73 



I think we have been able to improve things somewhat for our 

 farmer constituents, and your input was just a critical part of mak- 

 ing that happen. 



Mr. Johnson. I think Mr. Pomeroy's point on the critical useful- 

 ness of your organizations is well taken. We will recess the sub- 

 committee now once again, conclude this panel, and we will take 

 up the final panel immediately after a vote on defense authoriza- 

 tion across the street and conclude this hearing at that time. 

 Thank you, again, to the members of this panel. 



[Recess taken.] 



Mr. POMEROY [assuming chair]. We can begin hearing the pre- 

 pared testimony, which in light of the hour, I would encourage you 

 to summarize. Please begin, Mr. Keith. 



STATEMENT OF KENDELL KEITH, PRESIDENT, NATIONAL 

 GRAIN AND FEED ASSOCIATION, ACCOMPANIED BY RAN- 

 DALL C. GORDON, VICE PRESIDENT, COMMUNICATIONS AND 

 GOVERNMENT RELATIONS, AND THOMAS C. O'CONNOR, DI- 

 RECTOR, TECHNICAL SERVICES 



Mr. Keith. Mr. Chairman, we do appreciate the opportunity to 

 testify on this issue. 



I am Kendell Keith, president of the National Grain and Feed 

 Association. Accompanying me are Randy Gordon, our vice presi- 

 dent of communications and government relations, and Tom O'Con- 

 nor, our director of technical services. 



Our organization is a nonprofit trade association of more than 

 1,000 grain, feed, and processing firms. Approximately 70 percent 

 of our members are country elevators, both private and coopera- 

 tives. Our membership is committed to ensuring a safe food supply. 

 In fact, our mission statement says that we are committed to en- 

 suring a wholesome, high-quality and abundant food supply for do- 

 mestic and world consumers. 



Let me first talk about aflatoxin and how it affects food safety. 

 The Food and Drug Administration has provided clear regulatory 

 guidance concerning the handling and merchandizing of grain con- 

 taining aflatoxin to provide a safe feed outlet for afiected corn. But 

 beyond just regulations, there are powerful economic incentives for 

 elevators to do what they can to avoid handling corn containing 

 aflatoxin. Elevators that take delivery and commingle com contain- 

 ing aflatoxin at levels exceeding legal limits do risk having the con- 

 tents of their entire elevator seized and condemned. Because of 

 user requirements, grain company contracts typically contain 

 clauses that require grain to be sold compatible with FDA regula- 

 tions. That is, the grain must be merchantable. Indeed, we have a 

 sample grain contract that our association publishes that we would 

 like to submit for the record that contains such a merchantability 

 clause. 



When our industry suspects an aflatoxin problem, our association 

 becomes very active in providing information to our members re- 

 garding the regulatory and statutory obligations concerning 

 aflatoxin. We do monitor research and new grain-handling tech- 

 niques and we maintain a close and ongoing dialog with processors 

 concerning aflatoxin. We have also been very active within the 



