The National Cotton Ginners’ Association is diligently managing multiple issues. Among the most serious is the threat posed by plastic contaminants — a concern addressed by National Cotton Council President/CEO Gary Adams in this magazine’s August issue and one that NCGA President David Blakemore has talked about in various ginner meetings across the Cotton Belt this year.
The NCGA will continue its training of gin employees on proper round module wrap removal. We also will continue supporting research at the three U.S. Department of Agriculture ginning laboratories where scientists are investigating methods to detect and remove plastic contamination before it gets too far along in the ginning process. In the meantime, we are strongly urging the industry’s use of the contamination prevention resources available on the NCC’s website at www.cotton.org/tech/quality/contamfree.cfm.
Support For Labs And Research
Regarding the ginning laboratories, the NCGA has worked with the NCC this past year on the NCC’s 2018 federal appropriations request, which called for specific increases in the budgets for all three labs. The NCGA sent letters to both the Senate and House appropriations committees’ chairmen requesting that the labs be funded at the 2017 level and not eliminating the Stoneville, Mississippi, gin lab as was proposed in the president’s budget.
The NCGA also continues to support and be an advocate for other quality-related research. Ginners have indicated that when it comes to cotton quality and gin efficiency, the top concerns are leaf hairiness, seed coat fragments, seed size, seed loss from ginning and small seed-size varieties. There is no doubt that with the increased capacities of modern gin machinery, we have a desperate need for better communication to take place between researchers, the ginning industry and gin equipment manufacturers.
I am pleased to note that more than 300 active ginners responded to a survey about bale tie usage, including the reasons for specific tie type choices and if there were plans to switch bale tie types. Although the NCGA does not advocate any bale tying system, we took the lead in conducting the survey – as part of an effort to seek views from all raw cotton sectors. The goal is to help the Joint Cotton Industry Bale Packaging Committee respond to a U.S. manufacturer’s request to eliminate wire ties by the 2018 crop year.
Addressing Burdensome Rules
The NCGA also has been dealing with several onerous regulations.
Among those are the Food & Drug Administration’s proposed Food Safety Modernization Act and the Animal Food Rule. We assumed that FDA would exempt those low-risk commodities held in facilities, such as grain elevators and warehouses, which store only raw agricultural commodities intended for further distribution or processing. However, in the final rule for Preventive Controls for Animal Food published in 2015, the FDA said it believed the application of heat to dry the seed cotton could be considered a process.
The NCGA and NCC continue to represent the industry’s interests with FDA about compliance with this rule, which includes contesting the agency’s belief that cottonseed should be treated differently from grain. We also pointed out that the FDA’s decision to regulate gins based on ownership structure or type was illogical and not germane to the rule. The NCGA and NCC continue to work to ensure that gins are treated equitably under this rule.
Tracking Illnesses And Injuries
On another significant matter, the ginning industry gained additional time for complying with the Occupational Safety & Health Administration’s “Improve Tracking of Workplace Injuries and Illnesses.” This rule would require employers to electronically report workplace injuries.
Comments on this proposed rule are due by Dec. 1, 2017, to provide the administration with an opportunity to review the new electronic reporting requirements and allow affected entities sufficient time to familiarize themselves with the reporting system. Both the NCGA and the NCC plan to submit comments. Both also plan to convey any concerns regarding OSHA’s announced intention to issue a separate, future proposal to reconsider, revise or remove parts of the prior final electronic reporting rule.
Harrison Ashley, executive vice president of the National Cotton Ginners Association, contributed this article. Contact him at (901) 274-9030 or firstname.lastname@example.org.
Sept. 20: PCCA Annual Meeting, Lubbock, Texas
Sept. 20: PCCA Board Meeting, Lubbock, Texas
Sept. 20: Staplcotn/Stapldiscount Annual Meeting, Greenwood, Miss.
Sept. 25: Calcot Ltd. Board of Directors/Auditors Meeting, Phoenix, Ariz.