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Mr. POMEROY. It isn't isolated. In other words, at any point in 

 the import system presently do we specifically impose a domestic 

 requirement on the testing of Canadian wheat? 



Mr. Campbell. Yes, but the way that the export programs are 

 structured right now, and wheat being totally dependent on Gov- 

 ernment programs, anybody who is importing Canadian wheat is 

 keeping that identity preserved in order to provide the certification 

 to the U.S. Government that it is not going to be exported under 

 Government programs. 



Mr. POMEROY. What is the nature of that requirement? 



Mr. Campbell. It is a statutory requirement that no no foreign 

 origin grain can be exported with our export enhancement pro- 

 gram, for example. 



Mr. POMEROY. So on your elevators, are there requirements that 

 may not be called end use certificates but have the effect of end 

 user certificates for purposes of keeping that grain isolated? 



Mr. Campbell. They are called warranties, if you are going to 

 participate in export programs. Most of the trade would be from 

 end users, and probably not through a middle person, not through 

 a grain elevator. So, again, whether you are an elevator who is pur- 

 chasing or whether you are an end user directly, you are going to 

 insist on the same quality specs, regardless of where the origin is. 



Mr. PoMEROY. Presently it is my understanding that if there is 

 an inspection requested of Canadian wheat, the elevator picks up 

 the tab for that inspection price. Do you have any position on that? 



Mr. Gordon. Who would request the inspection? 



Mr. Campbell. If the elevator is requesting it, then the elevator 

 would pay the fee. 



Mr. PoMEROY. Is that a disincentive for the elevator to have a 

 quality inspection done of Canadian wheat? 



Mr. Keith. I don't think the price in this case is a relevant con- 

 sideration, given that if he perceives a risk of a high vomitoxin 

 level, the discounts are sufficient enough incentive to have the test 

 done. 



Mr. Campbell. And the grain industry is testing everything any- 

 way. It might not be an FGIS test, but we are protecting ourselves 

 by testing everything anyway. 



Mr. PoMEROY. That gets to my next question. This has been a 

 year where we have seen, as I think you mentioned, Mr. Campbell, 

 very substantial price impacts for quality discounts assessed. Are 

 testing programs and procedures sufficiently reliable to give the 

 marketplace a great deal of confidence that that discount is appro- 

 priately placed? 



Mr. Campbell. I think it is now, but of course early on, take the 

 first couple weeks of harvest, there was a lot of confusion about the 

 tests; there was concern about repeatability. So the market really 

 had a hard time sorting things out early on. And now things have 

 become much more orderly. 

 Mr. PoMEROY. Mr. Keith. 



Mr. Keith. Well, yes, things have become more orderly. There is 

 still some concern about the accuracy of the test, but ultimately, 

 you have to live with what you have. We are always trying to en- 

 courage greater accuracy. We want tests to be repeatable, we want 

 them to be efficient. This is not the perfect test, but it is the test 



