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