OPINION The National Grain and Feed Association is recommending several policy improvements that would create a more-reliable competitive and cost-effective official grain-inspection and -weighing system.
The grain-storage, -handling and -export industry specializes in the logistics of purchasing the commodities a farmer grows – and finding a market for it here at home or in global markets. Our legislative recommendations to amend the U.S. Grain Standards Act will strengthen the official inspection and weighing system. They will foster the competitive position of U.S. grains and oilseeds in world markets, and maintain the integrity of official-inspection results.
The National Grain and Feed Association recommendations were developed in collaboration with the North American Export Grain Association, with which it is co-located and has a strategic alliance.
The Federal Grain Inspection Service’s delegated and designated state and private agencies are relied upon to provide “competent, state-of-the-art and reliable” inspection services, which are paid for by the industry to facilitate marketing of U.S. grains and oilseeds. Official grain inspection and weighing generally is mandatory for most U.S. export shipments, while the use of such services is voluntary in the domestic market.
Reforms enacted by Congress in 2015 served as a springboard for a series of improvements to the Federal Grain Inspection Service and the official inspection system. Secretary of Agriculture Sonny Perdue’s decision to return the service to the U.S. Department of Agriculture’s Agricultural Marketing Service brings about positive changes.
As lawmakers consider reauthorizing the U.S. Grain Standards Act, the National Grain and Feed Association offers several recommendations for improvement.
- The Federal Grain Inspection Service should expressly prohibit the inappropriate and misleading practice of using grain-standard quality factors as an indicator of plant-health risk on phytosanitary certificates issued by the USDA’s Animal and Plant Health Inspection Service. The Animal and Plant Health Inspection Service inappropriately and unwisely acquiesced in late December 2017 to Chinese-official requests that foreign-material content – a grain-quality factor – be used as a proxy for weed-seed content in U.S. soybean export shipments. The resulting market uncertainty led to a sharp reduction in U.S. soybean exports to China months before the advent of tariffs.
- Delegated states should be required to notify users of official inspection or weighing services at least 72 hours in advance of any intent to discontinue service. Such agencies already are required to provide such notification to the USDA. We strongly believe affected facilities need and deserve the same courtesy and consideration as currently provided to the USDA. That way they can make appropriate logistical and other alternative arrangements to continue to serve customers whenever possible – including farmers as well as upstream and downstream customers.
- The Federal Grain Inspection Service should conduct a detailed review of the current geographic boundaries for each officially designated agency operating in the domestic market. The Federal Grain Inspection Service designates a single agency to provide official inspection services in each geographic territory. The agency has not conducted a comprehensive review of those boundaries since it was established in 1976.
- Federal Grain Inspection Service user fees paid by those obtaining inspection and weighing services should be directed solely for that purpose. They should not be used for developing U.S. grain standards or for compliance and enforcement activities, which have broad societal benefits to producers and consumers. Users of the official services already pay for the direct costs incurred by the Federal Grain Inspection Service plus administrative overhead for those services, which typically comprises 70 percent of the service’s total annual budget.
- Extend the reauthorization period for the U.S. Grain Standards Act to somewhere between five and 10 years, versus the current five-year schedule.
- The Federal Grain Inspection Service should be required to report to Congress and the public the number of and specific types of waivers from official inspection and weighing service being requested and granted, the number of non-use of service exceptions requested and granted, and the number of specific testing services requested. The service should preserve confidential business information.
- The Federal Grain Inspection Service’s Grain Inspection Advisory Committee should be reauthorized. The advisory committee provides counsel to the service’s administrator on the implementation of the U.S. Grain Standards Act. It’s comprised of members who represent the interests of grain producers, exporters and handlers.
The National Grain and Feed Association concluded that reauthorizing the U.S. Grain Standards Act on time – or even a bit early – would provide continued certainty to grain handlers, farmers and global customers.