As in Dave Hartman response from PDA.
Due to tropical storms and an overabundance of rain many acres of grain and other crops were inundated by floodwaters across Pennsylvania. This has generated concern about the potential use of flood-affected crops for food or animal feed, since floodwaters can contain sewage, heavy metals, or other contaminants and can also predispose these crops to molds and the development of toxins. Since this has been an unusual event, there is little local precedent for dealing with this issue.
We have worked with federal agricultural agencies for guidance on the testing, handling and disposition of these crops. Based on their research and recent communications with United States Food and Drug Administration (FDA) officials on this issue, we are now able to offer some guidance regarding the testing, handling and disposition of these crops.
The Center for Food Safety and Applied Nutrition at FDA has assessed the potential use of these crops for food uses and concluded that there is no practical way to recondition these crops for use for human food. They recommend that the flood-affected crops be segregated and or otherwise disposed of to ensure they do not contaminate unaffected crops during harvesting, storage and distribution. Adulterated grain and other crops may be subject to seizure under the Federal Food, Drug, and Cosmetic Act. Based on this determination by FDA, grains, which have been harvested from flooded crops, should not be handled, used or marketed in manner that could allow them to potentially be mixed with grains intended for human consumption. Example: Soybeans intended for human food processing, such as soybean oil, should not be commingled with flood affected soybeans.
The Center for Veterinary Medicine at FDA has also assessed the potential use of these crops as animal feed. FDA has indicated that as harvested these crops would not be acceptable for use in animal feed. Producers must be aware that by choosing to harvest and use flood water adulterated crops as animal feed they will assume the liabilities associated with the potential problems of this feed.
To even be considered for use in animal feed, these crops should be cleaned and dried or heat-treated. The grain must be tested for the following criteria, at a minimum:
- Mycotoxins to include at least aflatoxin, fumonisin, vomitoxin, zearalenone, and ochratoxin.
- Heavy metals, with emphasis on cadmium, mercury and lead.
- Presence of certain pathogenic bacteria and their toxins, especially Salmonella, E. coli 0157:H7, E. coli 0104:H4 and Clostridium perfringens and botulinum. Heat treatment must be done for a duration and at temperatures sufficient to destroy these pathogenic organisms.
- Pesticide screen, with particular emphasis on organophosphate and chlorinated hydrocarbon pesticides.
- Presence of PCBs (polychlorinated biphenyls) consistent with the levels found in Title 21 Code of Federal Regulations, Part 500.45.
It is important to note that if further information becomes available concerning other environmental or industrial contaminants in a specific locale, additional testing may be necessary.
Maximum acceptable levels for the contaminants listed above are summarized in the tables, paragraphs and referenced documents below:
20-300 ppb: See link below- species specific
5-100 ppm: See link below – species specific
1-10 ppm: See table below – species specific
No established limit *** See note below
No established limit *** See note below
E. coli 0157:H7
E. coli 0104:H4
See link below
See link below
Action Level (Parts Per Billion)
Corn and peanut products intended for finishing (i.e., feedlot) beef cattle
Cottonseed meal intended for beef, cattle, swine, or poultry (regardless of age or breeding status)
Corn and peanut products intended for finishing swine > /= 100 lbs
Corn and peanut products intended for breeding beef cattle, breeding swine, or mature poultry
Corn, peanut products, and other animal feeds and feed ingredients but excluding cottonseed meal, intended for immature animals
Corn, peanut products, cottonseed meal, and other animal feed ingredients intended for dairy animals, for animal species or uses not specified above, or when the intended use is not known
0.5 (aflatoxin M1)
Peanuts and Peanut products
Corn and corn by-products intended for:
Total Fumonisins (FB1+FB2+FB3)
Equids and rabbits
Swine and catfish
Breeding ruminants, breeding poultry and breeding mink*
Ruminants > 3 months old being raised for slaughter and mink being raised for pelt production
Poultry being raised for slaughter
All other species or classes of livestock and pet animals
*Includes lactating dairy cattle and hens laying eggs for human consumption
Vomitoxin – (DON)
Class of Animal
Feed Ingredients &
DON Levels in Grains & Grain By-products and (Finished Feed)
**Ruminating beef and feedlot cattle older than 4 months
Grain and grain by-products not to exceed 50% of the diet
**10ppm (10ppm in beef) (5ppm in dairy)
Grain and grain by-products not to exceed 50% of the diet
Grain and grain by-products not to exceed 20% of the diet
All other animals
Grain and grain by-products not to exceed 40% of the diet
Finished wheat products
Infested grains testing 10 ppm or less for DON may be used in animal feed according to the advisory based on the species, portion of the diet and level of DON. FDA does not recommend the use of grain with levels of DON that exceed 10 ppm in animal feed.
