Nick Goddard
CEO
Pulse Australia
Via email: ua.moc.suaeslup@kcin, Cc: ua.moc.suaeslup@nimda
Re: Pulse Standards Review 2020/21 - Round 1
Dear Nick,
GrainGrowers is a leading voice for Australian grain farmers, representing their interests at a national and international level. Our vision is a more efficient, sustainable and profitable grains industry for all Australian grain farmers. Working with the grains sector and broader agricultural community, GrainGrowers aims to set a progressive agenda to drive positive change for Australian grain farmers across the national and global landscape.
GrainGrowers welcomes the opportunity to provide a first-round submission to Pulse Australia regarding the pulse standards review 2020/211. We have not commented on each individual section specified in the Call for Submissions, rather only those we had specific comments or concerns.
Agreed Changes for Adoption in the 2020/21 Season
GrainGrowers supports the agreed changes for adoption in the 2020/21 season, including the implementation of standards as follows.
3.1 Updated government and industry links – all pulse commodities
GrainGrowers supports this agreed change to ensure the currency of information provided via html links on government and industry sites available for industry reference regarding standards, including maximum residue limits (MRLs) and phytosanitary requirements.
3.2. Visual recognitions standards guide (VRSG) – all pulse commodities in VRSG
GrainGrowers supports this agreed change to improve clarity of imaging and definitions, and to rectify the standards issues as agreed.
3.3 Varietal lists – all commodities
GrainGrowers supports this agreed change to ensure the industry website remains current and accurately reflects all varieties, by commodity, as listed in the corresponding standards.
3.4 Defective grain sub-categories and tolerances – faba beans, green lentils, red lentils
GrainGrowers supports this agreed change to achieve consistency in the approach to defective (all other defects) across Australian Pulse Standards for No.1 Domestic, No. 2 Domestic and No.1 Export standards.
Industry Feedback
GrainGrowers provides feedback regarding items for future review as follows.
4.4 Nil tolerance parameters – all pulses
GrainGrowers supports the review of Grain Trade Australia standard definition of ‘Nil’ (tolerance), the applicability of Nil tolerance quality parameters in bulk grain loads, and the assessment of regulatory impacts as a result of any change from nil tolerances. We believe this should be reviewed and consulted with the committee early to ensure timely agreement between stakeholders and incorporation with national standards.
4.5 Truck Sampling – all pulses
GrainGrowers has previously raised heightened concerns regarding grain sampling discrepancies across seasons from 2016/17 to 2019/20 seasons. In particular, there is reported to be significant discrepancy in pulse samples collected by (primarily manual) vacuum sampling probes.
GrainGrowers’ previous submission regarding manual vacuum sampling can be found here: https://www.graingrowers.com.au/graingrowers-submission-regarding-the-gta-technical-guideline-document-on-sampling/
GrainGrowers supports the Pulse Australia’s proposal for further investigation and research to improve sampling processes across Australia. However, we note that any such research should be:
- Conducted by suitably qualified and independent experts
- Cost effective
- Targeted to achieve outcomes
As per previous guidance, we encourage the Pulse Standards Committee and GTA Standards Committee provide a thorough and comprehensive review of the current GTA Technical Guidelines Document on Sampling (TGD No.5). This review must aim to strengthen the TGD document and minimise sampling errors caused by (1) inconsistent design of different vacuum sampling probes; and (2) inconsistent use of sampling probes by different operators. In our opinion, the expertise of the persons/organisations in the GTA Standards Committee, combined with the broader GTA membership, should allow the current TGD to be improved without the need to undertake research/expenditure.
Furthermore, GrainGrowers recognises that the committee are yet to receive a response from GRDC regarding the research proposal, as requested by GTA in May 2019. It is imperative Pulse Australia and the Pulse Standards Committee engage GRDC, GTA and industry stakeholders to drive changes to sampling methodology to achieve positive outcomes for the sector that will otherwise be subject to extended processes of unnecessary formal engagement, from research proposal to publishing, extension and adoption.
If you require further information regarding this submission, please contact Lucy
Darragh, Policy Officer, at ua.moc.sreworgniarg@hgarrad.ycul or (02) 9286 2000.
Sincerely,
Lucy Darragh
Policy Officer, Grain Growers Limited
- Pulse Australia – First Call Industry Submissions (2020/21 Standards)