FIRST EDITION PUBLISHED JULY 2013. THIS VERSION JULY 2025. © Grain Trade Australia MANAGEMENT OF GRAIN WITHIN THE AUSTRALIAN GRAIN SUPPLY CHAIN: Australian Grain Industry – Code of Practice
Previous versions of Management of Grain within the Australian Grain Supply Chain Australian Grain Industry - Code of Practice: First Edition: July 2013 Updated: May 2018 Updated: July 2025 Compiled on behalf of the Australian Grain Industry by Grain Trade Australia This version of the Australian Grain Industry Code of Practice (Code) is current at the date of printing in July 2025. Please note - the Code, the Transport Code of Practice and supporting Technical Guideline Documents are subject to review and amendment as determined by GTA. GTA reserves the right to update and make changes to these documents. To ensure access to the most recent version of any of these documents, including GTA Trade Rules and Standard Form Contracts, please visit the GTA website. www.graintrade.org.au Australian Grain Industry - Code of Practice
Table of Contents Section 1: About this Code of Practice 1.1 Purpose of the Code 2 1.2 Scope of this Code 2 1.3 Industry Endorsement 3 1.4 Supporting Codes and Technical Guideline Documents 3 Section 2: Code of Practice Requirements 2.1 On-Farm Activities 4 2.1.1 General Processes 4 2.1.2 Crop Growth 5 2.1.3 Grain Harvesting and Storage 5 2.1.4 Movement ex-farm 6 2.2 Grain Sampling and Testing 6 2.2.1 General Requirements 6 2.2.2 Equipment to be Used 6 2.2.3 Equipment Monitoring and Calibration 7 2.2.4 Trade Certification of Equipment 7 2.3 Storage Facilities 7 2.3.1 Storage Construction & Maintenance 7 2.3.2 Stored Grain Pest & Hygiene Management 8 2.3.3 Storage Operations 8 2.4 Chemical Use 9 2.4.1 Regulations 9 2.4.2 Industry Practices 11 2.4.3 Chemical Application 12 2.5 Grain Quality Management 12 2.5.1 Commodity Vendor Declaration 12 2.5.2 Quality Checks 13 2.5.3 Grain Receival & Segregation 13 2.5.4 Grain Quality Management during Storage 14 2.5.5 Grain Outturn - Domestic 15 2.5.6 Grain Outturn - Export 15 2.6 Transport 16 2.6.1 Regulations 17 2.6.2 Processes 17 2.7 Marketing 18 2.7.1 Understanding Market Requirements 18 2.7.2 Marketing Australian Grain 19 2.7.3 Market Access 21 2.7.4 Sustainability, Environmental Social and Governance Credentials 21 2.7.5 Contract Documentation 22 2.7.6 Grain Pool Providers 23 2.7.7 Data Management 23 2.7.8 Financial Management 24 2.8 Training 24 2.9 Complaints 25 2.9.1 Customer Complaints 25 2.9.2 Complaints against an Industry Participant 26 Section 3: Reference Material Appendix 1 - Glossary & Definitions 27 Appendix 2 - Technical Guideline Documents 32 1
1.1 Purpose of the Code This Code of Practice (Code) is a practical guide for participants in the grain industry to achieve the standards and expectations of domestic and export customer requirements. Customer requirements include those stipulated in contracts and regulatory requirements at the Australian State, Territory and Federal levels and international and overseas country level. Compliance with the Code is mandatory for members of Grain Trade Australia (GTA). Code terms are not incorporated into any contract unless the parties expressly agree to do so. Associated with this Code are also: i. A range of industry Standards; ii. Ancillary Codes of Practice, such as the Grain Transport Code; iii. Technical Guideline Documents (TGDs) that support and provide greater detail of components of the Code; and iv. A range of other documents produced by GTA on topics of relevance within this Code. Whilst each industry participant manages their own operations based on the needs of its customers, their own commercial operations, internal procedures and systems, this Code focuses on common standards, operating procedures and documented processes. In adopting this Code all participants accept they shall be individually responsible for implementing the necessary systems, procedures, and processes to achieve the purpose of the Code. Adoption of this Code will provide all industry sectors including Governments, researchers and consumers with confidence that grain industry processes and management systems exist in Australia to successfully: i. Guide the farm-based production practices of grain; ii. Ensure effective assessment, classification, storage and transport of grain; iii. Promote the Australian industry and its grain in support of market access; and iv. Supply grain that meets the expectations of the market. Self-regulation is a key focus of the grain industry. An objective of this Code is to support that purpose by providing guidance to industry that outlines minimum requirements of all involved in the Australian grain industry. GTA will continue to review this Code with input from industry and Government, to ensure its integrity is maintained. 1.2 Scope of this Code This Code provides practical guidance for persons conducting business in the Australian grain industry. It has been developed to be applicable to all grain and grain products and applies to all processes and activities from market driven varietal classification, grain production through to the end consumer. The Code has been designed to promote the use of best management practice by industry participants. This means: • Mandatory compliance with all laws and regulations; and 2 Section 1: About this Code of Practice
• Recommended compliance with accepted industry practices as documented in this Code including: - On farm management practices; - Quality Assurance systems; - Storage and transport practices; - Sampling and testing regimes; - Grain quality management; - Marketing and contractual arrangements; - Environment, sustainability and traceability management; and - A complaint handling procedure. 1.3 Industry Endorsement All organisations involved in the Australian grain industry from plant breeding to the end consumer are encouraged to adopt this Code. Industry participants who adopt this Code agree to: • Comply with all laws and regulations relating to the growing, merchandising, inspection, grading, weighing, storing, handling and transport of grain, including relevant Workplace Health and Safety regulations; • Conduct activities considering the impact on the environment; • Conduct activities in a sustainable manner; • Comply with legal requirements for the application and use of chemicals at all stages along the supply chain; • Comply with Australian and importing countries' maximum residue limits (MRLs) and other regulated import requirements such as food safety parameters and biosecurity; • Implement financial management standards where applicable; • Comply with industry standards, processes and procedures; • Conduct activities and manage data and all transactions as required in a secure manner; • Where contractors are used, comply with industry and individual company procedures; • Maintain and promote the use of industry-accepted management practices, standards and procedures in the transaction of business; • Promote the Australian grain industry and its grain in support of market access; • Promote the adoption of safe practices at all stages along the supply chain; and • Improve the standards of practice and service in the Australian grain industry. 