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Commentary: Test weight case reminds CGC of need for consultation

Sask Wheat and APAS were right to call out the CGC for what it said was a lack of consultation with its membership.
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Sask Wheat chair Brett Halstead said aligning primary standard to export standard was not done with proper consultation with producer groups and individual farmers.

Changing an institution with complex stakeholder relationships is difficult, as the Canadian Grain Commission found out this summer when it repealed its proposed changes to the Official Grain Grading Guide for the 2023-24 crop.

In June, the CGC said it was going to align the primary and export tolerances for test weight and total foreign material for multiple wheat classes.

These tolerances are more relaxed at grain elevators compared to export standards.

The CGC stated the changes would better meet the needs of the agriculture sector in Canada and grain buyers around the world.

The Saskatchewan Wheat Development Commission (Sask Wheat) and Agricultural Producers Association of Saskatchewan said the changes were not justified in a joint news release published in July.

“Separate primary and export standards recognize that blending and cleaning throughout the grain-handling system naturally and economically improve grain quality for grain-handling companies. Producers do not have the same ability to improve the test weight of their grain.”

With the primary standard tightened to export standard, the news release said, CWRS wheat that previously would have graded No. 1 could be downgraded to as low as feed if test weight is the determining grade factor.

For instance, CWRS wheat weighing between 60.1 and 60.9 pounds per bushel meets primary minimum test weight tolerance for No 1.

Under proposed changes, CWRS wheat weighing between 60.1 and 60.9 lb. per bu. wouldn’t even meet No. 3 CWRS test weight minimum of 61 lb. per bu., causing the wheat to be sold as feed to primary elevators.

The CGC said it was making the changes in response to stakeholder consultations, including at both the Eastern and Western Standards Committee meetings.

However, Sask Wheat chair Brett Halstead said aligning primary standard to export standard was not done with proper consultation with producer groups and individual farmers, and that the decision failed to consider a motion that was carried at the most recent Western Standards Committee meeting that called for the decision to be delayed until an economic analysis could be conducted.

So why did the CGC want to change in the first place?

Grain companies are important stakeholders the CGC would have worked with when crafting the new rules, and aligning the primary and export tolerances for test weight and total foreign material for wheat classes works in merchants’ favour.

Sask Wheat and APAS were right to call out the CGC for what it said was a lack of consultation with its membership.

The groups said the CGC has not provided evidence that tightening these primary tolerances to align with export tolerances is necessary to maintain export quality or shown how this change is neutral to its mandate to act in the interests of grain producers.

The economic analysis they want before any change is made is also an obvious step the CGC should have taken before announcing the changes in June.

It’s easy for any governing body to focus on the needs of large stakeholders because they have the resources, including staff, who know exactly how to advocate for their interests.

Wealthy organizations can employ effective communications tactics to spell out exactly the course of action they want, as well as justifications the regulatory bodies can use for the changes.

This is why it’s important for staff at the CGC, as well as any regulatory body in Canada, to make sure all stakeholders are consulted when significant changes are needed.

To the CGC’s credit, it reversed its proposed changes in the face of opposition from stakeholders.

This illustrates that farmers also have the power to exert pressure, and why they should support vocal representatives at grower groups who will stand up for their interests.

Robin Booker is The Western Producer’s production editor.

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