**FDA has updated the advisory levels of DON in distiller's grains, brewer's grains, gluten and gluten meal. Ruminating beef cattle and dairy cattle over 4 months of age- 30ppm not to exceed 50% of the diet and not to exceed 10ppm in beef cattle finished feed and not to exceed 5ppm in dairy cattle finished feed.
Ochratoxin A and Zearalenone – "No regulatory standards have been initiated for these toxins and results from exposure data and/or risk assessments have indicated that regulatory standards are not warranted at this time. The FDA continuously follows development of newer data regarding these mycotoxins, thereby constantly evaluating the need to set regulatory standards." (from the Council for Agricultural Science and Technology Task Force Report No. 139 January 2003) Other countries have established maximum levels for Ochratoxin A and Zearalenone in foodstuffs, dairy products and animal feedstuffs in the parts per billion (ppb) range dependent on commodity and intended use.
Pesticides – The following referenced documents and websites establish pesticide and regulatory compliance standards.
- FDA Compliance Policy Guide Sec. 575.100 Pesticide Residues in Food and Feed – Enforcement Criteria (CPG 7141.01)
- EPA 40CFR Part 180 Tolerances and Exemptions for Tolerances for Pesticide Chemicals in Food - http://www.access.gpo.gov/nara/cfr/waisidx_04/40cfr180_04.html
Polychlorinated Biphenyls (PCBs) – The temporary tolerances for residues of
PCB's are as follows:
0.2 part per million in finished animal feed for food-producing animals (except the following finished animal feeds: feed concentrates, feed supplements, and feed premixes).
2 parts per million in animal feed components of animal origin, including fishmeal and other by-products of marine origin and in finished animal feed concentrates, supplements, and premixes intended for food-producing animals.
10 parts per million in paper food-packaging material intended for or used with finished animal feed and any components intended for animal feeds. The tolerance shall not apply to paper food-packaging material separated from the food therein by a functional barrier which is impermeable to migration of PCB's.
Forages and silages affected by flood waters should be tested for the same contaminants as flood affected grains. Refer to the Managing Flood Damaged Forage and Pasture document for more information.
Pennsylvania's dairy and livestock community should be aware that any animal feed crop touched by flood water is considered adulterated under federal law. It is reasonably likely that a variety of contaminants are present in the silt on the plants or on the plants themselves. Adulterated silage and forage should not be used as animal feed unless the risks of its use can be appropriately managed. If flooded feed is not managed appropriately, adulterated feed places animal health at risk and poses a means for contaminants to enter the human food supply, particularly through the milk supply.
Grain crops raised for feeding on-farm are not directly subject to federal and state regulations because the grains are not in commercial distribution. However, food (eggs, meat and milk) produced from feeding these grains may be regulated. Contaminants from potentially adulterated feed, if found in milk, may impact the farm's ability to ship milk. It is recommended that all producers test these grains to ensure that the flood-affected grains are below the tolerances for the contaminants identified above. Again, it is important that producers consult with Penn State Extension to assess the handling and use of flood-affected grains and other crops.
Producers must be aware that by choosing to harvest and use adulterated crops as animal feed they will assume the liabilities associated with any problems from such feed.