1.4 Supporting Codes and Technical Guideline Documents The Code is supported and enhanced by ancillary Codes of Practice (Grain Transport Code), Technical Guideline Documents (both existing and under development) and other documents including GTA Fact Sheets. The purpose of these supporting Codes and Technical Guideline Documents (see Appendix 2) is to: • Provide more detailed information to industry on specific activities; and • Assist implementation of each listed activity as outlined in this Code. Industry is encouraged to provide input into the development of Technical Guideline Documents and other instructional documents. 3
This Code is structured on a number of activities that industry undertakes along the supply chain commencing with OnFarm Activities. There is no intention to prioritise each activity, as all are considered essential to managing grain within the Australian grain industry. There are many generic requirements and processes that are applicable to more than one of these activities or areas of industry operation. For example: • Mandatory compliance with applicable regulations; • Staff training; • Impact on the environment; • Documentation of procedures; • Collection of data and maintenance of records; and • Traceability through the supply chain. 2.1 On-Farm Activities All farm related activities are carried out in compliance with the Stewardship Guide Growing Australian Grain - Safely managing risks with crop inputs and grain on farm available from Grain Producers website.1 That guide details information for grain growers and their advisers about managing risks with inputs, grain handling and safety on-farm. 2.1.1 General Processes This activity refers to all processes occurring on the farm including: • Pre-sowing; • Crop growth and agronomy practices; • Harvesting; • Storage; and • Transport. At all stages the crop and/or harvested grain is managed to consider the impact of those practices on producing grain that meets market requirements. These factors include yield, grain quality, agronomic aspects of the crop and environmental impacts, and to limit and/or eliminate the presence of toxins, microbial and other contamination, non-approved chemical residues, live stored grain insects and contaminants as appropriate. Activities conducted in all areas of operations for this purpose include: • In-crop monitoring for insect pests, weeds and diseases; • Biosecurity risks are managed appropriately; • Maintaining the hygiene of storages, vehicles, equipment and surrounds; • Minimising contamination of the commodity produced; • Complying with regulatory requirements and controls at all times; • Conducting activities according to workplace health and safety regulations and other labour laws such as modern slavery; • Prior to and during crop growth, chemicals are applied based on agronomic and environmental conditions. • Complying with any regulatory or industry requirements as appropriate for grain, including sustainability, traceability and environmental management of producing grain; and • Contractors used to carry out an activity providing a declaration attesting to compliance with industry guidelines. 4 Section 2: Code of Practice Requirements 1 https://www.grainproducers.com.au/australian-grains-guide
Documentation and records of relevant management practices are kept. Records are kept as per requirements of any relevant Federal, State or Territory legislation or as required by industry. 2.1.2 Crop Growth Where applicable, seed purchased for sowing complies with the Australian Seed Federation National Code of Practice for Seed Labelling and Marketing2. Seed should be: • Labelled and traceable; • Accompanied by an assurance that the variety has been tested; and • Treated prior to sowing to minimise potential disease infestation during crop growth. During crop growth a range of agronomic practices are conducted: • To maximise the quality of grain produced; • To maintain the integrity of the crop; • To minimise contamination of the harvested grain; • To control pests and diseases as required; and • Records are maintained of all chemical treatments applied. Principles of managing pests are followed, as outlined in the Farm Biosecurity Manual for Grain Producers3. This includes at a minimum: • Crop monitoring and pest surveillance; • Maintaining good farm hygiene; • Keeping records; and • Reporting suspect pests. 2.1.3 Grain Harvesting and Storage Grain is harvested, handled and stored to preserve its integrity according to industry standards. Where relevant, on-farm storage facilities are managed as per requirements outlined in Section 2.3 “Storage Facilities”. During the harvest operation: • Grain is harvested to maximise its quality based on the end-use; • Grain integrity is maintained; and • Operations are carried out, and equipment is used that will minimise the risks of contamination of the harvested grain. During the storage period: • Documentation and records of all storages used on-farm are kept by the producer; • All storages are maintained in a suitable condition; • Grain is monitored to preserve its quality; • Documentation is kept of grain storage and movement activities to provide traceability of the grain when moved on to the next segment of the supply chain; • Stored grain is managed to comply with the need to be free of live stored grain insects on outturn; and • All chemical treatments to storages, handling equipment and grain are applied as per regulatory and industry requirements. 5 2 https://www.asf.asn.au/wp-content/uploads/2016/06/ASF_Code-of-Practice_WEB.pdf 3 https://www.farmbiosecurity.com.au/wp-content/uploads/2023/05/Biosecurity-Manual-for-Grain-Producers_23.05.23.pdf
