AUSTRALIAN GRAIN HARVESTERS ASSOCIATION INC.
Submission to the Gene Technology Grains Committee.
10th September 2002.
AUSTRALIAN GRAIN HARVESTERS ASSOCIATION INC
President: Brett Drysdale. "Gilgunnia". Spring Drive. Corowa. 2646. Ph. 0260333909.
Email: brett.drysdale@bigpond.com
Secretary: Rod Gribble. PO Box 555. Yenda. 2681. Ph/fax. 0269681741.
Email: rocka@dragnet.com.au
Administrator: Janice Pumpa. "Glenwood" Pleasant Hills 2658 Ph/Fax 02 60290150
Email: jpumpa@bigpond.com
Dr Fay Stenhouse
Secretary, Gene Technology Grains Committee
C/- Avcare
Locked Bag 916
Canberra. 2601.
Ph. 0262306399
Fax. 0262306355
Email: sracp@avcare.org.au
To quote the opening statement of "A strategic framework for maintaining coexistence of supply chains" - Draft discussion GTGC 31/7/2002
"The introduction of genetically modified (GM) crops will have a significant impact on Australian production systems and supply chains. With the first GM grain varieties - in the form of herbicide tolerant canola - likely to be introduced into commercial production in Australia in 2003, the grains industry must position itself to manage issues associated with the introduction of these, and future GM crops."
There has never been a truer word nor a clearer statement from all sides of the GMO debate.
This exact issue must be fully discussed & finalised to the satisfaction of all, well before any introduction of GMO crops on a commercial basis occurs in Australia.
AGHA - A BRIEF HISTORY.
The Australian Grain Harvesters Association (AGHA) was formed in 1973 by a group of contract harvesters from the central west area of NSW, who were concerned about the image and the longevity of the harvesting business. Now in 2002, AGHA has many members in every state of Australia. Our members can travel from state to state harvesting numerous varieties & types of grain crops. Over the years, a thoroughly professional commitment to contract harvesting by AGHA members has gained great credibility with not only Australian farmers but also with Australian governmental and regulatory authorities.
AGHA OBJECTIVES.
To maintain & promote the image, welfare & general interest of the association with grain harvesting in Australia & to work in co-operation with the farming & grain industry for the betterment of all.
To secure for its members the advantage of unanimity of action to consider & deal with matters affecting not purely of local concern but of common interest to all members.
GMO's - THE IMPACT ON OUR BUSINESS.
The possible introduction of GMO crops into Australia on a commercial basis, is a major concern to not only contract grain harvesters but also our clients, namely the grain growers of Australia.
As contract harvesters, many of our clients have been quite adamant that if our headers have been in any GMO crop they do not want us on their properties no matter what hygiene assurances are given whether verbal or formal.
This is a totally unacceptable restriction being placed on our business brought about entirely by GMO crops. GMO crops will absolutely prohibit contract harvesters - freedom to operate.
HARVESTING DYNAMICS & PROCEDURES.
To understand the full ramifications & implications of GMO's into the Australian grain sector, you must have an understanding of the dynamics & procedures of not only harvesting but also the trucking of that grain to delivery systems & all on-farm grain handling procedures.
Firstly, grain crops don't just happen. Successful grain crops take careful planning - at least 12 months of planning & procedure - before a seed is sown. Since RR Canola is the crop that has been earmarked for commercial release, canola will be the example used in this instance.
The vast majority of farmers (99% claimed by agronomists) use glysophate - commonly called Roundup - to initiate a fallow or for the control of weeds, or volunteer cereals for the upcoming canola crop. Depending upon the season, at least 2 applications of Roundup are applied pre-sowing. In any weed species there can be a small percentage of weeds that will be resistant to any chemical. Mechanical fallowing is often the only way to alleviate this problem, although this is no guarantee.
The crop is sown & normal agronomic practices are carried out throughout the season - weather being co-operative.
Windrowing - most often done by contractors - occurs approximately 2 weeks before harvest. Because canola is a crop that does not uniformly ripen, windrowing can incur some seed shattering. Seeds will be trapped in all sorts of crevices & spaces in the windrower as well as displaced to ground.
