Grain Traceability = Good for Business

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					    COVER STORY
    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                                                 
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
Description: According to [Charles R. Hurburgh], QMS and traceability can be a source of profit - not a source of cost - if it's approached in the proper way: "If a company does just enough to comply, saying, 'What's the minimum I have to do to get the inspector off my back?' - if that's the attitude, it'll be a cost. You'll have a stack of paper and not get anything out of it.
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