2.1.4 Movement ex-farm Prior to loading, all transport and handling equipment is inspected to determine its suitability for use in the loading and transporting of grain. Where external transport agents are utilised a Grain Commodity Truck Cleanliness and Prior Load Declaration should be completed. All aspects of the Grain Transport Code of Practice, as outlined under section 2.6, are followed where relevant. For the purposes of traceability, producers provide appropriate documentation to transport agents when used to move grain from the farm through the supply chain. Grain is accompanied by a Commodity Vendor Declaration (CVD)4 that provides details on the status of the grain as required by the market. As outlined in section 2.5.1, at a minimum a CVD is required: • For the tonnage of grain covered under each individual contract; and • For each truckload tendered for delivery where no contract exists (e.g., at harvest). 2.2 Grain Sampling and Testing 2.2.1 General Requirements Procedures are documented for all major processes associated with sampling and testing grain. These documented procedures for equipment maintenance and use and sampling and testing procedures are outlined in the company Sampling Manual or the Operating Procedures. Where available, industry reference material is to be used to assist the grain classification process. This includes material such as: • GTA Technical Guideline Documents; • Visual Recognition Standards Guide; • Seed Impurities of Grain Identification Guide; • Insects of Stored Grain, A Pocket Reference; and • Equipment operating manuals and instructions. 2.2.2 Equipment to be Used There is a range of equipment available for sampling and assessing the quality of grain against specifications listed in grain quality Standards (Standards). The type of equipment used, and the level of sophistication and accuracy will vary by organisation, location used, purpose of use and commodity being assessed. Only equipment suited to its intended purpose is to be used. The preference is for the use of: • Pneumatic or mechanically operated vacuum sampling equipment rather than manual vacuum or handheld probes when obtaining a sample from a road truck; • A grain divider to obtain a subsample for assessment; and • Objective technology rather than subjective assessment, where available and commercially acceptable and feasible. Where “field methods and equipment” are used, these are to be based on and where applicable, calibrated against the reference methods to provide comparable results. 6 4 https://graintrade.org.au/trade-rules-contracts/
2.2.3 Equipment Monitoring and Calibration All equipment is to be routinely monitored, calibrated and checked as relevant, to ensure correct operation as outlined in the company Sampling Manual or the Operating Procedures. The frequency of calibration and these checks will vary based on the type of equipment, frequency of use and operating procedures of the company. At a minimum, equipment should be checked annually. During periods of continual use, equipment should be checked more frequently. Checking of all equipment including any calibration must be done by a person appropriately qualified to carry out such a task. Personnel may be external to the company or internal staff skilled in that task. Records must be kept of all such maintenance and checks. If equipment is found to not be properly calibrated, the Sampling Manual or Operating Procedures is to be checked for actions to be taken - with corrective action to be taken as soon as practically possible. Refer to the appropriate TGD for specific details by equipment type.5 2.2.4 Trade Certification of Equipment Where equipment is used that falls under National Measurement Institute (NMI) regulations and is considered to be “for trade”, it must meet conditions as outlined by the NMI6. This includes any equipment that is referenced in those regulations such as for grain quality assessment, weighbridges and analytical balances used at any stage throughout the supply chain such as at receival. Industry is committed to the use of all equipment of a standard for “use in trade” where the outcome of the grain classification process is a payment to the supplier of the grain. All other equipment used for testing grain that does not fall under this NMI legislation is also to be checked under similar processes, as it is the desire of industry to ensure all equipment used for grain testing is suited to that purpose. 2.3 Storage Facilities 2.3.1 Storage Construction & Maintenance Grain storage facilities: • Are to be soundly constructed; • Must be maintained to minimise the entry of pests, vermin and moisture that may affect stored grain; • Must prevent seepage of grain from the storage; and • Are to be located in an area, and the surrounds are to be of suitable construction material, to minimise contamination of grain and to prevent damage to stored grain through water ingress. Where an individual storage is categorised as sealed, and is used on that basis, it is to comply with the Australian Standard AS26287. This includes the requirement to comply with the pressure test as outlined in that Standard. Storages should be suitable for the commodity to be stored. For more 7 5 https://graintrade.org.au/technical-guidelines-documents/ 6 http//www.measurement.gov.au/Pages/default.aspx 7 Australian Standard AS2628 Sealed grain-storage silos - Sealing requirements for insect control - http://infostore.saiglobal.com/store/default.aspx
information refer to GRDC Stored Grain Website8. Industry preference is for the use of sealed and well-maintained permanent storages that have aeration to assist maintaining the quality of grain in storage. The structural integrity of storages must be monitored regularly during the storage period to maintain the integrity of the stored grain and to assist in maintaining its quality. Any storage condition that may impact on the quality of grain to be stored should be addressed as soon as possible after detection. 