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FDA Monitoring Hay Movements

Two of the family owner/ managers were there...Since they buy a great deal of hay and own several hay hauling semis ( and are strongly involved in the NCBA- which I thought might give them an inside to info), I asked them about these new rules and how they would be affected... The answer I received was "What new rules?"

Don't you just love the FDA.This is something the ag extension system has to do. Somebody from Extension should have reacted when this press release came from the FDA; http://www.cfsan.fda.gov/~dms/fsbtact.html
 
New rules will fight terrorism

By Chris Anderson
canderson@pantagraph

BLOOMINGTON - Dennis McCormick knows where every ingredient arriving at his mill comes from before he mixes it into cattle and swine feed for his customers.

In fact, the owner of Bellflower Feed Mill records every lot number of every ingredient received just in case customers have any problems with feed.

But all the recordkeeping may not be enough to meet looming federal bioterrorism deadlines. Grain elevators and feed mills have joined a long list of places ranging from airports to government buildings that now face increased security since the 2001 terrorist attacks.

By June 9, grain elevators and feed mills employing 11 to 499 workers will have to comply with the Bioterrorism Act of 2002. Facilities with 10 or fewer employees, like Bellflower Feed Mill, have until Dec. 11 to comply.

The new Food and Drug Administration rules mean grain elevators, feed mills, grain processors, grain exporters, pet food manufacturers, railroads, barge lines and truckers must register their facilities. They will have to identify the immediate previous source and the subsequent recipient of food, feed and other agricultural commodities. Records must be maintained for two years.

"We handle more than 100 feed ingredients. It would take a tremendous amount of time and expense to label every feed bag and record lot numbers on the invoice," said McCormick. "We will have to pass on the costs. I don't know where this will stop."

Jeff Adkisson, Grain & Feed Association of Illinois executive director, empathizes. He believes grain and feed business owners understand the need for the regulations. FDA officials want to contain any type of feed or grain contamination within 48 hours.

"We just need to figure out how to comply without getting too mired down in too much specificity," said Adkisson, whose organization consists of 260 grain and feed facilities. The Illinois Department of Agriculture licenses about 374 companies with 1,055 locations.

Adkisson noted that Illinois grain and feed facilities with 500 or more employees had to comply with the law by Dec. 9 last year.

Stu Selinger, Illinois Department of Agriculture warehouse examination supervisor, said state inspectors ask feed mill operators if they are registered under the bioterrorism act. The inspectors then note the registration in a report sent to the FDA.

Booklet on registering

"If the feed mill says they are not registered, we leave them a booklet that tells them how to register (at www.fda.gov/oc/bioterrorism/bioact.html). Inspectors estimate 80 percent of the feed mills are registered," said Selinger.

That's the case at Graymont Cooperative Association in Livingston County. The farmer-owned business registered its feed mill in 2004. It will have to comply with FDA rules by June 9.

"Our registration was prompted by our affiliation with Land O' Lakes. They had to comply last December, and they encouraged us," said Alan Zehr, Graymont Co-op general manager.

FDA inspections

Lou Carson, FDA deputy director, told Adkisson and other feed and grain representatives last month that FDA inspectors may ask a company during a routine visit whether the company is aware of the law and whether the company could respond to a record request within 24 hours.

Carson said inspectors will not request records unless reasonable belief exists that a food or feed ingredient has been contaminated and presents a serious threat to animal or human health.

Adkisson also expects to receive more definitive compliance guidelines from the National Grain and Feed Association next month.
 
I had a chance to talk with several more local producers today- Absolutely none have heard of these rules- but like me they don't doubt thats what the government is doing....The government backed Corporate world would like nothing better than to run the smaller and medium sized producers out of business...What is truly sad is they are blindly backed and supported by groups like NCBA.........

But I did find that the USDA thru FSA does have a satellite that can tell if you've spread cow manure too heavy on your fields- which is an EPA violation- even if its on dryland fields that are not in a drainage area :???:
 
Big Muddy rancher said:
Even if it is a federal program nothing to say it will be applied evenly. Different rules are enforced at different Ports of Entry.

I agree Big Muddy- and that has been pretty much the consensus with everyone I talked to-- the ones most affected by the rules with hay will be the Canadians that have for the last few years sold large quantaties of hay in the US (anyway in this area)- because they are the ones that "have" to come into contact with the Federal authorities- whereby most of the state officials don't have the time or manpower to worry about it, let alone check..........
 
Thought i would give you my 2 cents worth being a canadian that exports hay to the USA. I have been doing this for 10 years and have run into more and more paperwork to get my hay moved. As far as FDA watching hay movements is not really a new issue to me , they have been doing this for several yrs already. It involves registering with the FDA and giving them information as to your operation , location, etc. When i have a load to cross into the USA i hace to give them 2 hours of prior notice before arrival at port of entry. This can all be done via internet after you have registered with FDA . In the prior notice i do what is called a web entry and a prior notice which includes all information on submitter,producer or consolidator, shipper,and ultimate cosignee. It also includes the time that you expect to arrive at port of entry,product identifier, product description ,lot number,and quantitiy. When i have completed this the system will give me a confirmation number and all i do is print it and present it at the port of entry along with all other regular paperwork needed.
 