Beware of products intended to be used for or promoted to bind mycotoxins and other harmful toxins. They must be the subject of an approved Food Additive Petition (FAP) from the FDA or Generally Recognized as Safe (GRAS) for use in food or feed if they are sold or intended to be used for this purpose.
Activated charcoal is not an approved food/feed additive and is not GRAS. Food or feed containing activated charcoal is considered adulterated under the Federal Food, Drug and Cosmetic Act.
Sodium aluminosilicate and hydrated sodium calcium aluminosilicate are GRAS when used as anticaking agents in animal feed at a level not exceeding 2 percent in accordance with good manufacturing or feeding practices. However, FDA's Center for Veterinary Medicine (CVM) has consistently maintained that the use of sodium aluminosilicate or hydrated sodium calcium aluminosilicate as binders for mycotoxins is not GRAS and approved FAPs must be obtained before these products may be used or claims may be made regarding their utility as mycotoxin binders. Products which are not the subject of an approved FAP may be subject to regulatory action.
CVM is concerned that all mycotoxins are not uniformly bound by anticaking agents and that similar anticaking agents do not bind mycotoxins to the same degree.
Furthermore, any mycotoxins which are bound might not remain bound when the feed is consumed and exposed to the acid environment of the gut. If this were to occur, the animal could be exposed to unknown and potentially unsafe levels of mycotoxin which could result in mycotoxin residues in meat, milk, or eggs.
The Department will offer grain testing at no charge to help producers, not covered by crop insurance, who choose to make determinations on grain quality for harvesting and feed potential and assess whether it is likely that any of the listed contaminants are present in flood affected field crops.
Grain Sampling Procedures
(These sampling guidelines are adapted from "Practical Procedures For Sampling Grain", from USDA's Grain Inspection, Packers and Stockyards Administration (GIPSA).)
It is recommended that grain sampling and shipping be completed by a PSU County Extension Agent if available. Also, your feed nutrionist may be able to offer support with the collection and shipping of the grain samples.
Sampling is an essential part of the inspection process and is critical to the accuracy of the final grade. If the sample is not representative of the lot, the inspection result will not reflect the true quality of the lot.
Basic Principles of Obtaining a GOOD sample:
• Collect several samples from different areas of the lot.
• Combine these samples to form a single sample.
• Consider the size of the sample needed for analysis.
• Completely mix or blend the final sample.
Use a container (a large coffee can will work) to sample grain from a moving stream of grain. Tailgate sampling will draw a reasonably representative sample, as grain is loaded/unloaded from a combine to a truck/wagon or from a truck/wagon to a bin.
To Obtain A GOOD Sample With A Tailgate Sampler:
• Let the grain flow from the carrier (truck, combine, bin) for a few seconds before taking your first sample. Avoid sampling the last few bushels flowing out of the container.
• Hold the sampling device so that it is at one side of the grain stream.
• Pull the tailgate sampler through the grain stream in a continuous motion.
• Empty each sample into a clean, dry container.
• Take a minimum of three samples per carrier. More samples will yield a more representative composite sample.
A hand probe is the only effective method of obtaining a representative sample from grain at rest in a truck bin or other container. There are two types of hand probes - a compartmented probe and an open-throat probe. The open-throat probe does not have compartments inside. This feature allows the sample to be poured directly from the probe into a sample container. The open-throat probe tends to draw more grain from the top portion of the lot. Results of the open-throat probe will differ from that of a sample drawn with a compartmented probe. Hand probes come in 5', 6,' 8', 10', and 12' lengths. The sample is more representative of the lot if the probe reaches the bottom of the carrier.
To Obtain A GOOD Sample With A Hand Probe:
• Determine the locations in the container to be probed. Avoid sampling in the spout stream.
• With the slots on the probe closed, insert the probe at a slight angle (10 degrees).
• With the slots facing upward, open the probe and move it up and down in two short motions to fill the compartments.