2.3.2 Stored Grain Pest & Hygiene Management (i) General A pest management strategy for all pests should be documented and regularly updated. Where required, additional pest management strategies should be implemented based on seasonal conditions (e.g., mouse plagues) or as required under regulations (e.g., operation of an Export Registered Establishment). Storages, their surrounds and all associated handling equipment should be regularly checked to prevent the entry of and to be practically free of pests, vermin and weeds. Grain spillages and dust should be cleaned and removed from the site as soon as practical following grain movement. Facilities should be regularly cleaned down following out-loading or movement of grain to remove carryover contaminants, assist insect control and assist maintaining hygiene. (ii) Stored Grain Insects For management of live stored grain insects, industry follows the principles of Integrated Pest Management including, where relevant, using tools such as: • Hygiene; • Inspection; and • Aeration. The intention is that grain is to be maintained free of live stored grain insects. Grain should be sampled regularly to determine the presence of live stored grain insects: • Any infestation should be treated as soon as practicable following detection; • When using chemicals, all label directions must be complied with; • The use of chemicals should be done to follow industry guidelines and to meet regulatory requirements and customer specifications; • All chemical treatments to grain should be done to ensure compliance with applicable MRLs; and • Only legal chemical treatments for grain, storages, structures and surrounds are to be used. 2.3.3 Storage Operations Any provider of a storage facility, including storage facilities located at processing and / or container packing facilities must operate that facility to ensure any commodity moving through that facility is not compromised in any way. This includes: • Minimising the risks for contamination of grain with other commodities stored and moved within that facility; and 8 8 https://grdc.com.au/resources-and-publications/grownotes/technical-manuals/grain-storage
• Minimising the risks of contamination of grain with treatments used for insect control on structures and handling equipment. All commercial Storage and Handling operators should provide a Storage and Handling Agreement outlining all terms and conditions. An Example Storage and Handling Agreement for use by industry is on the GTA website9. Procedures will be documented for the major activities occurring at that facility. All staff will be adequately trained. Workplace Health and Safety and Chain of Responsibility procedures will be documented and complied with as required by relevant legislation. Services offered at the storage facility will be documented and, where relevant, documentation will be publicly available that lists a range of commercial services including but not limited to: • Storage and Handling Agreement outlining: - The nature of the service provided; - The responsibility of the storage provider in supplying the service to its customers; - Procedures for allocating lost or damaged grain against inventory when grain is in a commingled ownership state; - Communication to the owner of the grain if an event has damaged the grain or prevents the owner from out turning or accessing the grain; - The liability of the storage provider should grain be lost or damaged; - The obligations of the storage provider covering insurance; and - The price for conducting those services. • Notices of the requirement for industry to be compliant with relevant procedures and actions to be taken by the storage provider in circumstances where non-compliance is detected, such as: - Detection of pickled grain and other nil tolerance parameters that may cause a food safety issue; - Detection of chemical residues in excess of legal requirements; and - An incorrectly completed Commodity Vendor Declaration. As outlined in the Storage and Handling Agreement, trace-back to the grain supply source will occur for investigation of any non-compliance. TGD No.17, Container Packer Operations Manual is available from GTA website and provides new and existing storage operators a reference document to assist in the handling of grain through a container packing grain storage facility. 2.4 Chemical Use 2.4.1 Regulations Industry is committed to complying with relevant Australian and International chemical regulations. The grain industry provides a product that is considered safe for human and animal consumption. A whole-of-chain approach applies to food safety and chemical residue management and the provision of grain according to customer requirements through a combination of: • Australian State, Territory and Federal Government legislation; and • Industry quality assurance systems and general practices. 9 9 https://graintrade.org.au/storage-and-handling/
At all times, the grain industry must comply with all regulatory controls for chemicals. The key elements of the regulatory system in Australia and overseas are: Australia • Chemicals are registered for both in-crop and post-harvest use on grain. In Australia there are two Government bodies (Australian Pesticides and Veterinary Medicines Authority (APVMA)10 and Food Standards Australia New Zealand (FSANZ)11 responsible for registration of chemicals and for determining MRLs of chemicals. The Australian MRLs and the registration and use of chemicals, are binding in all Australian States and Territories; • Australia is a full signatory to the Codex Alimentarius Commission12, an international body created by the World Health Organisation and the Food and Agriculture Organization to develop, amongst other things, international MRLs ; • The Australian Government Department of Agriculture, Fisheries and Forestry (DAFF) regulates exports under the Export Control Act 202013 or any subsequent legislation. Plant Exports Branch14 is part of DAFF and is responsible for this task. Plant Exports Branch interfaces with the grain industry through various means such as the Grain and Plant Products Export Industry Consultative Committee15 (GPPEICC); and • The Australian National Residue Survey (NRS)16 gathers information on chemical residues and environmental contaminants in the products of participating industries such as grain. Samples are taken from a range of domestic grain products, container exports and all bulk exports of prescribed grains and assessed for levels of a range of chemical compounds. Where MRL violations are detected, the NRS initiates a trace-back system to determine the cause. That trace-back system is done by the relevant regulatory authority in each State and Territory as required by legislation. As required by legislation, NRS reports on those violations. Industry participating in the NRS Program must assist in those trace-back investigations. Under this Code, the following industry sectors are required to actively participate on a continuous basis in the NRS grains residue monitoring program, and to comply with any NRS directions applying to that program: - All grain organisations out-turning on the domestic market to an end-processor (who is not defined as a primary producer); - All bulk grain exporters; - All container exporters; and - Where relevant, operators of facilities who provide grain as part of the above services. 10 10 https://www.legislation.gov.au/F2023L01350/latest/versions 11 https://www.legislation.gov.au/F2015L00468/latest/versions 12 https://www.fao.org/fao-who-codexalimentarius/home/en/ 13 https://www.legislation.gov.au/C2020A00012/latest/versions 14 https://www.agriculture.gov.au/biosecurity-trade/export/controlled-goods/plants-plant-products 15 https://www.agriculture.gov.au/biosecurity-trade/policy/partnerships/consultative-committees/gppeicc 16 https://www.agriculture.gov.au/agriculture-land/farm-food-drought/food/nrs
