Monthly Archives: June 2015

By: Derrell S. Peel, Oklahoma State University Extension Livestock Marketing Specialist

May 2015 was not only the wettest May on record but was the wettest month ever in Oklahoma. The statewide average was nearly 15 inches of rain in May with numerous locations receiving over 20 inches and a few areas with over two feet of rain. This far exceeds the previous record for the statewide average of about 10.5 inches in May. The resulting floods continue and are causing losses for people and creating management headaches for agricultural producers. Summer crop planting and hay harvest are delayed and the winter wheat crop, nearing harvest, is now threatened by wet conditions after suffering from drought impacts through most of the growing season. Fences have been washed out and some cattle are scattered while others had to be relocated to higher ground. Stored hay has been ruined by flood waters or washed away in some cases.

The tremendous amount of precipitation in May has all but eliminated drought conditions in Oklahoma. The drought that began in the fall of 2010 has remained a specter over Oklahoma agriculture for over four and a half years until this last month. During that time, even when periodic relief came and marginally improved conditions allowed for forage and crop production, the threat of regressing back into drought was a constant factor in producer decision making and a limit to production plans. Agricultural producers have been continuously on the defensive through the long drought.

By recharging soil moisture and replenishing surface water supplies, the record rainfall in May has effectively reset all drought indicators to zero. It may turn hot and dry this summer and we may be concerned about drought conditions later in the year or for next year, but it will be a new drought rather than a continuation of the previous drought. Starting from this point, any new drought conditions that might emerge will take time to reach critical levels and provide producers an opportunity to plan and prepare. Until or unless that happens, producers can be back on the offensive, focusing on what they would like to do, as opposed to what they have been forced to do so much of the time for the past four years.

One of many questions that accompany this change in conditions is how this might impact herd rebuilding. In general, I don’t expect this to change the trajectory of herd rebuilding already underway in 2015. Oklahoma started 2015 with a 25 percent year over year increase in beef replacement heifers, indicating relatively aggressive herd expansion. Perhaps the biggest impact is that it removes the risk that some producers were facing by gambling on relatively aggressive expansion plans this year. Improved forage conditions ensure that robust herd expansion in 2015, already planned, will occur. Better 2015 conditions may, however, set the stage for a more aggressive expansion in 2016 than would have otherwise occurred. This could push […]

Group wants implementation to take risk-based approach

Release Date: 2015-05-29

The National Grain and Feed Association (NGFA) on March 26 submitted comments to the Food and Drug Administration (FDA) regarding Food Safety Modernization Act (FSMA) implementation.

According to the comments, NGFA’s membership “recognizes the paradigm shift FSMA represents in terms of placing the principal focus on prevention of hazards that can pose a risk to human or animal health. The law also codifies a fundamental principle that the grain, feed and grain processing industry has long held — that the industry bears the principal responsibility for producing and distributing safe products.

“That is a responsibility our industry embraces and takes very seriously,” said NGFA.

As such, the association seeks to ensure FSMA implementation takes a risk-based approach with a clear understanding — from regulators and industry — about what is involved under new FSMA-related rules. In its comments, the association focused on:

A common understanding of responsibilities and obligations must be developed: For regulatory officials and industry to have a clear and common understanding of responsibilities and obligations under the new FSMA-related rules, FDA will need to issue multiple guidance documents for various industry sectors in a timely manner after final rules are issued.

According to its statement, NGFA urges “FDA to work closely with the regulated industry while developing such documents so that content reflects the realities of industry practices, aligns with regulatory requirements and serves to further enhance the safety of human food, animal feed and pet food.”

Investigators must undergo comprehensive training: While FDA has signaled that it intends to develop metrics to measure the industry’s compliance with FSMA requirements, the NGFA also believes that the agency must establish clear metrics to accurately measure its investigators’ understanding and application of the regulations.

“Consistent and reasonable inspectional activities will play an essential role in establishing the constructive relationship between regulators and industry that is necessary to advance food and feed safety,” according to NGFA’s statement.

FDA should use an “educate before regulate” approach: NGFA strongly supports FDA’s stated FSMA-compliance philosophy of “educate before it regulates.” However, NGFA urges FDA to provide adequate time for industry to fully understand and comply with the new and far-reaching FSMA requirements.

FDA should use a risk-based approach when setting inspection priorities: NGFA believes that FDA should rely upon currently collected and publicly available information and data when determining whether a facility or its products should be subject to more frequent inspections as mandated under FSMA.

According to its comments, NGFA strongly believes that “FDA’s inspectional resources should be focused on facilities that have a higher risk of affecting human and animal health.”

FDA should continue to use state regulatory officials for inspections: The NGFA strongly supports FDA’s continued use of state feed regulatory officials to conduct FDA-credentialed inspections of animal feed and pet food facilities.

NGFA said, state regulatory officials who are familiar with and knowledgeable about animal feed and pet food facilities and the types of products manufactured and distributed can […]