Haydude
Now you are going to keep FDA Section 306 records on that hay as they start going into force at the end of this year for the 24 hr. FDA traceback law.That is above and beyond the prior notice law that you tell about and importer's have to do.
 
I have been in the business of hay export for sometime now and have seen numerous changes come into place. When new rules and regulations come into place somehow you just do what they ask.
 
Yes ,just like the dairy hay our neighbors ship to Florida,he's now on SSI records as its easy to pass data via the Scoringag.com database and be in compliance with FDA.Good Thoughts Haydude.
 
FDA rules that are coming;

Require certification that proves that growers have read and are aware of FDA crop safety regulations and guidelines and without which, no one in the United States can sell food or feed commercially.
Mandate a traceback system in which the sellers, shippers, distributors,retailers, and processors maintain records and can quickly identify the sources of batches of fruit, vegetables and feed crops, and the vehicles and drivers in which they were transported.
Mandate farm of origin and country of origin labeling on at retail. U.S. food producers concerned about cheap imports should recognize that safer food is a feature for which consumers are willing to pay more.
 
I was reminded of this thread from another site... Has anyone got any updates on these rules- anyone heard if they are being enforced yet :???: ....I haven't heard word one from anyone- government or otherways....Crop season has started and most everyone I know has no idea this law exists still.....
 
We are hoping for a little more rain.


The boys out west are having more trouble with lack of rain. This spring has been pretty dry in the panhandle (Amarillo) area.

Texas is a BIG state. I am from east texas, where rain is more plentiful. We get to worrying about the rain when a week or two goes by without it. I have been out west a bit and know rain is measured in tenths of inches where we have always measured it in inches or feet (we have had 24 inches in 24 hours before).

They say for every 19 miles east of dallas you pick up another inch of rain. I was just out in Canton Tx, where it seemed normal. In Shreveport, La, at my uncle's house, you could put two hands in the cracks in the ground.

Weather (and rain) is like politics. Everything is local. It is relative. In my case it depends on which relative you are talking to.

Porker, go to the weather channel.
 
William Kanitz said:
Latest Update from FDA ,Posted linkat www.scoringag.com ; http://www.cfsan.fda.gov/~dms/recguid3.html

Thanks WK-- I had heard there were some farm exemptions- but from just this one question I can see these DC idiots still have no idea of what they are doing :roll: ...How the hell are you going to harvest alfalfa if you don't dry it and chop it or bale it or pellet it do something with it :???: .... Its all part of the process....


---------------------

Q: [Added November 2005] A farm grows, dries, and chops alfalfa before releasing it to another person for use as animal feed. Is the farm still exempt from this regulation?

A: No. Traditional farming activities, such as harvesting of grains, are covered under the farm exemption. However, this question implies that the drying and chopping are post-harvest activities, which would be considered manufacturing/processing and therefore are subject to this rule. Therefore, the facility drying and chopping alfalfa must establish and maintain records of the food's receipt and release as required in 21 CFR 1.337 and 1.345.
 
Say Oldtimer ,WK at ScoringAg has the right stuff,remember when his company came out with the cost for keeping cattle ID's and it was $0.25 cents 5 years ago and everybody from Maine to Tin Buck To said noway one could build a database that cheap.Well He did, and he's still doing it and their database system is even better nowadays.Now you can add every activity from breeding to feeding an shipping too.ScoringAg doesn't care what country your ranch is in and if its in the US you can keep yourself in compliance with FDA when the cattle ID is still being worked on.
As for the FDA rules about Bioterrorism,I think they went overboard.The only exemptions are farms that don't move any product into commerical channels as I see it On the otherhand I am glad that at least one company knew what records needed to be kept .Heck I never heard a peep from the ag extension system. My hat's off to WK's company I rep. for and to WK for his forward thinking of the easy way cheap way to comply with FDA or M"ID recordkeeping whether we like it or not.He's the best friend agriculture has nomatter which country's we live in.AT least we have a farmer and rancher that builds databases the way ag works.
 
FDA SAYS:The record must include information that is reasonably available to identify the specific source of each ingredient that was used to make every lot of finished product.

Identify the immediate non-transporter subsequent recipients of all foods released, including the name of the firm and the responsible individual; address; telephone number; fax number and email address, if available; type of food, including brand name and specific variety; date released; lot number or other identifier if available; quantity and type of packaging; and the name, address and telephone number and, if available, fax number and e-mail address of the transporter who transported the food from you. For transporters, the records for each food transported would have to include:

The name of the firm and the responsible individual who had the food before you and their address, telephone number, and, if available, fax number and e-mail address, and the date you receive it.
The name of the firm and responsible individual who had the food immediately after you and their address; telephone number, and, if available, fax number and e-mail address, and the date you delivered it.
The type of food, including brand name and specific variety; lot number or other identifier if available, quantity, and type of packaging.
Identification of each and every mode of transportation used (e.g., company truck, private carrier, rail, air etc.) and the individual responsible from when the food was first received until it was delivered.

This same rule affects farms and feed /grain companies.
 

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