Export • Each importing country operates its own legislation in relation to chemical residues permitted on imported grain. Industry uses the information available to: • Understand those requirements prior to supply of grain; • Implement measures to meet those requirements; and • Implement corrective action practices when residues on grain are identified that do not meet importing country MRLs. As required by legislation industry will not trade (i.e., supply) in grain on the domestic or export market that contains a chemical in violation of relevant legislation. Industry will have a documented procedure to manage non-conformances. Where an MRL is found to be in violation of domestic or export regulations: • Where required by legislation, it is to be reported to authorities and the cause investigated as relevant. • Industry will take action to review the cause: - If a minor exceedance is found, appropriate communication and advocacy will be conducted. - If any intentional misuse of a chemical is identified, it is to be reported to the relevant authority. 2.4.2 Industry Practices Industry implements a range of quality assurance systems and practices relating to the safety and compliance of Australian grain with market and regulatory requirements, including insect control and chemical residues of in-crop and postharvest chemicals. These measures: • Promote the safety of Australian grain in general to show compliance with changing customer requirements and regulations. • Highlight that industry only uses chemicals as required; • Incorporate measures outlined in the On-Farm Stewardship Guide; • Incorporate the principles of Integrated Pest Management; • Incorporate rotating the use of chemicals and judiciously using chemicals to manage insect, weed or pest resistance, to assist in ensuring chemicals are available in the long term; • Include compliance with FSANZ “National Code of Practice for Chemicals of Security Concern”17; • Include a range of sampling and testing procedures to determine the chemical residue status of grain; • Include compliance with any regulatory or customer Quality Assurance systems; • As a back-up to industry sampling and testing programs, include participation in the NRS program, including any industry agreed practices in relation to that program; • Apply across the Australian grain supply chain from on-farm production to export in bulk vessels, containers or bags and trade to the domestic market; 11 17 https://www.nationalsecurity.gov.au/protect-your-business/chemical-security/national-code-of-practice
• Ensure that industry does not knowingly trade in grain that contains residues in excess of regulatory or market requirements; and • Are updated based on a range of factors such as changes in regulations, variable agronomic practices and environmental conditions or the pest status of stored grain. 2.4.3 Chemical Application At all times, chemicals are applied: • To comply with label directions for those chemicals; • To comply with MRLs for those chemicals; and • By appropriately qualified personnel. Prior to, during and following harvest, chemicals such as structural, equipment hygiene and stored grain treatments are applied: • At rates based on a range of factors including end-use of that grain; • To maintain and prolong the life of those chemicals; • To comply with MRLs for each applicable market; • To minimise the cross-contamination of grain subsequently handled through any infrastructure; • To comply with the Strategy to Manage Resistance to Grain Protection Chemicals in the Australian Grain Industry to prolong the life of fumigants such as phosphine and other stored grain protectants18; and • Abiding on outcomes recommendations and activities of the National Working Party on Grain Protection (NWPGP) as determined and published following each year's annual conference19. Industry adopts a nil tolerance for live stored grain insects on outturn of grain to the domestic or export market. Storages are actively monitored for the presence of live stored grain insects and industry strives for grain in storage to be free of live stored grain insects. Fumigations are monitored to ensure recommended concentrations are achieved and to meet regulatory requirements. 2.5 Grain Quality Management Industry activities are conducted safely, to meet expectations of workers, customers, regulators, the community and all industry stakeholders. All involved in the supply chain are responsible for providing traceability of grain as it moves through the supply chain. This is based on the principle that any entity in the supply chain has the capability to trace grain one step forward and one step backward. Documentation is used for various reasons including to undertake investigations of non-conformance. All legal requirements for the operation of facilities (e.g., Export Registered Establishment for bulk and container premises under the Export Control Act 2020 or subsequent legislation) are complied with. 2.5.1 Commodity Vendor Declaration Preference is for a standard-form CVD to be used across industry where possible. It is recognised CVDs may be developed by individual industry participants. 12 18 https://graintrade.org.au/nwpgp/post-harvest-chemicals/ 19 https://graintrade.org.au/nwpgp/
