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HOW FAR do crop producers have to go to prove the corn, soybeans or hay growing in their fields is safe for animals or people to eat? Today the U.S. Food and Drug Administration's trace-back requirements for field crops and hay are relatively simple to follow, but some officials predict more detailed records could be necessary in the future. Although you aren't required to tag every single hay bale yet, it might be a good idea to start moving toward collecting more detailed information about that grain or hay crop.

According to the Public Health Security and Bioterrorism Preparedness and Response Act of 2002, if animals or humans get sick due to contaminated food or feed, and the feed ingredients may have originated on your farm, an FDA agent may come knocking at your door. Food safety is the goal behind the requirements agricultural producers need to meet in order to comply with the Bioterrorism Act.

Right now, grain handlers, feed mills and processors bear the major responsibility for tracking grain or hay. Most producers will only need to be prepared to provide information on the grain and hay they sell, showing “one step up and one step back,” according to industry officials. This means being able to show where the grain or hay came from and where it was sold.

What is “compliance”?

There is some confusion among producers regarding just what “compliance” means in regard to the Bioterrorism Act, what action needs to be taken, and even questions about who is required to provide what information. The FDA provides answers to many of the questions on Web sites such as However, just sorting through all the jargon to get to the agricultural information is challenging.

According to FDA officials, some producers think they don't have to keep records simply because they have heard that farms are exempt from the Bioterrorism Act requirements. But that is not necessarily the case. It is crucial to read the definition of “farm” closely. As FDA officials point out, the Recordkeeping Final Rule (Title 21 of the Code of Federal Regulations (DFR), Part 1, Subpart J) does exempt “farms” from all record-keeping requirements. Keep reading! It is important to pay attention to the details of the definition, because “farm” is defined as a “facility in one general physical location devoted to the growing and harvesting of crops, the raising of animals (including seafood), or both. The term ‘farm’ includes: 1. Facilities that pack or hold food, provided that all food used in such activities is grown, raised, or consumed on that farm or another farm under the same ownership; and 2. Facilities that manufacture/process food, provided that all food used in such activities is consumed on that farm or another farm under the same ownership.”

So if you sell what you grow, and you don't own the buyer's farm, you may have to provide information for the transfer of records.

Information to the elevator

“The farmer is not exempt from providing the information to the elevator regarding where that crop came from, for example,” says Howard Shepherd of the Iowa Grain Quality Initiative, a program of Iowa State University. When a producer delivers his grain or hay, he has to pass on information regarding who he is, what the farm address is, and his telephone number, e-mail address and/or fax number. This is required when the producer decides to market the grain to another buyer, whether it comes right out of the field, into the wagon, into the truck and into town, or whether it goes into a bin before going into town.

“As soon as that grain goes out of the gate from the farm facility to another buyer, the information needs to go along,” Shepherd states. “Once the transfer is complete, the scale ticket from the elevator can serve as documentation that the grain has been shipped and received. The recipient, such as the elevator, alcohol plant, etc., has to keep the records about where that crop came from. The load has to be tagged with the recipient information by the elevator.”

If a third-party transporter, such as a contract trucker, delivers the grain, the transporter is also responsible for getting the information about where the crop is coming from. It is the transporter's responsibility to make sure the elevator gets the necessary information. “Today, most elevators are going electronic, so they want to set up a delivery ticket process, and the farmer will probably have called in to tell the number of loads that will be brought in,” Shepherd says. “Usually the elevator knows their clientele; however, if the elevator does not get the information they need, they could refuse the delivery. The farmer needs to understand that the load can be refused if the necessary information is not clearly passed on to the recipient.

“Most people won't have to drastically change their record-keeping practices, but from a biosecurity perspective, additional information would be helpful,” Shepherd continues. “I believe even though the producer is exempt, he needs to keep better internal records for himself, just to protect himself.”