• Close the probe, withdraw it from the grain and empty the grain onto a canvass or trough that is slightly longer than the probe you are using. If you are using an open-throat probe, pour the grain from the open end of the probe directly into a clean, dry container.
While drawing the sample, observe the general condition of the grain and check for objectionable odors, insect infestation, large stones, pieces of metal or glass and any other potentially harmful conditions.
****It is imperative to draw a representative sample and get as accurate of an inspection as possible. The condition of stored grain can change depending on the conditions of the storage area and the quality factors of the stored grain. ****
The Department will offer grain testing, at no charge, to help producers, not covered by crop insurance, who choose to make determinations on grain quality for harvesting and feed potential and assess whether it is likely that any of the listed contaminants are present in flood affected field crops.
Grain samples submitted for testing must meet the following criteria:
- Grain samples should be obtained by collecting a representative 6 - 10 pound sample of the grain from a bin or truck using established procedures (see guidelines above). Grain should be cleaned and dried. Ideally, samples should represent grain lots of 10,000 bushels or less.
- Samples should be submitted to the laboratory in a paper bag, so condensation does not occur, along with the name, address, and telephone number of the grain producer. The lot of grain that was sampled should also be identified.
- Test results should be available to the producer in approximately 7-10 days from receipt of sample, dependent on the findings. Positive results in any category may require additional testing and increase the turnaround time for analytical results.
- Based on the test results, producers can then voluntarily advise the Department of their intentions regarding the use, non-use, incorporation, composting, handling, storage, or other disposition of the grain.
Samples should be submitted to the attention of: Michael Hydock, Chief; Division of Lab Section, Bureau of Food Safety, 2301 North Cameron Street, Harrisburg, PA 17110
If the above testing and sampling procedures are followed and the grain meets the criteria established, FDA will not require the submission of a diversion request as outlined in their regulations for use of these crops as animal feed. Producers should voluntarily notify the Pennsylvania Department of Agriculture of their intentions to process, test, and sell or use these crops. A PDA Voluntary Notification Form is available at the end of this document or upon request to the Pennsylvania Department of Agriculture
Producers should seek consultation with a livestock nutrionist and veterinarian on any analytical results that they receive for flood-affected crops for the proper use or disposition of the crops.
- Use a respirator approved by the National Institute for Occupational Safety and Health (NIOSH). Nuisance dust masks (paper masks) are not effective against smaller particles such as mold spores and fumes. Approved respirators are recommended to anyone that may come in direct contact with the waste material (contaminated grain or other crop material). Producers may wish to consult the following website,
http://www.agsafety.psu.edu/factsheets/E36.pdf for more respiratory protection information.
- Waste material (contaminated grain or other crop material) must be packaged in a bladder bag, supersac or equivalent packaging technology which can completely enclose the material for acceptance at intended disposal facility/location.
- Transport vehicles transporting the enclosed waste material should also be covered (tarped) to prevent air dispersal of waste material (contaminated grain or other crop material).
- For landfill disposal, the waste material (contaminated grain or other crop material) should be covered immediately after deposition at the landfill working face.
- For disposal at a waste-to-energy facility, the waste material (contaminated grain or other crop material) should be fed directly into the burning chamber and not placed into the waste pit.
1. For Flood affected grains and other crops
Physical mixing of flood affected grain with uncontaminated grain for animal feed is not an acceptable practice. Blending of "clean" grain with adulterated grain is generally not permitted and the final product resulting from blending is unlawful, regardless of the level of the contaminant.
2. On-farm disposal:
Pre harvest crops can be rotary mowed and incorporated into soil. Composting on farm or through a commercial composter is an option.
3. Biofuels production:
The contaminated grain or other crop material may be used in biofuels production provided it meets the quality specifications of the production facility and the facility is permitted under General Permit WMGR109 http://www.depweb.state.pa.us/landrecwaste/lib/landrecwaste/residual_waste/gp/wmgr109.pdf, other DEP permit authorization, or under a co-product determination. In addition, the contamination levels of the distiller's grain must be evaluated before it is allowed to be used as animal feed.