CVD forms: • Are routinely used in the grain supply chain on receipt of grain from a producer or during the transfer of ownership within the trade; • Must include details of: - Variety - Chemical residue status - GM status of the grain; • May include details of the quality status of the grain; • Contain information that is used by the buyer or handler of the grain to confirm the status of the grain and to verify the grain meets regulations and/or market requirements; • Are only to be provided where information documented can be supported by records or other suitable means; • May only be completed by approved persons; and • Are actively transferred by industry along the supply chain following a change in ownership and movement of grain. 2.5.2 Quality Checks Grain quality checks: • Are carried out from the time grain is harvested and received into storage up to the time: - It is placed on a shipping belt for loading onto a bulk vessel for export; - It is loaded into a container for export; - It is delivered to a domestic enduser; and • Involve assessment of a range of representative samples taken along the supply chain as outlined in 2.5.3 -2.5.6 to ensure customer and regulatory requirements will be met on outturn of that grain for various grain quality parameters. Samples and certification documentation may accompany each grain parcel as it moves through the supply chain. These may be provided by each participant in the supply chain or by independent third parties. 2.5.3 Grain Receival & Segregation (i) Receival Industry preference is for the use of common industry Standards and procedures to sample, test, classify and grade grain. On receival of grain, all commercial storage providers: • Apply industry approved sampling and testing procedures, with any field test methods being equivalent to reference methods where applicable; • Document operational procedures associated with sampling, testing and classification of grain and, where applicable, make these publicly available; • Take representative samples for assessment of grain against Standards; • Classify grain according to industry or end-buyer Standards20; • Conduct assessment and classification of grain at the point of receival, recognising the practical difficulties of this process in certain situations; • Assess individual truckloads or rail wagons or on a composite basis as applicable of all grain tendered for delivery according to those Standards; 13 20 https://graintrade.org.au/grain-trading-standards/
• Where feasible, use reference methods for grain assessment; • When determining grain weight, determine that weight on a Registered Weighbridge or other approved weighing device. • Document and make known to industry where variations to industry Standards occur; • Use reference material where applicable (e.g., GTA Visual Recognition Standards Guide21); • Make available at each receival site a documented dispute and rejection procedure for each load tendered for delivery. Preference is for the use of a procedure applying common industry principles22; • Obtain a declaration from the deliverer of the grain on a range of parameters, including where applicable commercial contract/price issues, variety, GM composition, chemical use and QA status of the grain; • Take various samples for further analysis of grain quality or verification of the declaration at receival based on the risk assessment procedure of the storage provider. At a minimum grade running samples are collected where relevant to operations; and • Maintain relevant records of each delivery. (ii) Segregation Segregations are created according to market requirements and/or based on compliance with the industry Standard for that commodity and grade. Documentation of each delivery is checked prior to unloading to ensure the integrity of the grain held in storage will be maintained. Where relevant, grain of differing varietal grade classification is not blended unless: • The outcome of the resultant grain quality is known; and • Appropriate approval has been obtained from the owner of the grain. 2.5.4 Grain Quality Management during Storage During the storage period: • Segregations and grain integrity are maintained to meet market requirements; • Regular sampling and grain inspection occur, and these processes are documented; • Hygiene of the grain is maintained; • Insect and pest control programs are implemented to assist in maintaining the hygiene of the stored grain and meet marketing requirements on outturn; • Following grain movement, grain spillages are cleaned on a regular basis; and • Relevant records are maintained for all storages and when grain is moved within the storage facility. These records may include: - Commodity - Grade - Quality - Chemical treatments 14 21 https://graintrade.org.au/fact-sheets/ 22 https://graintrade.org.au/technical-guidelines-documents/
2.5.5 Grain Outturn - Domestic All handling and transport equipment is inspected prior to moving grain to ensure: • It is of an adequate standard; and • It will not compromise the integrity or quality of the grain to be moved. Prior to and during outturn: • Quality requirements of the customer are known, and stock is selected based on meeting those requirements; • Representative samples are taken, and grain is physically inspected to ensure its quality has been maintained whilst in storage; . • Representative samples obtained are retained for a suitable period. A documented sampling, testing and sample retention procedure ensures staff are aware of requirements; • As required, representative samples are taken according to requirements of the National Residue Survey; • Transport units loaded with grain are to comply with relevant weight limits and other transport regulatory requirements; • Where grain weight is assessed, it is determined on a Registered Weighbridge or other approved weighing device; and • Suitable documentation (e.g., CVD) is supplied with the outturned grain to identify its quality and integrity. 2.5.6 Grain Outturn - Export Grain may be exported in bags, containers or bulk. Documented procedures apply to each type of export operation. All export premises, grain handling equipment, pathways and processes must meet any regulatory requirements, including those stipulated by DAFF. Documented procedures are to be maintained at the export premises relating to a range of procedures including but not limited to storage and grain pathway hygiene, grain sampling, grain testing and sample retention. Grain sampling, testing and records as appropriate are used to confirm appropriate stock is selected and loaded and it will meet customer and regulatory requirements. Grain loading may commence: • Once the empty vessel (e.g., bulk vessel, container or bag) is deemed fit to load,as per the DAFF Guideline23, the Australian Maritime Safety Authority requirements for domestic commercial vessel inspections24, and any other relevant regulations and requirements; • If grain pathways and the empty vessel have been inspected and it is determined they do not to contain any material that may adversely impact on the quality and quarantine status of the grain to be loaded; and • Once the quality of grain accumulated is known. No grain is to be loaded unless the quality is known. 15 23 https://www.agriculture.gov.au/sites/default/files/sitecollectiondocuments/biosecurity/export/plants-plantproducts/plant-exportsmanual/guideline-empty-bulk-vessels-export.pdf and https://www.agriculture.gov.au/sites/ default/files/documents/guideline-inspectionempty-containers-for-plant-exports.pdf 24 https://www.amsa.gov.au/vessels-operators/domestic-commercial-vessels/domestic-commercial-vessel-inspections
