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 UNITED STATES DEPARTMENT OF AGRICULTURE

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 GRAIN INSPECTION ADVISORY COMMITTEE

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 THURSDAY,

DECEMBER 16, 2021

 The meeting came to order at 11:00 a.m. EST

via Videoconference, Matthew Kerrigan, Chair,

Presiding. 

COMMITTEE ATTENDEES: 

DAVID AYERS, Champaign Danville Grain Inspection,

 Inc. 

CHAD CHAMBERS, Caledonia Farmers Elevator 

JANICE COOPER, Wheat Marketing Center 

CURTIS ENGEL, The Scoular Company 

NICHOLAS FRIANT, Cargill, Inc. 

MATTHEW KERRIGAN, EGT, LLC 

RYAN KUHL, Northern Plains Grain Inspection

 Service 

ROBERT SINNER, SB&B Foods, Inc. 

JIMMY WILLIAMS, Missouri Department of

 Agriculture 

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USDA STAFF: 

LEE CAPPER, Chief Innovation Officer 

ANTHONY GOODEMAN, Field Management Division 

ED JHEE, Technology and Science Division 

KENDRA KLINE, Agricultural Marketing 

ARTHUR NEAL, FGIS Deputy Administrator 

TIMOTHY NORDEN, Scientific Integrity Officer 

DENISE RUGGLES, Executive Program Analyst 

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 C-O-N-T-E-N-T-S

 PAGE 

Call to Order 

Matthew Kerrigan, GIAC Chair Person. . . . . . . . 4 

FGIS-FDA MOU Discussion 

Nick Friant, Subcommittee Chair. . . . . . . . . . 6 

Public Comments. . . . . . . . . . . . . . . . . .41 

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P-R-O-C-E-E-D-I-N-G-S

 11:00 a.m.

 MR. KERRIGAN: Good morning, 

everybody. I just was going through to see who 

was on currently because our speaker here in a 

couple minutes, I don't see Nick on just yet. 

While I am search for Nick and we're waiting for 

Nick, we'll go ahead and take a roll call. I 

think we have a pretty good list here. It looks 

like David Ayers, it looks like you're on.

 MR. AYERS: Yes, sir.

 MR. KERRIGAN: So we've got Janice.

 MS. COOPER: Yep.

 MR. KERRIGAN: Jimmy?

 (No audible response.)

 MR. KERRIGAN: Mr. Sinner?

 (No audible response.)

 MR. KERRIGAN: We've got Chad.

 MR. CHAMBERS: I'm here.

 MR. KERRIGAN: Curt Engel?

 MR. ENGEL: Here.

 MR. KERRIGAN: Ryan Kuhl? 

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(No audible response.)

 MR. KERRIGAN: And we are waiting on, 

it looks like, Nick and -- oh, I just saw him 

join.

 MR. FRIANT: I'm here. Sorry about 

that.

 MR. KERRIGAN: And how about Tom 

Tunnell?

 (No audible response.)

 MR. KERRIGAN: Tom had some conflicts 

yesterday, and I did not hear back from him about 

today. So okay. Well, we will keep an eye out 

on that. Going off the agenda, we do have one 

discussion to update the group on regarding some 

subcommittee work regarding the FGIS FDA MOU 

which I'm going to ask if Nick would walk us 

through where that subcommittee work is at.

 Once we're through that, we will take 

roll call one more time to see where we are at. 

If we have a quorum, we can discuss the 

recommendations. If we don't, we'll open it to 

public comments. And that may be the wrap. 

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Nick, do you want to go ahead and take it over as 

the Chair of the FGIS FDA MOU Subcommittee?

 MR. FRIANT: Indeed I will. Thanks, 

Matt. And thanks everybody for the time today to 

hear what the subcommittee worked on. And we'll 

be able to show -- we'll actually be able to show 

you that.

 So what I wasn't able to do before 

today's meeting -- sorry, I have too many screens 

to look at here. What I wasn't able to do before 

this morning's meeting was pull up the actual 

recommendation that was made by the committee 

during the last advisory committee meeting. But 

in essence, it said let's move the former 

subcommittee to look at -- to develop some preapproved reconditioning plans when a facility has 

had an FDA actionable lot of grain.

