The National Grain and Feed Association is recommending that USDA not develop standards for biofuel products — such as distiller's dried grains or DDGs — because existing government and industry frameworks for such products are working.
In a statement submitted to USDA's Grain Inspection, Packers and Stockyards Administration, the NGFA said existing procedures for approving feed ingredients, and the NGFA's own Grain Trade Rules, Feed Trade Rules and Arbitration System, already provide parameters for trading distillers grains and other biofuel products.
“We believe the existing government and industry frameworks are working well and provide for the effective trading of these products and do not believe that additional involvement by GIPSA is necessary to further enhance the marketing of grain inputs used for ethanol production or the resulting distillers grains products,” the NGFA wrote.
“The NGFA believes additional government standards for these inputs could have the negative impacts of stifling the rewards of innovation, reducing the number and quality of products available in the marketplace and ultimately limiting the opportunities for either buyer or seller to capture optimal value for these products.”
NGFA Biofuels Committee Chairman Michael F. Malecha, ethanol manager for NGR Development Co. Inc., a biofuels company headquartered in Minneapolis, signed the letter, which was written in response to a USDA-GIPSA request for comments.
“The opportunity for both buyers and sellers to differentiate products and capture appropriate value is essential in maintaining a market system that fosters the creation of new technologies and products that ultimately benefit all parties affiliated with the inputs and outputs of ethanol production,” said Malecha.
GIPSA is considering whether to develop standards for distillers dried grains with solubles and standardized testing methods for ethanol product quality factors.
The NGFA cited the ingredient definition approval process administered by the Association of American Feed Control Officials, which recently was formalized through a memorandum of understanding with the Food and Drug Administration as an example of how the current regulations are working.
“This time-tested AAFCO process includes an assessment by FDA of the safety and effectiveness of each feed ingredient for its intended purpose, and a review of the chemistry involved in manufacturing the product,” the NGFA said.
In addition, the NGFA noted that AAFCO's existing categorization of distillers grains products and other approved feed ingredients provide “meaningful and recognized terms that contribute to the effective trading of such products.”
AAFCO first adopted official feed ingredient definitions for distillers dried solubles, distillers dried grains and distillers dried grains with solubles in 1964 and subsequently has added new and updated definitions.
The NGFA also noted that state feed laws establish appropriate nutrient labeling requirements for distillers grain products, which typically include required analysis to determine the moisture, protein, fat, fiber, calcium, phosphorus and other nutrient components of such products.
Likewise, the NGFA said, “GIPSA's current official grain standards adequately facilitate the trading of raw grain inputs used in biofuels production.”
The NGFA, which represents 900 grain, feed, processing, exporting and other grain-related companies, also took issue with GIPSA's assertion that the industry lacks agreement on reference methods for analyzing the quality attributes of biofuels products, and said there is not a need for the agency to develop standardized reference methods of analysis.
As justification, the NGFA cited an industry coalition study completed by South Dakota State University in February 2007 that provided recommended guidelines for proximate analysis of moisture, crude protein, crude fat and crude fiber of distillers dried grains with solubles — the most widely-traded form of distillers grain products.
In addition, the NGFA cited the National Corn-to-Ethanol Research Center's current efforts to develop standard equations for using near-infrared spectroscopy calibration to measure nutrient factors in distillers' grain products. “We also believe it is important to allow buyers and sellers of distillers grain products the opportunity to mutually agree contractually to the specific type of analytical method that applies to given transactions,” the NGFA said.
The NGFA did encourage GIPSA to continue administering its current program that validates and issues certificates of performance for commercially available rapid test kits used to determine various grain quality attributes, including those of distillers' grains.
But in response to a question posed by GIPSA, the NGFA said it would be inappropriate for the agency to initiate the development of secondary tests for specific traits in grains, such as fermentable starch content, arguing that is a role typically and properly served by commercial companies that introduce such traits to the market.
“We believe it is outside the scope of GIPSA's mission to independently pursue the development of other types of secondary or rapid methods for use with the inputs of ethanol production or distillers grain products,” the NGFA said.
“We believe commercial companies are best positioned to develop secondary or rapid methods in response to market demand. But if such methods are developed, we believe GIPSA has a role in validating the methods through its current evaluation program.”