Application of Mineral Oil (MO) on All CGC Regulated Grain

The following memorandum provides supporting information to implement the Canadian Grain Commission (CGC) Order Number 2019-54 respecting application of mineral oil (MO) to grain.

Scope

The CGC Order is applicable to the application of MO to grain, destined for the export market, at licensed terminal elevators in Canada who satisfy the requirements of the Order. Grain is only those seeds designated by regulation as a grain for the purposes of the Canada Grain Act (CGA). The CGC Order does not permit:

  1. Application of MO at any location other than licensed terminal elevators in Canada (e.g. primary elevators, feed mills, or processing facilities); or
  2. Any dust suppressant other than food grade MO (e.g. canola, corn or soybean oil, or water).

Authority

The CGC’s authority on dust suppression is pursuant to the CGA and Canada Grain Regulations (CGR). Subsection 104(d) of the CGA requires operators of licensed elevators to have CGC permission to ‘mix with any grain in the elevator any material other than grain’.

The CGC has permitted licensed terminal elevators to apply food grade MO to grain only at a maximum of 0.02% by weight as an aid in dust suppression during the receipt, handling and/or discharge of grain, in accordance with the terms and conditions of the Order.

Prohibition

Under section 104(d), it is prohibited for any operator of a licensed elevator to mix any material with grain, except other grain, unless it is permitted by the CGC. Under section 105(c), it is prohibited for any person to sell, store or obtain inspection of grain that is ‘so treated, mixed or dealt with as to conceal its true characteristics’. Application of water to grain may have the effect of concealing its true characteristics. Application of water to grain has not been permitted by the CGC.

Mineral Oil Specifications

MO applied to grain must meet food grade specifications as prescribed by Health Canada.

Section B.01.045 of the Food and Drug Regulations (FDR) requires that food additives that do not have specifications set out in Part B of the FDR meet the most recent specifications set out in the Food Chemicals Codex (10th ed. 2016) or the Combined Compendium of Food Additive Specifications. The Food Chemicals Codex is a compendium of standards for purity and identity for food ingredients, including food additives, published by the United States Pharmacopeia Convention. The Combined Compendium of Food Additive Specifications is prepared by the Joint Food and Agriculture Organization (FAO)/World Health Organization (WHO) Expert Committee on Food Additives and published by the FAO of the United Nations.

Questions related to the specifications as prescribed should be directed to Health Canada or the supplier of the MO.

Initial Request Process

In order to have the Order apply, licensed terminal elevators must make a one-time request to the CGC. The following information is required as part of the request process and the necessary form is attached:

  1. Terminal elevator making the request;
  2. A description and schematic of all equipment to be used in the application of MO (e.g. storage tanks, oil pumps, lines, regulators, meters, application nozzles) including the number of application nozzles and the location where the application nozzles will be installed;
  3. Locations where the MO will be applied at the terminal elevator
    1. on receipt of grain
    2. during the handling and/or cleaning of grain, and/or
    3. on discharge of grain;
  4. A detailed description of the measures in place for the terminal elevator operator to verify, on an ongoing basis, even application and that application rates of MO are within permitted tolerances;
  5. A detailed description of the measures in place, or the work instruction, to be followed in the event of excess application of MO or MO spills;
  6. Identification of visual monitors and/or devices that are accessible to CGC staff for periodic verification of the application of MO;
  7. The intended application rate for each application of MO expressed in a percentage by weight;
  8. The nature and type of records that will be maintained and made available to the CGC upon request;
  9. A copy of documentation of the properties and specifications of the intended MO which demonstrate that the MO meets food grade specifications; and
  10. Density values of the intended MO.

Upon receipt of an email or written acknowledgement from the CGC that the initial request for the application of MO is complete and approved, the CGC Order will permit the operator of the licensed terminal elevator to apply MO to grain, in accordance with the terms and conditions of the Order.

Requests should be submitted to Gino Castonguay, Chief Grain Inspector for Canada, at gino.castonguay@grainscanada.gc.ca.