 So that was the basis for the 

recommendation. We formed the subcommittee. 

That subcommittee consisted of myself as the 

Chair as Matt mentioned. We also had Dave Ayers, 

Ryan Kuhl, Curt Engel. And I think that was it, 

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wasn't it? I don't even have those -- sorry, I 

got caught in another call before this one.

 I think that was all of the 

subcommittee. And the intention of the 

subcommittee was to take a look at the current 

FGIS FDA MOU, what items were considered 

actionable under that MOU, and then determine 

what types of pre-approved reconditioning plans 

we could have for that. Real quick and I didn't 

see, is Barry from FGIS on this morning?

 MR. GOMOLL: Yes, I am, Nick.

 MR. FRIANT: Barry, sorry to put you 

on the spot. Did you want to maybe just given a 

quick update on the overall work that you've been 

doing with FDA on the MOU? Because I think that 

is pertinent to our discussion.

 MR. GOMOLL: Yeah, I haven't had any 

discussions recently, not since I think our last 

meeting with the subcommittee. But I've been in 

continuing talks with several members of FDA 

CFSAN and others in their policy about 

possibility of working with sort of pre-approved 

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plans. They seem to be at times more or less 

receptive depending on how they're receiving the 

messages, I guess.

 Sorry. I just hit the space key. The 

mute was on. They see to be more or less 

receptive. And we'll have to -- once we get some 

more concrete things, we'll have to figure out 

which channels to go. I know they had said in 

the past that with some other agencies, I think 

talking about with maybe peanuts or some other 

industry that a lot of the changes were pushed 

from the industry and not from the U.S. -- hold 

on one second.

 My wife left the dogs behind me. So 

now they're acting up. Can you not? Sorry. So 

we've been having discussions. And I think I'm 

definitely try to have a meeting with them 

sometime in the early part of the year just to 

touch base to see where they're at, especially 

after we hear some more, what comes out of this 

meeting.

 MR. FRIANT: Excellent. Thanks, 

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Barry. And appreciate -- for sure from my seat, 

appreciate your continued work with FDA on that 

front. And I think it could have some good 

discussions with them on how we can get these 

pre-approved reconditioning plans in place.

 So with that, the process that we took 

as a subcommittee like I kind of alluded to was 

we looked at the MOU, looked at the actionable 

items that were in there and went through it and 

said, okay, which of these actionable items do we 

think are ones that we could reasonably have a 

reconditioning place for that again could be preapproved? And I think hopefully this will work. 

I'm going to try and share this. If not, Kendra, 

I might need you to share it. But I'm going to 

try and see.

 MS. KLINE: Okay.

 MR. FRIANT: Okay. Hopefully folks 

are seeing the draft version. And I believe, 

Kendra, this was sent out also as part of the 

meeting announcement too, correct?

 MS. KLINE: It was posted to the 

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public website a couple weeks ago.

 MR. FRIANT: A couple weeks ago, yeah. 

So what you can see here at the top is the types 

of items, for lack of a better term, that are 

actionable for which the subcommittee thought we 

could have some sort of pre-approved 

reconditioning plan for. And it was things like 

the animal filth which we know has been a big 

discussion topic, particularly deer droppings, 

insect damage grain, aflatoxin which already has 

a pre-approved condition plan, deleterious 

foreign matter in grain, and then DLQ I have here 

on account of large animal excreta.

 And the next part of our process was 

to essentially take the current pre-approved plan 

for aflatoxin and modify that to fit all of these 

actionable items. So what you'll see here or 

what you may have seen if you went through the 

draft that was posted on the public website 

basically is following that, the reconditioning 

plan that is in the mycotoxin handbook, the 

Section 6 or 6.4 more specifically. And we 

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basically took that verbiage that was in that 

reconditioning section and modified it to fit 

additional types of actionable items that we 

could see in grain elevators.

 So I don't know that we need to read 

through the whole thing with this group. But 

maybe what I would call out is a couple points 

that the subcommittee talked about that we found 

were important. And I'll start with kind of 

right here on the middle of my screen.