During loading: • Grain is inspected as per DAFF requirements25; • Representative samples are taken as per documented procedures at the required rate of 2.25 litres per 33.33 tonnes; • Grain as sampled is tested for quality and its' quarantine status; • Analytical results obtained using approved objective testing technology for quality parameters take precedence over results obtained by subjective assessment methods; • Independent inspection companies are used where contractually required to independently verify the status of grain loaded: - Representative samples of the cargo may be taken directly by independent inspection companies; or - Representative samples of the cargo are provided to the independent inspection company; • As required, representative samples are taken according to requirements of the National Residue Survey; • Where certification is produced, this certification is based on: - The representative sample being taken during loading and composited following loading; - Assessment of the grain to verify the certification statement; and - Any legal requirements such as those required by DAFF. • Samples obtained during loading may be further assessed or retained as required. 2.6 Transport Efficient grain movement and logistics is a focus of industry. All participants in the supply chain have a primary duty of care under Chain of Responsibility legislation to ensure the safety of road transport operations, including managing the risks of speed, fatigue, mass dimension and loading - so far as reasonably practicable. For every grain movement, all participants shall: • Maintain the quality and integrity of the grain; • Actively seek to prevent unintentional contamination of the load; and • Transport grain to their designated destination, safely and within the relevant laws. This is achieved through compliance with the Grain Transport Code of Practice jointly developed by GTA and industry or other approved Transport Codes of Practice. Adoption of a Grain Transport Code of Practice is a commitment to operate safely and efficiently, whether industry participants are a commodity trader, local storage operator, a transport company, grain processor, packing facility, export terminal or operate in other areas of the supply chain. 16 25 https://www.agriculture.gov.au/sites/default/files/documents/inspection-prescribed-grain-and-plant-products-forexport.pdf
2.6.1 Regulations All supply chain participants involved in the transport of grain comply with: • Regulations relating to all activities associated with transport vehicles such as; - Vehicle cleaning and cleanliness; - Work Health & Safety requirements; - Loading and unloading; - Consigning; - Scheduling; - Driving; - Vehicle mass; - Driver fatigue management; and - Vehicle roadworthiness. • Primary duties under Chain of Responsibility legislation; • Relevant Biosecurity requirements; and • Relevant industry Codes, including any approved Transport Code of Practice. All staff involved in the grain transport process are to have the relevant licences, permits and be appropriately trained. 2.6.2 Processes All supply chain participants: • Must demonstrate compliance with Chain of Responsibility legislation by: - Having established and determined the business' Transport Activities; - Conducting a risk assessment to identify risks within those Transport Activities; - Completion of a process to establish what steps are reasonably practicable for the business to comply with Chain of Responsibility parameters (such as preventing mass breaches, ensuring drivers do not speed); - Development and ongoing review of supporting Policy and Procedures; - Implementation of active training; and - Development of a means to record activity and to audit processes and procedures for compliance. • Must achieve the minimum standards of grain hygiene for road transport units and loading/unloading equipment as relevant by: - Having suitably documented systems, procedures, and conduct training for all staff and contractors to meet the grain industry requirements for the transport of grain as documented in those procedures; - Being able to demonstrate adherence to the relevant Transport Code of Practice through records and audits, and must provide those records on request; - Using dedicated transport units where possible where there is a risk of contamination of subsequent loads; - When required, sampling grain during loading or unloading to minimise the risk of loading or discharge of inappropriate quality grain; - Ensuring grain is loaded and unloaded in a safe manner; and - Where available, ensuring grain is loaded into transport units within legal weight limits using a Registered Weighbridge. Where a weighbridge is not available the methods as described in the GTA or other Transport Code of Practice are to be adhered to. Where non-compliance with transport obligations has been detected: • Actions must be taken to remedy the situation as soon as possible; 17
• Industry actively investigates issues to implement measures where feasible to prevent re-occurrences; and • Where legally required, such incidents must be reported to the relevant authority. All transport units (e.g., rail wagons, road trucks, containers): • Are to be inspected and cleaned to an agreed industry standard prior to loading26; • Are to be of suitable condition to maintain the integrity and quality of the product to be loaded (e.g., able to be enclosed); • Are to be suitably dry and free of contaminants to preserve the quality of the grain to be loaded (e.g., free of fertiliser residues)27; • Must comply with any industry or regulatory “prior load” requirements; • Must be accompanied by relevant documentation and not be loaded unless the required documentation is provided; • Are not to contain chemical residues that may impact on the integrity of the grain to be loaded or violate market or regulatory requirements; • Must only be loaded with a quantity of grain that meets legal weight limits; • Are not to be used to fumigate grain while in-transit or be used to outload grain that has been treated with a grain contact insecticide unless legally permitted to do so; and • Are to be cleaned in a suitable biosecurity area following discharge. 