4. Boiler fuel:
The waste material (contaminated grain or other crop material, etc.) may be used as fuel (co-product for energy recovery under Chapter 287.1 of the residual waste regulations) http://www.pacode.com/secure/data/025/chapter287/s287.1.html in an industrial boiler provided permit approval is granted by the DEP's Air Quality Program and the waste material has at least 5,000 BTUs/lb.
5. Waste-to-energy facility:
The waste material (contaminated grain or other crop material, etc.) may be processed at a waste-to-energy facility as a residual waste (agricultural waste) if accomplished in accordance with these procedures, the waste-to-energy facility operator has received "Form U - Request to Process or Dispose of Residual Waste" approval, and the waste-to-energy facility operator has determined the waste material will not adversely effect the facility operations and has received Air Quality Program approval. No chemical analysis is required in accordance with the Chemical Analysis Waiver provisions under Section D4. of the Form U provided the chemical analysis waiver does not conflict with the waste-to-energy facility's approved waste acceptance plan, see http://www.elibrary.dep.state.pa.us/dsweb/View/Collection-9584. In addition, the waste material should be fed directly into the burning chamber and not placed into the waste pit.
6. Landfill Disposal:
It has been determined that the waste material (contaminated grain or other crop material, etc.) may be disposed in Pennsylvania landfills as a residual waste (agricultural waste) if accomplished in accordance with these procedures and if the landfill operator has received "Form U - Request to Process or Dispose of Residual Waste" approval. No chemical analysis is required in accordance with the Chemical Analysis Waiver provisions under Section D4. of the Form U provided the chemical analysis waiver does not conflict with the landfill's approved waste acceptance plan, see http://www.elibrary.dep.state.pa.us/dsweb/View/Collection-9584. However, the landfill operator must still determine that the waste material will not adversely affect the landfill operations, liner and/or leachate collection and treatment capabilities.
DEP Regional Offices
- The following DEP regional offices may be contacted for information on permitting, Form U approval requests, and other disposal options listed above:
I. Bucks, Chester, Delaware, Montgomery, Philadelphia.
Southeast Regional Office
2 East Main Street
Norristown, PA 19401
Phone: (484) 250 – 5960
II. Carbon, Lackawanna, Lehigh, Luzerne, Monroe, Northampton, Pike, Schuylkill, Susquehanna, Wayne, Wyoming.
Northeast Regional Office
2 Public Square
Wilkes-Barre, PA 18711-0790
Phone: (570) 826 – 2516
III. Adams, Bedford, Berks, Blair, Cumberland, Dauphin, Franklin, Fulton, Huntingdon, Juniata, Lancaster, Lebanon, Mifflin, Perry, York.
Southcentral Regional Office
909 Elmerton Avenue
Harrisburg, PA 17110-8200
Phone: (717) 705 – 4706
IV. Bradford, Cameron, Centre, Clearfield, Clinton, Columbia, Lycoming, Montour, Northumberland, Potter, Snyder, Sullivan, Tioga, Union.
Northcentral Regional Office
208 West 3rd Street – Suite 101
Williamsport, PA 17701
Phone: (570) 327 – 3653
V. Allegheny, Armstrong, Beaver, Cambria, Fayette, Greene, Indiana, Somerset, Washington, Westmoreland.
Southwest Regional Office
400 Waterfront Drive
Pittsburgh, PA 15222-4745
Phone: (412) 442 – 4000
VI. Butler, Clarion, Crawford, Elk, Erie, Forest, Jefferson, Lawrence, McKean, Mercer, Venango, Warren.
Northwest Regional Office
230 Chestnut Street
Meadville, PA 16335-3481
Phone: 814-332 – 6848
For more information pertaining to this guidance document contact Erin Bubb, Chief, Division of Agronomic and Regional Services at the Pennsylvania Department of Agriculture at 717-772-5215.
For more information pertaining to the grain sample submission contact Michael Hydock, Chief, Food Safety Lab Division at the Pennsylvania Department of Agriculture at 717-787-4315.
