Supporting Non-assured Grain

RED TRACTOR:

SUPPORTING NON-ASSURED GRAIN TO HAVE ACCESS TO FEED MILLS

All eyes now on AIC and the feed mills

Red Tractor (RT) released a statement on 23rd November from Jim Moseley, chief executive of RT, saying "Red Tractor recognises and supports the principle for all UK growers to be free to choose which markets they access, whether they are assured or not".

This comes after a group of growers, who came together on The Farming Forum, started working together to highlight the fact that feed mills would only purchase UK produced grain if it was farm assured under a scheme such as RT or Scottish Quality Crops (SQC). These exact same feed mills do not request imported crops to have any farm level assurance when operating under the Agricultural Industries Confederation (AIC) Universal Feed Assurance Scheme (UFAS).

Representatives of the farmers requested a meeting with AHDB, which was held near Milton Keynes on 19th November, to discuss the unlevel playing field and how AHDB could help levy payers get fair market access which would no longer put them at a disadvantage to imported grain. It's a crazy situation where our own industry has made it more difficult for our own farmers to access their own markets.

This is a market access issue, and it's been voluntarily created by our industry leaders. The NFU have supported RT and AHDB have financially supported RT. UK Farmers now either have to pay to be in a farm assurance scheme, or they have their market access cut off. Farmers have been voting with their feet, and resigning their NFU membership over this single issue. As an industry we're stronger together, so we need to quickly find a solution to this situation.

Written by Steve Ridsdale, Arable Farmer

Red Tractor’s chief executive Jim Moseley who has recently been appointed to the government’s new Trade and Agriculture Commission and a Red Tractor press release states that he will work hard to protect and promote the interests of UK farmers (Image supplied by from same press release).

The RT statement went on to say

"We are urging the AIC to review and amend its scheme to create a route to market for non-assured domestic grain under FEMAS and its gatekeeper protocol. Equal opportunities to supply the UK's assured animal fed market should be given to domestic farmers as is afforded to imported grain".

If AIC agree to this change, farmers will not need to be members of an assurance scheme such as RT or SQC to supply combinable crops to a UFAS feed mill.

Mills And Market Access

There are 47,000 cereal producers in the UK, but only approximately 21,000 farmers in a recognised farm assurance scheme. As a result of this, less than half of UK cereal farmers are currently able to access the feed mill markets. Meanwhile, imports are literally able to sail in on a boat with no requirement to be farm level assured and get unfettered access to our feed mill markets.

All eyes will now be on the AIC and the individual feed mills to see if they back the amendment to give UK growers equivalent market access, which is no more onerous than they expect of imports. It will be interesting to see if farmer owned mills respond differently to non-farmer owned, and if mills will consider the wishes of their owners and suppliers, some of which will also be their animal feed customers.

What Will the New Requirements Be?

We don't yet know the answer to that question. The important point is the principle that RT have agreed that non-assured grain should be able to

access feed mills. We now need to establish what will be required of UK grain.

The safety of non-assured imports is checked via laboratory testing for parameters such as pesticide residues and heavy metal concentrations. This technique is designed to work for large shipments of grain, whereas a system for UK grain needs to be nimble enough to work for a 29-tonne load.

RT livestock scheme rules (e.g. beef and sheep or dairy) allow non-assured grain to be purchased provided it is accompanied by a grower declaration that grain is suitable for consumption by livestock and free from contaminants. As this declaration is both designed and accepted by RT, then this same declaration should also be acceptable for grain which is supplied to a feed mill, as it will ultimately be fed to the same RT assured livestock.

The difference between the domestic grain and imported grain is that the domestic grain has been grown within the UK legislative framework, and thus should not be required to go through the laboratory testing procedure. It is for this same reason that RT assured grain is not required to undergo any laboratory safety testing.

Feed Grain and Human Consumption Grain

Imported combinable crops access human consumption markets as well as feed markets. Once the precedent has been set and a standard agreed for UK grain to access feed markets, then the same principles should apply to human consumption combinable crops. I would encourage processors to engage with AHDB Cereals & Oilseeds to help determine which standards they may like to see adhered to. One suggestion is to have a system designed to back up the grower's declaration, so it would be more comprehensive than the currently accepted RT feed declaration if the customer required it to be so. This could hold real-time information such as the NSTS certificate number and expiry date, and it could have multiple tiers depending on if the farmer wished to only supply feed grains, or if the farmer wished to supply to human consumption markets. 1. Feed grain declaration. Grown to UK legislative standards. 2. Human consumption. Declaration backed up with real-time information (e.g. NSTS expiry date, grain drying and storage records, mycotoxin risk assessment etc.)

This would be a step-change in the way grain assurance could work. It only needs to hold food safety information, it would be cheaper and easier for farmers to comply with yet offer a better level of assurance due to the real time nature of the system.

Declarations

Audited assurance schemes essentially just check our self-declarations. • Our mycotoxin risk assessment is self-declared. • Our legally required pesticide application record is self-declared. • The date we filled up our rodent bait stations is self-declared. • The date we washed and disinfected our grain bucket is self-declared. • The fertiliser spreader calibration record is self-declared.

We just have to pay a private company to tick a box, witnessing that we've self-declared something. This doesn't alter the fact it was a selfdeclaration.

We can still self-declare our working practices and grain safety (just as RT currently allows for farm-to-farm grain trading) but we are unhappy paying a private company to simply check our self-declarations when our buyers are happy to purchase imported grain which does not have this on-farm requirement and associated costs.

We already get DEFRA and Trading Standards on-farm checks. They check pesticide records, pesticide stores, grain handling and storage facilities and insist on a written and recorded HACCP protocol for grain drying and storage.

The Role Of AHDB

The creation and running of grain quality marks and schemes is within the remit of AHDB. We've asked AHDB if they will create a new system to help the 27,000 farmers who currently have no access to either feed or human consumption markets. We think information could be held on the digital passport framework, so it's accessible and available to customers.

We've also asked AHDB to consult with feed mills, human consumption mills, maltsters and oilseed crushers, as to how a new scheme could fulfil their grain assurance needs

The farmers have done their bit in bringing this issue into the limelight. All eyes are now on our AHDB, AIC and the processors to implement a solution for levy payers.

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