U.S.D.A APHIS Part 340 Comments

On Monday, June 19 NAEGA joined the Corn Refiners Association (CRA), the National Grain and Feed Association (NGFA), the National Oilseed Processors Association (NOPA), and the North American Millers Association (NAMA) in comments to the U.S. Animal and Plant Health Inspection Service (APHIS) regarding proposed revisions to regulations under 7 CFR Part 340 (“Part 340”) applicable to the importation, interstate movement and environmental release of certain genetically engineered organisms.

The comments urge APHIS to withdraw the proposed Part 340 rule given insufficient interaction and consultation by the U.S. Government with the governments of major U.S. export markets. Instead, the U.S. Government should develop a comprehensive engagement strategy with regulatory agencies in other countries to build international regulatory compatibility and acceptance around a new, more science- and risk-based approach that ensures genetically engineered plants do not pose a plant pest or noxious weed risk. APHIS should also engage and consult adequately with relevant U.S. state governmental bodies concerning its proposed new regulatory approach to avert situations in which individual states may attempt – in the absence of APHIS regulatory oversight – to exercise their own regulatory control over field trials or commercial cultivation of plant-breeding innovation techniques.

Until such time as APHIS achieves broad-based acceptance through such international and domestic engagement of its new regulatory approach, the agency should not move forward with the proposed rule. Moving forward would endanger the marketability of U.S. agriculture products in global markets.

A copy of the comments can be found here.

U.S. FDA Genome Editing Techniques Comments

On Monday, June 19 NAEGA joined the Corn Refiners Association (CRA), the National Grain and Feed Association (NGFA), the National Oilseed Processors Association (NOPA), and the North American Millers Association (NAMA) in comments to the Food and Drug Administration (FDA) regarding the use of genome-editing techniques to produce new plant varieties intended for use in human and/or animal foods.

The comments urge the FDA to require premarket notification of the agency by plant breeders and others intending to develop and commercialize plant gene-editing techniques – regardless of the technique used. In addition, any future determinations regarding the level of safety consultation and risk assessment for a given biotech-enhanced trait should be based upon the characteristics of the resulting product, rather than on the technique used to develop the plant. Premarket notification should not necessarily trigger a full-fledged FDA safety review or risk assessment.

The comments also stressed the need for enhanced consultations with safety regulatory agencies in other countries, particularly main export markets. Such consultations improve the marketability of U.S. crops and help prevent trade disruptions due to the asynchronicity of domestic regulations.

A copy of the comments can be found here. 

USDA FAS 2018 UES Application

On Monday, June 19 NAEGA officially submitted its 2017 Unified Export Strategy (UES) to the USDA’s Foreign Agricultural Service (FAS). The UES sets the framework under which NAEGA will administer its Market Access Program funding in the 2018 program year. The 2018 UES highlights many past successes and planned initiatives NAEGA intends to engage in over the next year, including efforts to promote the electronic exchange of commercial and official trade documents and efforts to address market access barriers during negotiations of the North American Free Trade Agreement (NAFTA).

A copy of the 2018 UES can be seen here. For more information, please contact Ryan.

U.S. Coast Guard ASP Workshop

On Wednesday, June 14 NAEGA Director of Operations Ryan Olson attended the biannual U.S. Coast Guard (USCG) Alternative Security Program Workshop. NAEGA, along with the National Grain and Feed Association, administers an Alternative Security Program (ASP) on behalf of the USCG. The ASP is available for all NAEGA and NGFA member facilities that are interested in an alternative way to comply with the Maritime Transportation Security Act (MTSA). During Wednesday’s workshop, ASP participants were briefed by Rear Admiral Paul Thomas, Assistant Commandant for Prevention Policy as well as USCG staff and officers on compliance related issues, trends and new security initiatives.

Please contact Ryan if you would like more information on the Workshop or our interested in participating in the NAEGA-NGFA ASP.

Kenya IGTC Working Visit

IGTC Secretariat Katy Lee is back from Nairobi, Kenya where she held her fourth working visit of the year with Nairobi based IGTC member the East African Grains Council (EAGC). In Nairobi, Katy sought to deepen the IGTC’s relationships with key regional players in the supply and trade of grains, oilseeds and other agri-bulks. During her stay, Katy presented at the EAGC’s Annual Members and Stakeholders Luncheon, attended a leadership seminar with 12 members of EAGC staff regarding best practices for the management and success of international grain trade associations, briefed the EAGC, the UN Food and Agriculture Organization, and Kenyan government officials on IGTC policy files, and visited three EAGC members.

A copy of Katy’s trip report is available here.