In comments submitted to the USDA on Oct. 7, the NGFA addressed several portions of Perdue's plan important to the grain, feed, grain and oilseed processing, and export sectors, specifically:
- Extricating the Federal Grain Inspection Service (FGIS) from the Grain Inspection, Packers and Stockyards Administration (GIPSA) and realigning it within USDA's Agricultural Marketing Service (AMS);
- Realigning the Farm Service Agency’s (FSA) grain warehouse functions within AMS; and
- Realigning the U.S. Codex Alimentarius Office from the Food Safety Inspection Service (FSIS) to the Office of the Undersecretary for Trade and Foreign Agricultural Affairs.
The NGFA strongly supported Perdue’s decision to break the FGIS apart from GIPSA and realign the agency within the AMS. The association recommended making the FGIS a stand-alone entity within the AMS with a direct reporting relationship to the AMS administrator. Once the realignment is completed later this year, the NGFA also recommended that the FGIS review the current geographical boundaries for designated agencies that provide official inspection, weighing and other services in the domestic market, and develop a standardized “delegation of authority agreement” that applies to all designated agencies that provide such services at export port locations.
Further, the NGFA said it believes once the realignment is complete, “FGIS should evaluate and consider utilizing independent third parties under FGIS oversight to perform mandated and optional inspection services at grain export ports to improve efficiency and reduce inspection costs to the industry and its farmer-customers.”
Additionally, the NGFA supported the realignment of the USDA’s grain warehouse functions within the AMS, but recommended that the USDA explore further cost-cutting efficiencies in Commodity Credit Corp. (CCC) program administration, such as ending duplicative examinations of grain warehouses operating under the Uniform Grain and Rice Storage Agreement contract with the CCC if those warehouses already are licensed and examined by the USDA or states, unless the warehouse is storing significant quantities of CCC-owned commodities. The NGFA also emphasized the importance of the federal grain warehouse program continuing to receive appropriations to pay for services provided under the UGRSA, which primarily benefit the USDA and producers obtaining marketing assistance loans under the federal farm program.
Finally, the NGFA noted its support of Perdue’s decision to realign the U.S. Codex Office within the mission area of the new undersecretary for trade and foreign agricultural affairs. However, when doing so, the NGFA recommended that the U.S. Codex Office be maintained as a stand-alone office reporting directly to the undersecretary, and not be incorporated within the Foreign Agricultural Service.
“We believe (this is) important to demonstrate that the U.S. Codex Office continues to be an advocate for science-based Codex policies” and prudent and science-driven risk-assessment and risk-management measures focused on food safety, the NGFA noted.
The NGFA said it greatly appreciated Secretary Perdue’s decisive leadership and initiative in reorganizing and realigning agencies within the USDA to improve customer service and to enhance the department’s effectiveness and efficiency.
