RMA's procedures governing commodities that contain substances, such as mycotoxins, at levels that may be injurious to human or animal health as stipulated by Food and Drug Administration (FDA) regulatory policies differ from other grain-quality factors, such as determining test weight, damage or other quality factors. For these "normal" grain quality factors, RMA's procedures allow -- for federal crop insurance loss-adjustment purposes -- that quality be determined by any of the following: 1) a licensed grader working under the authority of a warehouse licensed under the U.S. Warehouse Act or a state grain licensing authority; 2) a grader working at a facility operating under USDA's Uniform Grain and Rice Storage Agreement contract; or 3) an official inspector operating under the authority of the U.S. Grain Standards Act (i.e., an official working for USDA's Federal Grain Inspection Service (FGIS) or one of its delegated or designated official agencies.)
Testing for Mycotoxins: RMA's requirements for determining mycotoxin levels for crop insurance loss-adjustment coverage are different:
- For crop production that will be stored on-farm or at a commercial facility, RMA requires that samples of commodities suspected of being contaminated with mycotoxins, other than vomitoxin, be taken by the insurance adjuster or a trained disinterested third party approved by the "approved insurance provider" (i.e., the USDA-approved crop insurance company) before the commodity is stored because of the potential for mycotoxin levels to increase during storage. If appropriate samples are not obtained prior to storage, such production will not be adjusted for mycotoxin-related quality loss by RMA. The one exception applies to on-farm storage of commodities suspected of containing vomitoxin, since the potential for vomitoxin to increase in storage is very slight. This vomitoxin exception for the 2009 crop year applies to crop insurance policies with a contract change date of Nov. 30, 2008 or later (the crop contract change date is stated in the crop provisions, and may vary by geographical area). For commercial storage, testing for all mycotoxins is required prior to storage, before the commodity is commingled.
- Importantly, if the approved insurance provider agrees in advance, the commercial grain-handling facility may obtain samples from each load (which can be combined into a composite sample representative of the producer's delivery per unit ), which, in turn, is to be sent to an approved testing facility for determining the mycotoxin content. The size of the obtained is to be in accordance with the requirements of the testing facility that will be determining the mycotoxin level present. The samples also are to be packaged and transported in a manner that conforms to the requirements of the testing facility.
- If the approved insurance provider authorizes the grain-handling facility to obtain the sample, it also can agree to allow the facility to submit the sample directly to an approved laboratory for mycotoxin testing. The samples are to be mailed or transported to the approved testing facility within four days after the sample is taken, or sooner if specified by the laboratory.
If the grain-handling facility does not submit the samples, the crop insurance adjuster or other authorized insurance provider is required within four days after the sample is collected to pick up the sample and transport it to the approved laboratory for testing.
- Testing of the samples obtained by the insurance adjuster is required to be performed by an RMA-approved testing facility or laboratory. To qualify, the laboratory is required to be able to perform quantitative tests on the grain to itemize the level of mycotoxins present (in parts per million or billion, depending upon the mycotoxin). Further, the quantitative test kits used are required to be certified by FGIS. The testing facility also is required to be a recognized commercial, government or university testing laboratory that uses industry-recognized sample sizes, equipment and procedures for testing the specific type of mycotoxin. The testing facility is required to be a disinterested third-party that's not involved in the buying or selling of the commodity being tested.
- On-Farm Storage: For commodities that are unharvested or stored on-farm, RMA has established a set scale of discounts that apply to quality losses attributable to aflatoxin, fumonisin and vomitoxin.
- Commercial Storage: For commodities that are harvested and transported to a buyer or placed into commercial storage and later sold, without first going into on-farm storage, the discount factor applied by RMA is the reduction-in-value for the commodity as determined by the elevator or other disinterested third-party buyer that accounts for all insurable quality factors, including those assessed for mycotoxin damage. The calculation takes into account the local market price paid by the buyer on the date the production is sold.
Members may click here to obtain more information from RMA's Loss Adjustment Manual Standards Handbook. The section on mycotoxins is found on pages 264-284. RMA cautions that producers should be referred to their approved insurance provider for information on RMA's policies concerning determination of mycotoxin quality-loss adjustments and the claims process.