For more information pertaining to the management of flood affected crops visit http://extension.psu.edu/prepare/emergencyready/flood/psuresources/managing or contact Penn State Extension. http://extension.psu.edu
This document was written with guidance from Greg Roth, Ph.D, Penn State Extension, University of Vermont Extension's "Managing Flood Damaged Crops and Forage From Tropical Storm Irene", and Vermont's Agency of Agriculture, Food & Markets
This document is only intended as a guide and in no manner endorses or encourages the harvesting, feeding or other use of flood damaged crops. By choosing to harvest and use flood damaged or adulterated crops as animal feed or enter such crops into the food chain, the producer assumes all risks and liabilities associated with the problems such feed may cause. The recommended tests set forth in this document are not all inclusive. In addition, the samples received are only as good as the techniques utilized and the test results achieved may or may not be representative of the entire affected crop area. The tests and the results thereof shall not be considered as any endorsement or decision by the Department related to a product's safety, regulatory compliance or final usage. All decisions related to the final use of any products tested are at the sole discretion of the producer and should be made with consideration of all laws and regulations related to such usage and the potential health consequences to their animals and the food supply. Test results shall not, in any manner bind the Department or release or vindicate any producer from, nor in any manner act to mitigate, any penalty or action that may be imposed upon such producer for improper use of the product tested.
VOLUNTARY NOTIFICATION OF
USE OF FLOOD - AFFECTED GRAINS IN PENNSYLVANIA
Name and Address of Grower/Producer:
Telephone and Fax Numbers (include cellular phone information if available):
E-mail address (if available):
Amount and Type of Grain (bushels):
How Grain was Cleaned and Processed:
Intended Use of the Grain
Name and Address of Intended User (if available):
Contaminant Test Results of Sample(s):
- Aflatoxin –
- Fumoninsin –
- Vomitoxin –
- Zearalenone –
- Ochratoxin –
- Cadmium (Cd) -
- Lead (Pb) -
- Mercury (Hg) –
- E. coli 0157:H7 –
- E. coli 0104: H4-
- Salmonella -
- Clostridium perfringens –
- Clostridium botulinum-
- Organophosphates -
- Chlorinated Hydrocarbons –
- Aroclor 1254 -
- Aroclor 1260 –
This form should be completed and submitted to the Department of Agriculture prior to any attempt to handle flood-affected grain. The completed form may be mailed or faxed to:
Pennsylvania Department of Agriculture
Bureau of Plant Industry
2301 North Cameron St
Harrisburg, PA 17110
Attn: Erin Bubb
List of PSU Cooperative Extension Staff in Affected Flood Damaged Counties
If your county is not listed above, Penn State Cooperative Extension may not have an educator located in that county working on this type of work, but someone from a surrounding county could be contacted for assistance.
FORAGE TESTING LABORATORIES
Agri-Analysis Laboratory……… Mycotoxins
Phone: 717-656-9326 280
New Port Road
Leola, PA 17540
Lancaster Laboratories…………Heavy metals, PCBs, Pesticides
2425 New Holland Pike
Lancaster, PA 17601
Skyview Laboratory ……………Mycotoxins, Microbiology
Jennerstown, PA 15547
PADLS-New Bolton Center………….Heavy metals, PCBs, Pesticides, Mycotoxins, and Microbiology
382 West Street Road
Kennett Square, PA 19348-1692
Toxicology Phone 610-925-6244
Microbiology Phone- 610-444-5800
FORAGE TESTING LABORATORIES
IN NEARBY STATES
A & L Eastern Laboratory…………Pesticides, Heavy metals
7621 Whitepine Road
Richmond, VA 23237
Cumberland Valley Analytical Services………Mycotoxins, Heavy metals
Maugansville, MD 21767
18501 Maugans Avenue
Hagerstown, MD 21742
DHI Forage Testing Laboratory
730 Warren Road
Ithaca, NY 14850