Harvest occurs when seed moisture is at the acceptable delivery standard - 7%. Canola is very brittle & can readily shatter when being picked up from the windrows by the header. Headers have numerous hidden spaces & crevices where seeds will be trapped. Canola has approximately 360,000 seeds per kilogram. Auger bins, field bins, field augers, farm silos & trucks are also often used to handle grain on & off the farm. All grain handling machinery has many places where grain will be trapped & may dislodge at a later date. No machinery operator or owner, taking all due care, can warrant the absolute security & integrity of the cleaning process.
Windrowers, harvesters, auger bins, tractors & trucks move from canola crop to canola crop with a sense of urgency, without delays or restrictions & with complete certainty that the canola they windrow or harvest at one farm is most likely to be going into the same grain handling system as the canola they windrow or harvest from the next farm. There is complete freedom to operate.
POST HARVEST - NON GMO's.
Harvest is over, machines are cleaned & put back in the shed, canola is trucked & delivered to receival depots, cheques are in the mail. Some weeks or months after harvest, it rains. Volunteer canola, weeds grasses etc. germinate. 99% of farmers go out & spray their paddock(s) with glysophate to control moisture robbing weeds in the previous canola crop paddock. All things being equal, complete or satisfactory weed control is achieved. The cropping cycle is nearly complete with an accepted management practice setting the farm up for another successful cropping year ahead.
HARVESTING IN A COEXISTANCE SUPPLY CHAIN.
The introduction of GMO canola into the harvesting equation, totally changes the whole operation. From one of complete confidence & freedom to operate, to another of entire insecurity & ambiguity. Add to this the very real possibility of litigation from cross contamination & you have a recipe that will restrict the businesses of contract windrowing, harvesting & grain haulage to a point of non-profitability.
Harvesters will have considerable problems & incur major expenses when moving from non-GMO crop to GMO crop & vice versa. These costs cannot & will not, be born by the harvesting industry. Harvesters will have to do a complete clean down when moving from a GM crop to a non GM crop & vice versa. A complete clean down does take between 1.5 to 2 days! That means removing all panels, covers, sieves, auger covers & troughs, pickup belts, table auger covers, skid plates, rotor & drum bar covers, concaves (in some instances), access to beaters, walkers, tyne separators, choppers, chaff spreaders, grain tank auger covers, unloading auger covers, engine bay covers & every other nook & cranny that seeds or crop residue may & most likely will be concealed. Even after all that, there is absolutely no guarantee or assurance given that the header is completely clean. Promoters of the introduction of GMO crops into Australia readily scoff at this very real scenario.
In a recent phone survey of AGHA members of their clients, the question was asked whether they (clients) would accept a header on their farm after that header had harvested GM crops & even cleaned down, even to the level of a border crossing? (QLD to NSW)
The response was a resounding & DEFINITE NO. Added comments such as… "don't ever come onto my farm again" ……. "you sign a statutory declaration so I can sue you later" emphasises the very real fact that Australian agricultural "grass roots" people don't want GMO's on their farm no matter what assurances are given. The response also emphasised the fact that GMO's will place unnecessary & restrictive conditions on the harvesting industry, ultimately making it unviable.
COSTS TO THE HARVESTING & FARMING INDUSTRY.
AGHA knows that the handling of GMO crops will add significant increases to the costs of harvesting crops. These costs will not be borne by Contractors alone, but will also be real costs to farmers with their own harvesting equipment. These costs are brought about by the constant need to clean down between GMO & non GMO crops. This entails complete clean down between paddocks on the same farms & complete clean down between farms & clients as previously outlined. Over the harvest period, considerable harvesting time will be lost in cleaning alone. AGHA has run models of this & concluded that harvesting costs could increase by as much as forty percent.
Consultation with insurance companies in regards to liability, have concluded that liability insurance will increase because they (insurance companies & underwriters) see it as an "increased risk".
Are farmers willing to pay an extra 40% for their harvesting?
Are farmers going to derive another 40% nett income from growing (in this instance) GM canola?
The answer AGHA members get back from their clients is an unqualified NO to all.
HARVESTING - THE ON FARM RISKS.
Harvest, at the best of times is a race against the weather. Timeliness of harvest & getting that crop into storage is of paramount importance to the viability of all concerned with the grains industry. Margins in farming, harvesting, trucking etc. are low & the risks are extremely high. It is vital that all operators are allowed to function efficiently. Having to constantly clean down machines places undue & unfair restrictions on harvesters, farmers, truckers etc.
Farmers aren't going to, or would be most reluctant to completely clean down all their augers, field bins, auger bins & trucks between GM & non GM crops - even if the weather doesn't look threatening.
