Handling Flood Damaged Grain Crops

Recently, many acres of grain crops were inundated by floodwaters in Pennsylvania. This has generated concern about the potential for these crops for food or feed, since floodwaters can contain sewage, heavy metals, or other contaminants and can also predispose these crops to molds and the development of toxins. Since this has been an unusual event, there is little local precedent for dealing with this issue.

We have pursued this question with officials at the Pennsylvania Department of Agriculture for guidance on the marketing and disposition of these crops. Based on their research, some of the following guidelines for handling these crops have recently been developed.

Food and feed crops that are exposed to moisture damage are regulated by the Food and Drug Administration (FDA) to ensure the safety of our food supply. In the past, flooded grain terminals or grain terminals that have had fires extinguished with river or seawater have been subject to these regulations. FDA considers floodwater to be inherently unsanitary and deems grain that has been in contact with floodwater to be unfit for human consumption or animal feed, unless reconditioned.

Grain crops that have been exposed to flood waters may be considered adulterated. FDA will consider specific written proposals to recondition floodwater-damaged grain intended for use in animal feed and human food. Since corn and soybeans may be marketed in Pennsylvania for either food or animal use, grains exposed to flood waters should not be marketed through conventional grain marketing channels until reviewed by FDA. (Manual of Compliance Policy Guides = http://www.fda.gov/ICECI/ComplianceManuals/CompliancePolicyGuidanceManual/default.htm.) This procedure indicates that requests for approval for feed use should be made to the FDA District Office. The District office will transmit the requests to the Division of Compliance, Center for Veterinary Medicine for evaluation. The main contact person with FDA in our region for questions on this issue has been identified as Michael O’Meara (302) 573-6447 ext. 102.

Grain crops that have been exposed to flood waters should be marketed for feed, only after being reviewed by the FDA district office, using the guidelines in the above regulations. In the short term, this will involve keeping this grain separate from non-adulterated grain and pursuing testing and approval procedures from FDA on the stored crop before marketing. Specific testing procedures will be identified by FDA, but could include bacteria, mycotoxins, heavy metals, or pesticides. Blending of adulterated grain with other grain is specifically prohibited. Adulterated grains marketed in commercial distribution are regulated by FDA and the Pennsylvania Department of Agriculture. Adulterated grains in commerce may be subject to regulatory action that could include withdrawal from distribution, seizure or civil penalties.

Grain crops raised and intended to be fed on that farm are not subject to these regulations because the grains are not in commercial distribution.

However, it is recommended to segregate flood affected grain from other grain and do an evaluation before feeding, by conducting the appropriate tests based on the flood water exposure of the grains to contaminants, including chemical, microbiological and microbial toxins. When sampling grain for any analysis, it is crucial that a representative sample of the grain is obtained. If you need assistance assessing the potential of contaminants from floodwaters, consider contacting the local Department of Environmental Protection Office.

There is no way to completely understand the risk associated with feeding these crops.

It may be small, but there is still a risk that some crops have been exposed to unknown contaminants or may have developed mycotoxins associated with the molds that developed on the crops. Feeding adulterated grains could lead to unwanted residues in eggs, meat or milk that could have additional regulatory consequences. The ideal situation would be to not harvest crops that have come in contact with floodwaters, but this may not be feasible. With careful testing and management, it may be possible to minimize the risks and potential liability associated with the feeding and utilization of these crops.

For more information, contact John Breitsman at the Pennsylvania
Department of Agriculture. Phone: 717-772-5215.

Greg Roth, Department of Crop and Soil Sciences