February 24, 2010
Grain Inspection, Packers & Stockyards Administration
US Department of Agriculture
1400 Independence Avenue SW
Room 1643-S, Washington, DC 20250-3604
RE: United States Standards for Wheat Notice Comments
Submitted via email to: [email protected]
These comments are in response to the November 27, 2009 Advance Notice of Proposed Rulemaking (ANPR) published on page 62257 of the Federal Register by the Grain Inspection, Packers and Stockyards Administration (GIPSA) inviting comments on whether the current wheat standards and grading practices need to be changed. We believe that some changes to the official standards for wheat are needed.
The North American Millers’ Association (NAMA) is the trade association representing the wheat, corn, oat and rye milling industry. NAMA’s 47 member companies operate 170 mills in 38 states and Canada. Their aggregate production of more than 160 million pounds per day is approximately 95 percent of the total industry capacity. About 80 percent of that production is milled wheat products.
USDA/Economic Research Service’s Marketing Year 2009/10 data show US millers are projected to purchase about 940 million of the 2.2 billion bushels of wheat produced, more than all export customers combined (825 million bushels).
Most, if not all, the factors in the US wheat standards were adopted many years ago. Unfortunately, through the years the standards and test methods for measuring compliance with them have not kept pace with market demands or testing technology.
Standards are simply a short-hand means of providing buyers and sellers with information about the value of the grain. But many of the factors that reflect true intrinsic value are either not included in the official US standards, or are included in only a backhanded way.
Of these we have identified these quality factors as deserving particular attention:
We will address each of these in more detail.
The function of standards is to provide a shorthand method of quickly communicating the value of a lot of wheat. At its most basic, that value is a reflection of the amount of saleable product – flour – that can be extracted from the wheat.
Consider: an average flour mill produces about one million pounds of flour per day, which depending on market conditions will generate gross revenue of about $150,000 per day. A flour yield reduction of just 1.0 percent reduces gross revenue by $1500 per day. Over a year of 300 production days, this impact grows to $450,000. Yet nowhere in the Official Standards for Wheat is flour yield mentioned.
NAMA encourages GIPSA to begin studying how a simple, precise and repeatable flour yield test can be incorporated into the official wheat standards.
Insect-damaged kernels (IDK) is an important indicator of the level of hidden insect infestation in the lot of grain. Certain insects chew holes in wheat kernels prior to laying eggs inside the kernel. These eggs, if not killed by chemical fumigants, will hatch and begin a new generation of live infestation in the wheat. If left unchecked, they will create a pest explosion.
The current standards specifically allow 31 or fewer IDK in a 100 gram sample before such damage causes the sample to be graded Sample – the lowest grade. Wheat kernels vary in size, of course, but generally speaking there are approximately 32 kernels in 1 gram, or 3200 kernels in 100 grams. So an IDK threshold of 32 is about 1.0 percent.
From years of real-world experience, millers know that IDK counts vastly underreport the actual level of infestation.
To meet sustainability goals, ours and those of our customers, the milling industry is attempting to use fewer pesticides. Our ability to control insects already in the grain is being reduced. Thus, every US miller’s purchasing specifications are far more strict on the point of IDK than the official wheat standards. Most US mill contracts limit IDK to between zero and three IDK. We believe a GIPSA IDK limit of five per 100 gram sample would be appropriate.
Live insect infestation
As wheat is food, there is no acceptable reason why GIPSA should permit live insects in the sample. Yet currently that is precisely the case. To receive the special designation “Infested,” a 1.0 kilogram sample must contain two or more live weevils, two or more live insects injurious to stored grain or a combination of the two.
Consider that a modern railcar holds approximately 3600 bushels of wheat – about 216,000 pounds, or about 98,000 kg. So, according to GIPSA regulations a railcar of wheat could theoretically contain nearly 98,000 live insects and still receive the top grade of US No. 1. While that is an extreme (although possible) example, it does provide a useful illustration of the lack of usefulness of the official standards. Wheat with even a fraction of that level of infestation, when milled, would produce flour in violation of the US Food and Drug Administration’s (FDA) action level on insect fragments.
On both the points of insect damaged kernels and live infestation, we believe it illogical, and indefensible, that one agency of the federal government (GIPSA) allows insect infestation at a level in wheat that, once milled, would be considered adulterated by another federal agency (FDA).
Protein quality (vs. quantity)
Over the last 20 years GIPSA has greatly increased its ability to measure wheat protein quantity with precision and repeatability. We commend the agency for that progress. We are particularly complimentary of the collaborative hard red spring protein studies NAMA and GIPSA have conducted annually for 20 years. That effort has dramatically improved the agreement between mill and official protein test results.
The next step is for the agency to develop a rapid, precise and repeatable test for protein quality. We encourage GIPSA to begin that work as soon as possible.
Currently, mycotoxins in wheat are not reflected on the official certificate. Mycotoxins may be associated with some forms of damaged kernels that are grading factors. However, the level of damaged kernels allowed in, for example, US No. 2 wheat is 4.0 percent. Wheat that contains 4.0 percent kernels damaged by disease (and therefore likely infected with mycotoxins) may very well produce flour that exceeds FDA guidelines. Using Damaged Kernels counts as a surrogate for expressing mycotoxin contamination is only an estimation and underreports mycotoxin contamination. We encourage GIPSA to study appropriate ways to incorporate mycotoxins as a grading factor.
Additionally, NAMA strongly believes the methods of validating mycotoxin test kits needs to be made substantially more rigorous. We understand there are currently 13 such tests available for deoxynivalenol (DON), with more under review for validation. Yet we frequently encounter DON test results that are imprecise and/or not repeatable. If the requirements for validation were made significantly more stringent, many of the less robust test kits would fail validation and the overall performance of the DON testing regime would be improved as a result. Validating and approving five or six of the best tests would be far superior to the current situation.
Finally, we recommend GIPSA implement a mycotoxin testing check sample program utilizing naturally contaminated reference material.
Alpha amylase enzyme activity
Alpha amylase activity in the wheat kernel breaks down the starch in the wheat kernel, thus diminishing or destroying the inherent value of the wheat for most food manufacturing uses.
Under current GIPSA inspection procedures, sprout damage is only counted by inspectors when it can be visually detected. However, before the point at which sprouting activity can be visually detected there has already been much unseen alpha amylase activity in the kernel. This enzyme activity, although undetected, causes a substantial decrease in the value of the wheat.
Current methods available for measuring unseen alpha amylase activity, such as the Falling Number test, produce results that often fall short in their precision and repeatability. We encourage GIPSA to begin development of a rapid alpha amylase test for deployment in the official inspection system.
Definition of Wheat of Other Classes
Currently, hard red spring (HRS) and hard red winter (HRW) wheat detected in a sample of hard white wheat (HW) are treated by GIPSA as “Contrasting Class” with the limit being 3.0 percent in US No. 2. We recommend changing the definition of HRS or HRW found in HW to be “Wheat of Other Classes” so the limit on US No. 2 would be 5.0 percent. We believe such a definition change may encourage the production of hard white wheat, which has struggled to gain acceptance by growers and the marketplace.
We appreciate the opportunity to submit these comments and any consideration you may give them.
James A. Bair