Grain Industry Code of Practice for the Management of Grain 18 September 2012

1. Grain Industry Code of Practice for the Management of Grain 18 September 2012

2. What the Code is • Describes practices that the grain industry uses to ensure Australian grain and grain products marketed meet domestic and/or export customer requirements • Covers all participants and can be applied at all stages in the supply chain • Focuses on common industry elements such as trading standards, procedures and documented processes • Is outcome focused rather than “dictating procedures required to be used” • Adjunct to the Code of Conduct • Proposed to become a mandatory Code for all GTA members in 2013

3. Why and how it was developed • Desire by industry to self-regulate and: • Implement and promote best management practice • Show compliance with all laws and regulations • Comply with industry trading standards, processes and procedures where contractual obligations dictate • Improve the standards of service in the industry • GTA Board developed draft and present to members for comment, also seeking non-GTA member comment • Receive comments and signoff during latter half of 2012 • Will be reviewed annually • Will involve a compliance mechanism as a key element • Reviewing reference in existing industry processes such as contracts

4. What it covers • On-farm Activities • Sampling and Testing Grain • Storage Facilities • Chemical Use • Grain Quality Management • Transport • Marketing • Training • Compliance with Code • Contains Reference Material • Links to Reference documents • Technical Guideline documents – detailed aspects to implement each activity, developed over time

5. On-Farm Activities • Activities documented and records kept • Use Best Management Practices • Farm biosecurity • During crop growth a range of agronomic practices are conducted to maximise quality etc • Grain in storage monitored to maintain its quality • Regulations complied with • Contractors approved and records kept • Grain moved ex-farm is accompanied by appropriate declarations

6. Sampling and Testing • Equipment is monitored, calibrated and checked, suited to purpose, prior to use • Procedures outlined in company Sampling & operational Manual • Preference for use of certain equipment (objective technology, grain divider) • Comply with NMI, other gear also “complies”

7. Storage Facilities • Construction and maintenance to manage grain quality • Preference is sealed storages (complies with AS2628) • Aeration is a useful management tool • Pest management and hygiene system is documented • Follows principles of IPM • Where practical, grain stored insect free • Regular sampling and inspection • Insect infestations should be treated as soon as possible • Chemical used as per industry guidelines, meet regulatory requirements and customer specifications • All chemical treatments ensure compliance with all MRLs • Only legal treatments for grain, storages and structures are to be used • Regular cleaning of spillages, site hygiene

8. Chemical Use (part 1) • Industry is committed to complying with relevant Australian and International chemical regulations • A whole-of-chain approach applies to food safety and chemical residue management and the provision of grain according to customer requirements through a combination of: • Australian Government legislation • Industry quality assurance systems underlying the legislation • Mandatory NRS for exports, domestic encouraged • Industry will not trade in grain that contains a chemical in violation of relevant legislation • If any violation of an MRL or mis-use of a chemical is identified, it is to be reported to the relevant authority • Apply Phosphine Resistance Management Strategy

9. Chemical Use (part 2) • Fumigations are monitored • Only trained operators apply chemicals • Use CVDs, and are only to be provided where information documented can be supported by records or other suitable means • Quality checks are carried out via sampling, inspection, testing • Grain is only outturned following compliance with the legislated label requirements such as With-holding and Ventilation Period; and/or Analysis of grain to confirm residue levels. • Where grain is known to contain a chemical that is in violation of a regulatory or market requirement, industry will not supply that grain to that market unless: • • A mitigation strategy is implemented; and / or • • The supplier receives written agreement from the customer of the grain, provided regulatory requirements are not violated.

10. Grain Quality Management • Apply industry sampling and testing protocols, uses CVDs • Documents where processes etc different • Documented dispute and rejection procedure • Segregations are created according to market requirements and based on the industry standard for that commodity and grade. • Grain of differing grade classification is not blended unless: • Procedures are documented; • The outcome is known; and • Appropriate approval has been obtained. • During outturn samples are taken and grain physically inspected • Grain loading may commence once the quality of grain accumulated is known. No grain is to be loaded unless the quality is known.

11. Transport • Comply with transport industry best management practices to: • Maintain the quality and integrity of the grain; • Prevent unintentional contamination; and • Transport grain to their designated markets quickly, safely and within the relevant laws. • Documented systems to show compliance, comply with regulations, staff / contractors are trained • Involve inspection prior to loading / comply with “prior load” • Where non-compliance has been detected: • Actions must be taken to remedy the situation as soon as possible; and • Where required, such incidents must be reported to the relevant authority.

12. Marketing (part 1) • Adopt common documentation and data management processes • Supports & uses the Commercial Resources developed by GTA • Preference is for the use of industry contracts and published grade standards • Grain traded is to be supplied with appropriate documentation • GTA grade standards (e.g., CS number) will only be used where the final grain out-turned meets all specifications of that standard including objective quality parameters and varietal purity, and all rules associated with those grades are complied with, including: • Applicable dates for implementation of new seasons standards • Re-classification of old seasons grain • Blending of old and new seasons grain

13. Marketing (part 2) • Certification is only to be supplied based on appropriate information such as records • Domestic grain meets APVMA/FSANZ MRLs • Export grain meets Codex, Cartagena etc • Each industry stakeholder recognises its responsibility to maintain the reputation of Australian grain & will adopt policies and processes to ensure that future trade to markets is enhanced • The commercial relationship between parties will be managed by a contract. Where possible, use GTA Trade Rules • Publish all fees and charges associated with any products or services in a transparent and clear manner • Deduct statutory and industry levies and end point royalties • Operators of Pools will provide fair ESR estimate and relevant reports on the operations of the Pool to stakeholders

14. Training • Encourage professional development though the continual development of training to maintain high professional standards • All staff including contractors and/or registered officers are to be adequately trained in the requirements of the Code. Where required, all suppliers are audited against their stated competency and records kept • Keep skills and accreditations up to date (e.g., yearly refresher training on application of grain standards) • Maintain documented evidence of training completed

15. Compliance • Industry participants will have in place a procedure for dealing appropriately with any customer complaints • In the first instance any complaint about the conduct of a Code Signatory should be referred to that Code Signatory who should be allowed a reasonable time to address or resolve the complaint. • If the complaint is not resolved to the complainant's satisfaction the complainant should contact the GTA [CEO] [Code Compliance Officer] who can advise whether the complaint falls under the jurisdiction of this Code and the GTA Board of Directors. • Any complaint will be dealt with in accordance with the Complaint Handling Guidelines

16. Technical Guideline Documents • Technical guideline documents have been requested by industry as a supplement to the Code. These documents will provide industry with more detailed information to assist implementation of each listed activity as outlined in this Code. • Industry is encouraged to participate/lead development of these documents • There are two levels of prioritisation for development of these documents: • In 2012 when finalising the Code • Future years, a long list…..

17. Technical Guideline Documents 2012