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U.N.'s Codex Alimentarius Commission concerning levels of 

 aflatoxin in international trade. 



Fundamentally to manage risks of aflatoxin when we suspect it 

 is present as an industry, producers and country elevators begin 

 working early to identify the extent of the problem while the corn 

 is still on the stalk. There is widespread sampling that generally 

 occurs and educational meetings are held on how to manage the 

 crop and try to minimize the damage. Furthermore, once aflatoxin 

 is known to be present in an area, the entire marketing chain 

 takes additional stringent quality-control measures to prevent con- 

 taminated grain from entering the market channels, and to direct 

 such com to FDA-approved uses. Export elevators, too, have insti- 

 tuted quality-control measures to screen inbound corn, and vir- 

 tually every processor in the United States is vigilant in inspecting 

 inbound com where aflatoxin is suspected. 



These stringent contamination prevention measures implemented 

 by domestic processors and export elevators, coupled with the in- 

 creasingly common quality control requirements from grain ele- 

 vators, are part of a multilayered system of safeguards that pre- 

 serve the safety of the food supply in the United States and those 

 grains that are exported that may contain aflatoxin. 



The regulatory framework governing aflatoxin, of course, has 

 been in place for many years, and is well understood. But in con- 

 trast, similar certainty did not exist until recently with FDA's cur- 

 rent regulatory stance on vomitoxin. It is, as stated earlier, a 

 noncarcinogenic toxin, but it was not until FDA issued its new ad- 

 visory levels on September 16, of this year, that our industry was 

 certain as to whether the 1982 advisory levels would become more 

 or less stringent, or whether the advisory levels would become ac- 

 tion levels. 



The distinction between action levels like those set for aflatoxin 

 and advisory levels like those that have been set for vomitoxin are 

 very important to our industry. Action levels denote specific levels 

 of contamination at which the agency is prepared to take regu- 

 latory action. With the handling of a noncarcinogenic mycotoxin 

 like vomitoxin, the grain handling industry must balance several 

 considerations. These include, first, the quality needs of end users; 

 second, FDA's regulatory policy; and third, the elevator managers' 

 desire to provide a fair, competitive market for the farmer cus- 

 tomers. 



Our members report that the magnitude of storage and market 

 risk associated with the 1993 wheat crop was particularly acute. 

 These uncertainties led many elevator managers to advise their 

 farmers to hold on to their 1993 crop until the situation became 

 clearer. But some farmers, either by choice or out of necessity, did 

 deliver new crop wheat for sale during this period of uncertainty, 

 and the price was discounted because of the presence of vomitoxin. 



The major market factors that led to the risk management strat- 

 egy of our industry included the extent to which the crop contained 

 vomitoxin — it was largely unknown until we got into the harvest 

 season; second, how extensive the damage level was it likely to be; 

 third, there were low quantities of high-quality stocks coming into 

 this crop year; fourth, there was concern over the market demand 

 for weather-damaged wheat; fifth, there was uncertainty surround- 



