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The Food and Drug Administration has provided clear regulatory guidance concerning 

 the handling and merchandising of grain containing aflatoxin to provide a safe feed outlet for 

 affected com. Most recently, in 1988 HDA revised its policy guidance concerning actionable 

 levels of aflatoxin applicable for that and future crop years. The agency also provided 

 procedures — limited to 1988-crop com containing aflatoxin — permitting such com to be 

 blended under FDA-prescribed conditions and supervision for subsequent use as feed for 

 approved ^lecies of beef cattle, swine and poultry. It is our understanding that FDA has 

 reinstituted its 1988 blending policy this year for certain geographical regions requesting it 

 to provide a safe feed outiet for com containing aflatoxin. 



Our members comprehend and support their regulatory obligations to protect and 

 ensure food and feed safety. Indeed, there are strong business incentives for doing so. Our 

 members are very alert to the quality demands of U.S. consumers and foreign buyers and 

 take this obligation seriously. 



There are powerfiil economic incentives for elevators to do what they can to avoid 

 handling com containing aflatoxin that caimot be directed to FDA-approved uses. Elevators 

 that take delivery and commingle com containing aflatoxin at levels exceeding legal limits 

 risk having the contents of their entire elevator seized and condemned by state and fiederal 

 authorities. Further, grain company contracts typically contain clauses that require grain sold 

 to be compatible with FDA regulations; shipments not meeting those standards are deemed 

 to be 'unmerchantable,* and are rejected by receivers at considerable expense to the shipping 

 elevator. Indeed, the sanq>le grain purchase contract developed by our own Association 

 contains such a 'merchantability* clause. I would like to submit a copy of this sample grain 

 purchase contract for the record. 



Once delivered by fiirmers, elevator managers institute grain drying, aeration and 

 conditimong procedures to minimize the possibility of mold growth in storage that could lead 

 to the further developmmt of aflatoxin. 



