snipe
Member
- Location
- west yorkshire
think this shows 2 things
1) they will make it as hard as possible (which we already know)
2) they are concerned about competition law
AIC discusses gatekeeper for Uk grain
- Thread starter snipe
- Start date
think this shows 2 things
1) they will make it as hard as possible (which we already know)
2) they are concerned about competition law
SilliamWhale
Member
They're crooks
- Location
- Yorks
This isn't for feed grains. It's bizarre really, it's for non-feed grains.
It comes from the EFISC-GTP document covering their trade assurance scheme which is the scheme of choice of many shippers/merchants exporting to the UK.
It means these imports can be classed as assured and then get mutual recognition by TASCC when the UK merchant picks it up from the docks and delivers to our mills.
The table and first footnote under the table explain how ex-farm grain can skip the expensive Gatekeeper lab tests. All that needs to happen is that the destination mill needs to have a sampling spear and then choose to do their own lab testa on it, which could be moisture, bushel, protein, hagberg, bugs, foreign objects and maybe mycotoxins
- Location
- Yorks
Yes, they'll make it as hard as possible because they want t make sure it never happens.
think this shows 2 things
1) they will make it as hard as possible (which we already know)
2) they are concerned about competition law
imho they'll ask for individual farms to do expensive lab tests on each crop, wheat, barley, OSR, etc.
I don't think they'll want to allow us to blend samples from 60 neighbouring farms and send in one sample. But they should do, because that's what happens on a boat.
In practical terms our grain is already grown to our legislative standards, so we could argue we don't need half of those expensive lab tests.
We've also got the EFISC-GTP scheme, and theoretically we could use that for UK grain.
We've also got fact that if we're not RT assured we're much more likely to get local authority inspections which cover similar things to a RT inspection. So do we really need Gatekeeper lab tests?
Imports are not farm assured full stop. So our competent authority checks trump imports by a country mile. We don't need Gatekeeper do we, and we don't need RT.
- Location
- Yorks
Page 25 to 28 of this document
- Location
- Yorks
... and afaik they're one of the half dozen cooperative members of SQC.
think this shows 2 things
1) they will make it as hard as possible (which we already know)
2) they are concerned about competition law
Without the current rules as they are, SQC could lose a lot of paying farmer members.
Just saying.
- Location
- Yorks
and the grain merchant members of AIC might need to segregate grains if AIC allowed anything other than RT/SQC. However, they already seem to manage with having the two standards of SQC and Red Tractor.
Bramble
Member
What a load of rubbish that report is.
think this shows 2 things
1) they will make it as hard as possible (which we already know)
2) they are concerned about competition law
Tries to make out RT is a ‘cheap’ cost as it is only £500/year audit cost plus £100 sprayer testing cost. What about all the other costs associated with complying with RT, either in time or direct actual costs?? Probably a few thousand ££s per year for most farms.
’Market confusion with introduction of new assurance scheme’ and ‘Gatekeeper approach may not be universally accepted by end consumers’ are given as disadvantages in letting U.K. farmers use Gatekeeper. End users are already buying Gatekeeper grain!!!!!
SilliamWhale
Member
And try getting some traceability data from your feed merchant!
- Location
- north lincs
And why would UK farmers be responsible for paying for the lab tests? Do they go to Canadian/Australian/Brazilian farmers and ask them to stump up the cost of lab tests to export to the UK? I can imagine their response. The merchants pay for them, so why do farmers here have to cover that cost?
On farm stores are inspected by local authorities so that's another cost lie.
You would think they would know this, it's only their whole job to know this stuff.
On farm stores are inspected by local authorities so that's another cost lie.
You would think they would know this, it's only their whole job to know this stuff.
ok so do I have this correct, to quote it again.