Traceability is here

Members of the Iowa Grain Quality Initiative predict that more thorough grain and feed trace-back requirements are on the horizon. “We are trying to get the grain-handling industry to understand that traceability is here and it could be an FDA requirement in the future in a lot more definitive requirement than one step up and one step back,” Shepherd states. “And it is not that we are mandating it. Europe is already defining traceability. If we want to be participants in the market, we are going to have to have traceability from that product they use in Europe all the way back to the farm at some point in time.

“When you look at Asian countries, they are tracing about 120 pesticides. When they receive grain in, they want to know what pesticides were applied to that crop. So traceability is here. It just isn't defined to an exact science at this point in time.”

Some companies are already working on products to help producers and other facets of the grain-handling industry with grain and hay-tracing options. ScoringAg, a division of Scoring Systems, Sarasota, FL, offers a Web-based system for complete trace back for all feed and food products, including ingredients and commingled bin products, from the field to the retail store. Producers, transporters, processors, brokers and everyone involved in the food or feed chain can keep their records confidentially in the Scoring Ag database. A record for any commodity, such as a field of hay or grain, costs only $0.55 and includes all activities performed on the commodity. Planting, spraying, harvesting and transporting can be recorded in the database.

Every commodity page creates a unique identification number. This allows a trace to every location where the hay or grain has been. “This helps everyone in the chain of custody to protect themselves from expensive recalls and provides the needed records for the FDA,” says William Kanitz, president of ScoringAg. “Trace-back labels can be created with the system-generated bar codes or RFID [radio frequency identification] labels even for finished products.”

Lean more at the ScoringAg Web site at

Who needs to register?

Producers are only required to register their facilities with the FDA and keep records of feed sales if they process and sell feed products. If the farm is going to use the processed feed products strictly on the farm, then the farm is exempt. Producers who simply harvest corn or hay are not required to register but may want to keep basic records regarding where the product came from and where it was sold.

Registration may be done online at the FDA Web site at

Dan Undersander, University of Wisconsin forage agronomist, is working to educate hay producers about how the rules may apply to them. “Farmers who simply bale hay for sale do not have to register their facilities or maintain records,” he states. “The FDA does not consider baling hay as processing.” Undersander says all the FDA needs is a receipt in a receipt book showing the person or entity that bought the hay and the quantity that was purchased. “There is no requirement that hay producers keep track of individual bales and where they go,” he says. “Records that are maintained for tax purposes which show that a sale was made and to whom the sale was made should be sufficient for compliance. The new FDA rule will not require a farmer to change record keeping as long as details of the feed sale are recorded.”

Don Kieffer, executive director of the National Hay Association based in St. Petersburg, FL, says many commercial hay producers have been keeping the right type of records for years. “Requirements as far as selling baled hay are ‘one up, one down,’” he explains. “This means producers have to identify where the hay came from and where it is going. This isn't a concept that just popped up because of bioterrorism. Good producers are already keeping these types of records, in addition to keeping track of any chemicals, pesticides or preservatives that have been applied to fields and specific crops.”

Undersander points out, however, that drying hay or grain and chopping for silage are considered postharvest activities, which would be considered manufacturing/processing. Therefore, the facility drying hay or grain or chopping forage must establish and maintain records of the feed's receipt (if purchased) and release (if sold) as required in 21 CFR 1.337 and 1.345. Those producers selling silage or total mixed rations (TMRs) would fall under this requirement.

Food safety

The Iowa Grain Quality Initiative is developing training modules to help producers understand what action needs to be taken regarding the Bioterrorism Act. The group's home page on the Internet has a step-by-step PowerPoint presentation to walk producers through the registration and record-keeping processes. Visit the group's Web site at

Iowa State's Shepherd sums up why producers should be concerned about tracing their crops. “It all comes down to food safety,” he says. “You can't really define food safety if you can't trace the food. And more complete traceability will probably be pushed from the food processor back to the producer in the future.”

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