In response to the flooding related to Hurricane Harvey, FDA issued a notice that any food or food ingredients exposed to flood waters may not enter the food chain. This notice is not specific to cotton or field crops, but covers all types of human and animal feeds. Click here to read the full notice.
In the notice, they do differentiate between flood waters, and crops that have simply been exposed to rain.
Several of our seed buyers have developed a form that they are requiring customers to sign which certifies that the seed being sold has not been exposed to flood waters. It is important that you communicate this issue to your farmers, and let them know that the seed from any seed cotton that was exposed to flood waters will not be allowed into the feed market. This is especially critical where the insurance adjusters are requiring the cotton to be harvested or processed – the adjuster needs to be informed that seed from the flooded seed cotton will not be salable, even if the lint cotton is.
This release is related to the FDA Food Safety Modernization Act (FSMA). We have been communicating various aspects of this Act for several years now. FDA has broad recall authority under this act, and it important for all of us to ensure that only good seed be allowed to enter the food chain. If you have any questions about this issue, please give us a call.