On Sept. 10, 2015, the US Food and Drug Administration (FDA) released new rules that could directly affect cotton gins across the country by next year.
Most people don’t think of cotton gins as producers of food, but since 2003, cotton gins have been required to register with the FDA as a producer of food for animals. We call it feed; FDA calls it animal food. Under a couple of different acts of Congress, first in response to the 9/11 attacks and then as a result of an ongoing effort to better protect the American people from food-borne illnesses, producers of food for both animals and humans have been subject to FDA rules and inspection.
Until last month, the most a gin had to do was register, renew every other year and maintain records of who brought them cotton and who they shipped cotton seed to. A few gins would get inspected each year, but there was relatively little disruption or real impact to the industry. The new rules developed as part of the Food Safety Modernization Act (FSMA) have the potential to change that.
Cotton gins are an extension of harvest. We’ve been treated as such by many different agencies and in their rules for decades. As such, all we do at the gin is separate the seed from the lint. The lint is the primary product, and the seed is a bonus. Many gins ship seed directly to a mill while others hold some for a period of time and ship out periodically to dairies around the country. Our seed is stored and shipped very similar to grain at a grain elevator.
Under the new rules, cotton gins are treated differently from elevators. Elevators, as we understand it, are exempt from some key portions of the new rules. The number of hoops that they have to jump through are minimal – very similar to the past with the biggest burden being recordkeeping – something they are already doing. For some reason, cotton gins are treated differently. We are still trying to understand FDA’s justification for the different treatment, but as it stands, gins will have to do a hazard evaluation and develop and implement plans to address any of the hazards discovered in the analysis. This seems an unnecessary burden if we are functioning the same as an elevator.
The new rules are being implemented over the next 12 months with the evaluations and plans required to be in place by September 2016. In the meantime, your state and regional cotton ginners associations, in cooperation with the National Cotton Council and National Cotton Ginners Association, are planning on opening a dialogue with FDA to discuss the different treatment of gins versus other facilities that store feed.
As this process moves forward, your associations will be keeping members informed as to the rule specifics and how to comply with whichever sections are finally applicable. Our goal is to keep this process as simple and practical as possible while achieving the intent of the new rules. Expect more from your organizations as things move via their normal communications, newsletters and/or blogs.
Dusty Findley of the Southeastern Cotton Ginners Association contributed this article. Contact him at (706) 344-1212 or firstname.lastname@example.org.
Make Your Plans To Attend 2016 BWCC
The 2016 Beltwide Cotton Conferences are scheduled for Jan. 5-7 at the Marriott Hotel in New Orleans. Make plans to attend this meeting, which will feature the annual Ginning Conferences. Call the National Cotton Council at (901) 274-9030 for more details.
Nov. 18: PCCA Board Meeting, Lubbock, Texas.
Dec. 8-10: C. Board/CI Meeting, Williamsburg, Va.
Dec. 16: PCCA Board Meeting, Lubbock, Texas.
Jan. 5-7: BWCC, New Orleans, La.
Jan. 13-14: Cotton/Rice Conference, Memphis, Tenn.
Jan. 20-23: Southern/SE Meeting, Savannah, Ga.
Jan. 27: Ga. Cotton Commission Meeting, Tifton, Ga.
Feb. 5-7: NCC Annual Meeting, Dallas, Texas.
Feb. 29-March 3: Cotton Board Meeting, Memphis, Tenn.
June 7-9: Cotton Incorporated Meeting, Dallas, Texas.
July 31-Aug. 3: S./SE Board Meeting, Amelia Island, Fla.
Aug. 2-4: C. Board/Cotton Inc. Meeting, Scottsdale, Ariz.
Aug. 24-26: NCC Board Meeting, Memphis, Tenn.
Jan. 4-6: BWCC, Dallas, Texas.
Jan. 18-21: S./SE Annual Meeting, Charlotte, N.C.