2.7 Marketing 2.7.1 Understanding Market Requirements All involved in the grain supply chain, including producers, storage providers and marketers are to be aware of the relevant domestic and international regulations and quality requirements where applicable. Depending on the parameter, information is obtained from a range of sources including: • On various overseas market Government websites; • From the DAFF Micor website28. • In marketing contracts; and • From commercial service providers. i) For chemicals, this includes MRLs applying to grain. Information is obtained from a range of sources including: • The Australian Grain Industry Post Harvest Chemical Usage Recommendations and Outturn Tolerances publication29; • On the NRS30 and GTA website; ii) For grain quality, this includes a range of physical quality parameters related to the grain. iii) For grain biosecurity, this relates to pests and diseases, food safety parameters such as chemicals, heavy metals, mycotoxins, radiation and any quarantine pre-shipment treatments. 18 26 TGD No.10 Truck Cleaning = https://graintrade.org.au/technical-guidelines-documents/ 27 TGD No.18 Truck Cleaning Procedures Treated Fertiliser = https://graintrade.org.au/technical-guidelines-documents/ 28 https://micor.agriculture.gov.au/Pages/default.aspx 29 https://graintrade.org.au/nwpgp/post-harvest-chemicals/ 30 https://www.agriculture.gov.au/agriculture-land/farm-food-drought/food/nrs/databases
2.7.2 Marketing Australian Grain When marketing Australian grain, industry: • Aims to proactively identify, engage in and maintain access to domestic and international markets; • Strives to adopt common Standards, procedures, documentation and data management processes to assist those aims. This includes adoption of various recognised QA systems, standards and processes where available and relevant; • Provides structured training programs to increase the awareness, and capability of industry participants to better support marketing goals; • Supports the use of documented contractual terms to facilitate aspects of the grain trade outlined within this Code, including where appropriate the use of the Commercial Resources developed by GTA covering grain sales contracts, storage and freight agreements and grain Standards; and • Implements appropriate procedures for the management of their operations and in particular grain quality to: - Underpin the product standard; - To comply with quarantine requirements as relevant; - To produce and manage grain according to food safety regulations and principles; - To comply with safety requirements for those personnel operating along the supply chain and those individuals who may come into contact with the grain supply chain; and - To comply with all regulatory, industry and customer safety requirements, underpinning the industry strategy of safely managing their operations. • Industry participants do so with the intention of promoting and maintaining the reputation of Australian grain, the supply chain and all participants that deliver the products to the domestic and international markets; • Where applicable, the relevant grain Standard and description as applied by industry will be used. This includes where relevant any varietal classification rules as outlined in the Varietal Master List and use of any applicable trademark relevant to that Standard; • Preference is for the use of industry approved contracts and published grade Standards; • All grain traded is to be supplied with appropriate documentation; • Buyers communicate relevant grain Standards and specifications to their suppliers in clear, meaningful and accurate terms; • GTA grade Standards (e.g., referring to CS number) will only be used where the final grain out-turned meets all specifications of that Standard such as physical quality parameters, relevant Varietal Master Lists and varietal purity, and all rules associated with those grades are complied with, including: - Applicable dates for implementation of new seasons' Standards; - Re-classification of old seasons' grain; and - Blending of old and new seasons' grain. 19
• Where samples or analytical results are required to be provided as per contract terms, the marketer or supplier of the grain arranges those samples to be taken so as to be representative of the consignment and assessed as per industry sampling and testing protocols; • Certification is only to be supplied based on appropriate information; and • Provision of analytical results is only to be supplied based on: - Appropriate sampling and testing; and/or - As outlined in the relevant contract; and/or - According to national or international standards. For grain destined for the domestic market, the grain meets all relevant Australian regulations such as: • The FSANZ Food Standards Code; • APVMA MRLs; • Where supplied for stockfeed use, all State and Territory stock food regulations. For grain exported, the grain at all times complies with: • Requirements outlined in the Export Control Act and associated legislation, including the collection of representative samples of the consignment; • Quarantine requirements of the importing country; and • Relevant international standards such as: - Codex Alimentarius Commission - Importing country MRLs for chemicals, Maximum Levels (MLs) for other contaminants such as heavy metals/mycotoxins and other relevant contaminant restrictions; - The Cartagena Protocol on Biosafety31. Grain is only out-turned: • When known to be in compliance with market requirements. • When treated with a chemical, following compliance with the legislated label directions such as With-holding and Ventilation Periods; • When in compliance with customer and/or regulatory MRLs that apply to that grain; and/or • Where applicable, following analysis of grain to confirm the status of the grain (i.e., chemical residue levels are in compliance with customer and/or regulatory MRLs). Where grain is known to contain a chemical that is in violation of a regulatory or customer market requirement, industry will not supply that grain to that market unless the following measures are undertaken to ensure the grain upon reaching the destination market will comply with the relevant MRL: • A mitigation strategy is implemented; and/or • The supplier receives written agreement from the customer of the grain, provided regulatory requirements are always met. 20 31 https://bch.cbd.int/protocol
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