Dr. Tim Herrman, pro- Once in the elevator, the preserva-
of the evaluation. Regardless of fessor and director, Office of the tion identity of the grain has not
whether you’re looking at the Texas State Chemist, Texas A&M been mandated up to this point.
physical attributes of the kernels System. “From a regulatory per- As it stands, Senate Bill 510 could
or monitoring moisture levels, spective, if you’re going to engage change this.
the ultimate goal is the same: in a recall, you need to be able to “Some of the wording is a bit
money. Once the level of quality trace product one step forward, onerous,” says Randy Gordon, vice
has been determined — and hope- one step back. Once you look for- president, communications and gov-
fully maintained — using grain ward to access and manage risk in ernment relations, National Grain
traceability as a jumping-off point distribution and draw conclusions, and Feed Association (NGFA).
for other process improvements then you’ll likely want to go back The grain handling industry’s
will allow elevators to maximize from what you’ve identified to fear is that the bill would not only
returns from both a market and a the point of contamination and to bring added cost to the agricultural
management perspective. identify the source.” system, but may seriously disrupt
In the United States, grain han- In recent years, the govern- the commingled raw commod-
dlers were introduced to federally ment’s regulatory focus has again ity handling, shipping and storage
imposed grain traceability sys- been drawn toward food tracking system. Most notably, the bill
tems, the tracking of the flow of and safety — specifically Senate may impose stringent traceability
grain and grain product attributes Bill 510, the FDA Food Safety requirements, basically identity
in the supply chain, as mandated Modernization Act. The commit- preservation in storage and record
by the FDA in Section 305 and tee has recommended the bill be keeping, with the goal of tracking
306 of the Bioterrorism Act of considered by the full Senate. individual shipments back to indi-
2002. While Section 305 prompts Under the Bioterrorism Act’s vidual farms or at least a reasonable
elevators to register, Section 306 definition of traceability, handlers number of possible sources.
requires registered locations to are not required to track intake As is the nature of bulk mate-
maintain records, which identify down to the field level, and should rials, grain moves through the
the immediate previous sources the FDA visit a premises regis- system as a series of “small sub-
and the immediate subsequent tered under Section 305, it would lots” with little identity. Once in
recipients of the grain. not be able to access the records the system, it is constantly com-
8 JUNE/JULY 2010| FEED&GRAIN www.feedandgrain.com
mingled into larger and larger lots. like that and then the buyer com- seen government regulations?
Making it to the level of trace- panies will start to get pushier — A team of researchers has been
ability proposed by the bill would and the industry will have to get asking themselves the same ques-
be a difficult — and potentially equally resistant,” Dr. Charles R. tion, and they offer a solution.
costly — endeavor. Ag organiza- Hurburgh, professor, agricultural
tions, like the NGFA, are pushing and Biosystems Engineering, Iowa Beneficial record keeping
amendments to the bill, hoping State University, predicts. “All it Working with the USDA,
to preserve the economic cost- takes is for an incident to occur extension programs, university
benefit model currently fueling with a product that is clos