* with the exception of direct farmers supply and unprocessed raw material (like oilseeds and grains) which do not required to be certified when are subject to further industrial processing (except compound feed) as they will be covered by the plant entry check program. So, no gate-keeper procedure required.
if they can record a chain of ownership to a non certified farm, for as it says oilseeds and grains, they can use the entry check program,
which in turn is run on.
chapter 6
HACCP stands for Hazard Analysis and Critical Control Points and is a "tool" that helps an operator to identify safety hazards and quantify the risk associated with their products and processes. The system then enables the operator to document, control and verify the effect of measures to control these safety hazards. The production of safe feed/food ingredients requires that the HACCP system is built upon a solid foundation of prerequisite programs. Prerequisite programs provide the basic environmental and operating conditions that are necessary for the production of safe feed/food ingredients. While prerequisite programs may impact upon the safety of a feed/food ingredient, they also are concerned with ensuring that feeds/foods are wholesome and suitable for consumption. HACCP system are narrower in scope, being limited to ensuring feed/food is safe to consume. The nature of the PRP will vary between individual operators but the general principles will apply across the European feed/food ingredient industry
so, in theory no testing needs doing if the risk assessments are done and they show, low risk?
and this is for non certified crops from farms in any country, and we require RT to get the same standing?
I may have it wrong but, from this paper trail it looks like risk assessments are all they use to basically turn non certified farm crops into assured crops coming off boats.
they don't even have to comply to gatekeeper rules. just the 'entry check program' that mostly uses risk assessments.
please explain it to me, if I have it wrong?
- Location
- Yorks
You're correct, afaik it's not the overseas farmer who pays for the lab tests. It's the merchant.
The work AHDB have commissioned looking into imported grain standards.... I've specifically asked them to find out who is paying for the lab tests.
As far as I understand it, you have it correct. They don't need to bother with Gatekeeper lab tests for imports to be considered "assured". AIC/TASCC then have mutual recognition of EFISC-GTP, so that grain is now considered assured by the UK grain trade.
that's actually good for us, in trying to break the AIC demands for RT or gatekeeper then?
we can make a case for a risk assessment scheme, that has either no farm level assurance just uk compliance to uk law, with a once every 3 years council checks, or a very cut back RT basics scheme that's basically the same as the council checks? with a system of basic risk assessments doing the rest.
and we make the case to the AIC to recognize it as an equivalent to the EFISC-GTP scheme that does the same.
- Location
- Yorks
It's version 4.0. Seems to be a version 4.1 imminent. Will it be the same?
I think it's unlikely they will make any changes, that will inflict cost onto the trade end of the rules.
requiring gatekeeper rather than using the 'entry check program' would add considerable costs, and if the AIC moved their goal posts to force gatekeeper as a minimum, then someone in the trade side has to pay the costs of testing and do all that extra paper work for the same basic result.
as gatekeeper actually requires every load to be sampled and tested, before shipping, and lots of extra steps for non-certified suppliers which we know on imports are often the majority of farm suppliers.
the AIC allowed the 'entry check program', because it cuts import costs and is very simple to work their assurance magic on.
if the AIC move to not take imports via the 'entry check program' then that's a win anyway, in a rebalancing of the system, it blocks simple assurance of crop that used to make it too the uk.
My take away is, the AIC has had a system in place that did allow non certified feed food crops to be imported, as assured under 'entry check program' rules. this included 'feed/food, processed and unprocessed*' when direct from farmers could be shown.
so, unless they move to change that, they cannot refuse an equivalent scheme so, uk farmers can do the same. so, buyers can just require risk assessment statements from farmers so they can take, quote'
'feed/food, processed and unprocessed*' of oilseeds and grains. from farm to processors
if direct from farmers supply, into the assured system. which we are.
I think it's a good place to start as it already includes feed and food direct from farms.
if we lose that loophole then it will cost them to close it.
Is AIC actually BRC for dyslexic or misinformed people?... everyone yabbering on about Greed Tractor and AHDB being the enemy, I see AIC being very aligned with BRC and rather bad for our existence, much more so than NFU et al, RT, AHDB.... there's a good move forward in protecting farming and a lot has been against those who have taken the wrong side ie NFU... but they are not the enemy of farming, they just f**ked up. The greatest predator to our existence is the Great British Retailers, a consortium of them... call them BRC. That's the target, its the lifeline of retailers and the death of us, we don't need answers from NFU, AHDB etc, they don't need killing, they need pulling out of the ditch to help get us back on top. BRC need f**king off to the moon
think this shows 2 things
1) they will make it as hard as possible (which we already know)
2) they are concerned about competition law
They noted that a new assurance scheme maybe a better solution, they all ready know gatekeeper is expensive, hence why they have get a rounds for it.
think this shows 2 things
1) they will make it as hard as possible (which we already know)
2) they are concerned about competition law
and yes they do see liability in competition law. As they should, they buy non certified, oils seeds and cereals from other schemes running that has no testing or gatekeeper and it’s classed as assured.
