KAP submission to Canadian Grain Commission: Falling number and DON as potential official grain grading factors

May 10, 2019

 Keystone Agricultural Producers (KAP) is Manitoba’s general farm policy organization, representing and promoting the interests of thousands of agricultural producers in Manitoba. Our membership consists of over 6,000 members and 25 commodity groups who set our organization’s policy through a grassroots governance structure. We work with government, industry and stakeholders to ensure that primary production in Manitoba remains profitable, sustainable, and globally competitive.

On behalf of KAP, please accept the following comments on the Canadian Grain Commission’s discussion on using falling number and DON as potential grain grading factors. The comments included in this submission were developed through KAP’s Grains, Oilseeds and Pulses (GOP) committee. 


The GOP committee appreciated the opportunity to meet with Doug Chorney, Lonny McKague and Dave Hatcher to discuss the details of the CGC’s current consultation on this important topic. The committee was able to get more information about the rationale for exploring the issue, the details of the tests themselves, and the potential approaches for implementation.


KAP recognizes the value that the Canadian grain quality assurance system provides to the agricultural sector and the important role it plays in upholding Canada's reputation as a producer of high-quality grain on the world market. Grading ensures that farmers are paid a fair value for their product and that customer requirements are satisfied. In considering any changes to the grading system, it is critical that thorough analysis be undertaken to identify the impacts to all players in the grain industry.


The committee has expressed concern with the lack of analysis on the impacts of adding DON and falling number as grading factors (i.e. how often it would result in a grade change and what the resulting financial impacts would be to producers). Therefore, it is wary of supporting this concept until such information is provided.

Since the grain companies negotiate the contracts, the committee feels that the companies will initiate testing for DON and falling number when they begin to be pressured by the end buyer to deliver based on those specifications. If producers advocate for such a testing system, this could ultimately work against them as it introduces a way to downgrade.


Overall, the committee is in support of the Harvest Sample Program continuing to test for DON and falling number, but would like to see more analysis on the impacts of adding DON and falling number as grading factors before taking a position on the issue. Committee members agreed they do not want to see testing done at the pit every single time a delivery is made and are not ready to change how they sell grain.

On behalf of KAP, thank you for your consideration of this submission. We appreciate the opportunity to be involved in discussions that affect the future of the grain industry.

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Email: kap@kap.ca