ON-FARM FOOD SAFETY
by Cam Dahl, Executive Director Grain Growers of Canada

For the past two years, work has been undertaken, through the Canada Grains Council, on the development of an on-farm food safety program for the grains and oilseed sector. This project has received increased focus because of the Agricultural Policy Framework. The time is rapidly approaching when decisions will be made on if and how to proceed with a grains and oilseed program. These decisions will have a direct impact on the operation of your farm.

There is a growing demand for food safety assurances from Canadian consumers and just as importantly, from some of Canada's key export markets like Japan. Development of the program was begun to meet this demand and to ensure that Canadian grains and oilseeds retain their well-deserved reputation for high quality.

If the program is constructed with the needs of Canadian grains and oilseed farmers as the primary driving force, an on-farm food safety program will become a valuable tool for producers. If these concerns are not at the forefront through the development of the program, we may find the resulting system costly, excessively restrictive, and a hindrance to the expansion and development of our industry. In particular, we are concerned with the potential cost of any program and the potential intrusiveness of an incorrectly designed audit program.

The crucial component of an on-farm food safety program for grains and oilseed will be the management of pesticides. Farmers will be asked to keep track of the type and quantity of pesticides applied to each crop. The timing of application will also be critical; to ensure that pre-harvest intervals are not overlooked.

Some system of auditing farmers' record keeping will also be part of the program.

The Grain Growers of Canada's (GGC) overriding key principle is that grains and oilseed farmers must manage any grains and oilseed on-farm food safety program. This is the same model upon which other food safety programs have been developed (e.g. livestock). Producer representatives must be selected from the commodity organizations that have chosen to voluntarily participate in the food safety program.

Any grains and oilseed program must also recognize the fact that our sector's food safety needs are different from other parts of the agriculture industry. Grains and oilseed producers do not have the same issues regarding spoilage or the risk of food borne pathogens as other sectors. It follows that our food safety requirements will be different as well. For this reason the GGC strongly believes that any program must be tailored to our specific requirements and not based on a whole farm concept.

It is also the position of GGC that the program will not require extensive yearly independent audits. Again, this is due to the unique situation facing the grains and oilseed sector. An alternative approach, such as random audits (e.g., 5% of participants) would be a better fit for our industry and would help minimize the costs of any program. Costs would also be reduced if audits of different commodity programs were combined and conducted by a single individual. Just because a program is not based on a whole farm model does not mean that the individual conducting a corn audit could not also carry out a wheat audit at the same time.

The GGC has outlined eight key principles that we believe should be followed. These principles are outlined below. We believe that farmers' involvement and participation in an on-farm food safety program would be significantly enhanced if these principles were adopted.

1. Program must be commodity specific, rather than whole farm. A whole farm option could be retained if it was done on a voluntary basis for individual farms.
2. Participation in the program by a commodity group will be market driven (i.e., is there a demand for an on-farm food safety program) and voluntary.
3. Least cost principles must be followed:

4. The certifying body must be overseen by a Management Board comprised of grains and oilseed producer representatives from all commodity organizations that have chosen to participate in the on- farm food safety program. The Management Board will also include representation from the Canadian Food Inspection Agency.
5. Appeal process and ombudsman must be available.
6. Program should be HACCP based and only related to safety issues not quality concerns.
7. Growers will keep and own the records.
8. The program must be cost shared (governments, industry, farmers) in such a manner to ensure that the cost burden does not disproportionately fall upon producers.

If any reader would like to discuss this issue further or would like to learn more about the process, we would be happy to discuss it in greater depth.