I-402 - Terminal elevator application on the proposed use of mineral oil (PDF - 64 kb)

Responsibilities of the Terminal Grain Elevator

Equipment and Devices

As a general condition of licensing, section 16(b) of the CGR requires that an elevator operator ‘notify the Commission, in writing, of any functional alteration to the elevator building described in the application or any functional alteration respecting grain flows or sampling or control mechanisms, and of any addition to any equipment associated with the elevator, within 15 days after plans for the alteration or addition become available’.

The applicant must install and maintain equipment for application of MO in accordance with manufacturer’s guidelines. It is the responsibility of the applicant to ensure that all equipment, product and storage tanks meet any civic, provincial or federal legislative and regulatory requirements.

Application of Mineral Oil

Under the terms of the Order, MO may be applied to grain upon receipt of grain into a terminal elevator, during the handling and/or cleaning of grain, and/or upon discharge of grain from a terminal elevator. However, the application of MO must be performed prior to official sampling and weighing upon discharge of grain from the terminal elevator.

It is the terminal elevator’s responsibility to ensure that MO is applied in a manner that provides for thorough mixing and promotes even coating of grain streams. If a terminal elevator chooses to apply two or more smaller quantities of MO to the same lot of grain, the sum of all applications shall not exceed 0.02% by weight of the grain.

Reporting and Recordkeeping

Terminal elevators are required to report to the CGC in the following manner:

Prior to loading a vessel with grain treated with MO, the terminal elevator operator must notify the CGC of MO application as part of the current process for submission of Vessel Loading Orders to the CGC. The Vessel Loading Order must now include the following:

  1. Grain tonnages to be loaded and the intended average MO application rate. Grain volumes must be reported in metric tonnes and MO application rates in percentage to the weight of grain loaded;
  2. A reference that MO has been applied to grain only at a maximum of 0.02% by weight; and
  3. Confirmation that the purchaser of the grain accepts the application of MO.

If any anomalies with the application of MO are experienced at any point in the MO application process, as per section 76(1) of the CGA, such anomalies must be reported to the CGC.

Notification and reports are to be provided to the respective Regional Manager of Inspection Services at:

Records

Records shall be maintained in a form readily available for inspection by the CGC and must include:

  1. MO application rates applied upon receipt, during handling, cleaning and/or upon discharge of grain in order that application rates and tonnage can be provided to the CGC upon vessel hold completion;
  2. Volumes of MO purchased;
  3. Quality properties and specifications of MO purchased; and
  4. Maintenance and/or replacement of equipment used in the application of MO.

All records shall be kept for a minimum of 2 years.

Monthly Reporting

The following information shall be collected, recorded, and reported to the CGC on a monthly interval:

  1. Name of the terminal elevator;
  2. Total tonnage of grain to which MO was applied during the month;
  3. Quantity, in litres, of MO applied to that tonnage of grain during the month;
  4. Copies of all documentation indicating the MO supplier’s name, address and date of delivery, litres of MO supplied, and product data to demonstrate that the MO meets food grade specifications in Canada and density values; and
  5. Average application rate of MO applied expressed in percentage by weight of grain.

The information for each month shall be provided no later than seven (7) calendar days from the end of that month (e.g. information for January shall be reported no later than 7 calendar days into February.)

Monthly reports are to be submitted to Gino Castonguay, Chief Grain Inspector for Canada, at gino.castonguay@grainscanada.gc.ca.

I-404 - Terminal elevator monthly report on the application of mineral oil (PDF - 40 kb)

Monitoring and Enforcement

The CGC will review all monthly submission reports submitted by terminal elevators to ensure compliance to this policy. Authorized CGC representatives must be permitted access to terminal elevator premises and records on request for compliance purposes.

In addition, the CGC may, on an ad-hoc basis, analyze a portion of the sample obtained during the official sampling, to verify that the amount of MO compounds present is within compliance. If CGC monitoring indicates that MO compound levels are not within acceptable tolerances, terminal elevators will be notified.

Inquiries

Questions related to this memorandum should be directed to: Gino Castonguay, Chief Grain Inspector for Canada, at (204) 983-2780 or gino.castonguay@grainscanada.gc.ca.

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