Farmers cannot guarantee complete cleanliness, even if they did a complete clean down.
Harvesters aren't going to, or would be most reluctant to do a complete clean down in the middle of the harvest day or night when they have to move paddocks. Farmers & harvesters want that machine to be working at all possible times.
Truckers aren't going to, or would be most reluctant to completely clean down their rig in the middle of the harvest day or night.
All those associated in getting that crop to the recieval site, theoretically could add to the possibility of contamination of another supply chain. Who is ultimately liable?
Supply chain coexistence cannot work & will not work without imposing undue & unfair restrictions on all grass roots on-farm grain handling & harvesting operatives.
POST HARVEST - RISKS & LIABILITY.
Another harvest is over, although this time, GM canola was harvested & that machine was cleaned & moved into & harvested a non GMO crop for the same or most likely, a different client.
Rains eventually come along after harvest & the non GM farmers previous canola stubble needs to be sprayed because of volunteer canola & weeds etc. 99% of farmers use the practice.
Non GM farmer applies glysophate to his canola stubble. Some time later & to his surprise, he notices glysophate did not kill all the volunteer canola. He sees volunteer canola that was not affected by the application of glysophate down his paddock.
Immediately he or she is on the phone to the last person that was in his paddock that he knows was possibly in or near, a GM crop of canola. The header owner receives a very angry phone call. The header owner said he did do a clean down.
A writ is issued & duly arrives in the header owner's hands claiming compensation. Was it the header that spread the GM canola? Could it have been the truck that had some GM canola trapped, then fell out in a trail down the paddock? Could it have been birds? Could it have been from bees cross pollinating canola ? Could it have been trapped in someone's boot & emptied out down the paddock? Could it have been a "willie-willie" that picked up GM canola from another farms windrow & deposited same into his canola paddock?
The above scenario is not fanciful. It is more than likely to happen. It clearly flies in the face of the "freedom to operate" proposal & is in clear violation of "one supply chain should impose neither demands nor costs onto another supply chain."
Whether it's a 1% or 0.5% cross contamination, the level is irrelevant when it comes to our clients demands that we do not, under any circumstance, bring GM crop residue onto their farm.
ROAD TRANSPORT.
Most grain carriers cannot be guaranteed leak free. This can be seen by quantities of grain along roadsides at harvest. Many volunteer plants grow from grain spilt or leaked from trucks along roadways. This can be seen as a major potential contamination source of GMO crop material.
There is multiple accounts of canola seed contamination of bulk fertiliser. Trucks carry canola to port & pickup a load of fertiliser for the "back load".
What happens if that contamination is GMO canola?
Who is liable when that load of fertiliser is delivered to a grower that is adamant they don't want any GMO product on their farm - let alone GM canola?
That grower might not see the canola seed in the fertiliser but rest assured, he will see it when it germinates in his paddock!
Delivery sights, Rail loading and trucking facilities are all potential areas of accidental & unintentional spread of GMO to non GMO supply chains. Further costs would be needed to clean up and handle GMO crops above & beyond normal handling procedures. There would be a need for further segregation & handling facilities to be built; that along with further staff training would be another cost to be borne by the industry.
CONCLUSION
Evidence, including anecdotal & research data suggests that there is no sure way of preventing cross contamination other than total isolation geographically of GMO crops from non GMO crops.
Australia has a major marketing advantage over many countries in the world when it comes to our "clean green image".
Why would anyone want to discard that advantage in such a competitive & often unbalanced world trading environment?
Who would think to risk the loss of international markets, to increase harvest and handling costs, to introduce the possible threat of super weeds & to pioneer the inability to maintain genetic integrity of non GMO crops?
AGHA members are getting a clear & precise message from our clients - the grain growers of Australia - that the proposed benefits gained from the commercial release of GMO canola crops are far outweighed by the risks. They do not want GMO's on their farm.
RECOMMENDATION
AGHA recommends that the Moratorium be extended on the release of all commercial GMO crops in Australia for at least another five years & until the full implications & ramifications of GMO technology can be further assessed on a case by case basis by all involved in the grains industry in Australia.
AGHA also requires its members to be totally exempt from any liability or responsibility whatsoever that may result from the dissemination of any GM crop material that may impact onto any other supply chain(s), group(s) or individual(s).
Signed. Janice Pumpa - on behalf of
Brett Drysdale. President.
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