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Anyone have a general list of prohibit prior commodities for grain?

previous commodity prohibited

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#1 jfox1

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Posted 10 October 2018 - 02:29 PM

Looking to see if anyone has a general list of prohibit prior commodities for grain? We have a list but it was before my time and we are getting lots of push back on it specifically because we require a washout if the previous commodity is on the list. Let me know if you guys have anything. I attached what we have now. I am new to the industry so I have a lot to learn. 

Attached Files



#2 Sabear

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Posted 10 October 2018 - 03:37 PM

Is the bulk product packaged?

I also deal with bulk seed product. From the farm, they must be cleaned. But we only use trucks that previous held other dry products hopper or open top.

After we process it (still in the raw form) trucks must be cleaned prior to arriving at the facility. They are not allowed to clean their trucks on our property, so we will reject them.

 

My only concern with washing out trucks is if they aren't completely dried before loading you'll risk the possibility of increasing your micro hazards (ie Salmonella)



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#3 Scampi

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Posted 11 October 2018 - 01:52 PM

that's an odd list..........i see unborn animal carcasses...........but no mention of just animal carcasses?  So a rendering truck without a wash could be used for grain without a wash??

 

 

If you getting push back about trucks being washed perhaps you could:

 

List the items on the list you attached and then in a second column list the reasons why

 

See what the MRL levels are for those items and match it agains the MRL for your products

 

Help management understand the reason for the list


Because we always have is never an appropriate response!


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#4 jfox1

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Posted 11 October 2018 - 02:05 PM

To Answer - the bulk material is not packaged (bulk truck or rail load out). We are getting questions and push back on some of the items like lime, stones, potatoes....I didnt create the list so I didnt know why they were on there either. 

 

No the BSE requirements seem to be what this was targeting. I think it is wise to think through these. Honestly I do not even know what each one is. I was hoping to get a general industry standard form but I dont think there is one. 

 

What is an MRL level?  



#5 Scampi

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Posted 11 October 2018 - 02:27 PM

Sorry jfox; Maximum Residue Limit.............all agricultural commodities have them. For grains it is maximum residues from pesticides/herbicides etc allowed left in the plant post harvest

 

Potatoes can grow a toxin

"Rotting potatoes give off a noxious solanine gas that can make a person unconscious if they’ve inhaled enough. There have even been cases of people dying in their root cellars due to unbeknownst rotting potatoes."

http://www.canr.msu....and_food_safety

 

 

Who published the list?  The USDA/FDA???  If so, you cannot argue it. period.


Because we always have is never an appropriate response!


#6 Parkz58

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Posted 16 October 2018 - 02:05 PM

Here's our list - we use raw grain as our sole ingredient, so we deal with this a lot.  Our list is still a work in progress, so I don't claim it to be perfect...but it's getting closer.Attached File  Bulk Carrier – Prohibited Prior Loads and Cleanout Requirements.doc   19.5KB   7 downloads



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#7 jfox1

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Posted 16 October 2018 - 02:38 PM

@Parkz58 - Thank you so much for sharing your list! I have one question for you.

 

I am being asked about Urea and having it be put in either the washout or the sweep/physical clean out section. Just wondered why yours was in the physical clean out section? I was told there is a feed grade and a fertilizer or non-feed grade urea? Not sure on this so I am hoping to get some info. I really like your list and will compare to mine. 

 

Thanks for any help with the urea question. 



#8 Parkz58

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Posted 16 October 2018 - 08:56 PM

You can probably specify between the two, and differentiate which kind of clean-out is appropriate, based upon your risk assessment.  We make sure to ask the driver to specify what type of product they carried (if it was feed/food grade, or fertilizer); if it's fertilizer, then we require a washout certificate.



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#9 jfox1

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Posted 17 October 2018 - 12:01 PM

Awesome. Thank you sir I will continue to work on this. 



#10 jfox1

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Posted 17 October 2018 - 12:56 PM

Also - Parkz do you have any studies or documentation that would help determine the risk here? We have locations that are very remote and are not within 150-200 miles of a washout so it is not very feasible for them. 

 

I want to be able to say that urea (even fertilizer) is not safe but most documentation I see is saying that it is not safe for ruminants at high levels... Just looking for justification. 



#11 Parkz58

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Posted 17 October 2018 - 01:35 PM

Hi Jfox1,

 

I don't have any specific documentation about urea - just using basic industry standards.

 

One thing that we do, if we have any doubt as to potential contamination of the load, is to have the truck driver crack open the hopper bottoms, one at a time, over a tarp or some other method of capturing what comes out, then shut them.  Generally speaking, if there was any residue left from a previous load, it would be at the very bottom of the hopper...and you would be able to see it in the hopper bottom sample.  You can then make the determination if it constitutes a level of contamination worth worrying about or not.

 

As with anything, it really does have to do with your risk assessment - you have to consider who/what the "end user" is (for example, if you are making calf starter feed, your limits may be different than if you made hog finisher feed), what the levels are that would constitute concern, how it specifically impacts the grain you are receiving (do you run it through a grain cleaner?  Sifting/sorting?  Aspiration?  Depending on the type of grain, and the type of material in the grain, you may be able to virtually eliminate any risk...or it may have no effect at all).



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