While require farm assurance from us, this is exactly what they are worried about.
Maybe a tribunal needs to be looked at?
Ok an extract from that pdf.
Example: Farmer Co-op in France • Only grain from members goes into stores • Co-op responsible for all drying and storage • Usually supplies seed, agrochemicals • Local knowledge of weather, mycotoxin risks etc.
The above seems simple. The difference is central stores, but is it, all it says is they only take it from members, so why cannot mills have members where as they once did they do a basic inspection of a farm and the farm becomes a member.
From that point the farm can sell to that mill with not other checks?
- Location
- Yorks
I've asked AHDB to specifically find out what happens with the French co-op system. It looks like grain coming from these co-ops is classed as "assured" and co-op sees to any grain quality testing, but up to co-op how they do this.
^^^ this model could work in UK. It could be a virtual co-op of say all cereal farms in a locality. They employ contractor to check facilities and grain, grain can then be sold by individual farmer on open market as assured.
Is it as simple as . Quote the AIC pdf.
Example: Farmer Co-op in France • Only grain from members goes into stores • Co-op responsible for all drying and storage • Usually supplies seed, agrochemicals • Local knowledge of weather, mycotoxin risks etc.
We start a members scheme, put some basic risk assessments in place, a council inspection, or RT member in the last 3 years with no storage non conformance’s.
And mills can buy from them like a farmer co-op in France. As members they are assured under there membership.
I think buying groups for chemicals could help with this, as they are linking the source of agrochemicals to the groups. So, a farmer in a buying group, that can demonstrate where they get chemical from, so farmers can create member groups, for selling crop.
This is not run inside the buying group, it’s just that if requested the buying group can verify where the farm gets its chemicals.
Or.
We ask all buying groups if they will assure there chemicals all meet uk standards, so any member of any buying group in the scheme, has that covered, then we have a risk assessment scheme based on council checks, or similar, and we form a large membership group, or Co-op from that with basic assurance.
The question is, if we did would the AIC be forced to recognise it?
If they say the Local knowledge of weather, mycotoxin risks etc. is missing, can we not, find a way to do this in this modern age with an app, based on rainfall recordings. And could we not argue that our agronomists already cover this aspect.
So a farm in a buying group and uses an agronomist, is in after a simple farm inspection and annual risk assessments?
Example: Farmer Co-op in France • Only grain from members goes into stores • Co-op responsible for all drying and storage • Usually supplies seed, agrochemicals • Local knowledge of weather, mycotoxin risks etc.
We start a members scheme, put some basic risk assessments in place, a council inspection, or RT member in the last 3 years with no storage non conformance’s.
And mills can buy from them like a farmer co-op in France. As members they are assured under there membership.
I think buying groups for chemicals could help with this, as they are linking the source of agrochemicals to the groups. So, a farmer in a buying group, that can demonstrate where they get chemical from, so farmers can create member groups, for selling crop.
This is not run inside the buying group, it’s just that if requested the buying group can verify where the farm gets its chemicals.
Or.
We ask all buying groups if they will assure there chemicals all meet uk standards, so any member of any buying group in the scheme, has that covered, then we have a risk assessment scheme based on council checks, or similar, and we form a large membership group, or Co-op from that with basic assurance.
The question is, if we did would the AIC be forced to recognise it?
If they say the Local knowledge of weather, mycotoxin risks etc. is missing, can we not, find a way to do this in this modern age with an app, based on rainfall recordings. And could we not argue that our agronomists already cover this aspect.
So a farm in a buying group and uses an agronomist, is in after a simple farm inspection and annual risk assessments?
Ok, yes we know but the AIC control most of the mills in the uk, so are a big target, yes your correct the BRC are also if not more of a problem, but the AIC is one of there fronts. And it sets policy for all there mills. Read up about them, they are very big and control a lot.
as for the NFU and AHDB, they were on auto pilot, and until, they had a kicking they could see no reason to come off it.
Now they have, they have to prove they have listened and are making changes.
They get no free pass, only swift actions will do.
We lit a fire under them, I see no reason to put it out, they have to get themselves safe.
They do that by being part of the solution, if not they get what they get.