 If the sublot or lot is found to be 

actionable due to IDK, the affected grain company 

could elect to divert that lot directly into 

animal feed without reconditioning. And this is 

something that we talked about and said, well, 

maybe the facility doesn't want to deal with 

reconditioning, try to remove that IDK. And so 

could go directly into animal feed and more 

importantly have a little bit more flexibility to 

go directly into animal feed without necessarily 

having to go through the full -- if folks aren't 

familiar with it, the very prescriptive process 

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of diversion to animal feet.

 So that was something I would consider 

new to kind of the overall reconditioning 

procedures is the ability to direct the 

actionable lot directly into animal feed. After 

that, we did spend some time talking about the 

concept around, well, how many times can you run 

the grain? So in most conditions, what we're 

saying is you can run the grain over a cleaner 

screener separator, some sort of process to 

remove that actionable item.

 And so we had some discussion around 

the ability to make multiple passes across the 

mechanical cleaners. Folks that are familiar 

with the aflatoxin reconditioning procedure will 

likely remember that the facility can run the 

corn, for example, over the cleaners as many 

times as they want but only have one chance to 

get that officially regraded and retested for 

aflatoxin. And so we talked about that piece as 

well which is number 2 here on the screen of --

the first part is the applicant can pass the 

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actionable lot over a cleaner -- some sort of 

mechanical cleaner multiple times.

 And a change that we're proposing is 

not only multiple passes which is consistent with 

previous procedure. But that grain can also be 

eligible for the original inspection and a full 

set of review inspections and follows the FGIS 

policy around review inspections. So we 

recognize that this was a potential -- not 

potential, it is a change from previous policy 

position and something that likely will be open 

for discussion with the agency FGIS and 

potentially FDA as well.

 I think that's probably the most 

substantive change I want to bring to the group. 

Otherwise, the FGIS procedures, FGIS 

responsibilities essentially stay the same to 

what is currently in the aflatoxin section except 

obviously expanded to cover multiple actionable 

items, domestic locations, essentially, the same 

procedure with the official agencies, sample size 

and preparation, again, essentially the same as 

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what's currently listed, basically, a cut and 

paste right out of the current reconditioning 

requirements in the mycotoxin handbook. And the 

disposition piece again is essentially the same, 

just expanding it to not only cover aflatoxin.

 It would be any of those actionable 

items. And so that's what the subcommittee has 

developed, what we are, I guess in this case, now 

reporting back to the broader committee. I think 

if folks had time to review it prior to today's 

meeting, I think we are certainly open to 

questions, comments. And then I guess we could 

probably have some discussion around next steps. 

But we -- I don't think we can take any official 

action necessarily on next steps.

 MR. KERRIGAN: Thanks, Nick. 

Regarding next action, obviously the subcommittee 

put this out there. I'm assuming that our entire 

group would be to recommend it. Or is this 

something that FGIS on their own would then be 

discussing with FDA without a recommendation just 

from a procedural question? 

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MR. NEAL: So in light that you all 

have been working with Barry on this, we can --

and with us and considering we do not have a 

quorum, I think -- and it's tough right now. 

It's tough because we've taken this work up as 

part of the committee. You can't make a formal 

recommendation on it.

 I think what we can do is still have 

conversations with FDA about the discussions and 

share industry thoughts. I think from a formal 

standpoint once we do get quorum, it will be 

great to have this officially come from industry 

to FDA because their feedback to us is that they 

need to hear from industry, not USDA. And so the 

whole purpose of bringing this issue to the Grain 

Inspection Advisory Committee is so we can have 

feedback directly from industry to FDA so that 

they do know that this is not just us carrying 

the war.

 (Simultaneous speaking.)

 MR. FRIANT: I'll just come to that 

does not prevent us from still engaging and 

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facilitating conversations about the concepts 

discussed so that we can still make progress.

 MR. GOODEMAN: May I add something 

real quick, Nick?

 MR. FRIANT: Yeah, please, Tony.

 MR. GOODEMAN: I think it would 

definitely help like Arthur was saying. Like, 

FDA was pretty -- they're big advocates for 

hearing from the industry. And so it'd be 

helpful for us knowing this was a really good 

unified position from the committee.

 And if there's not a whole lot of 

dissension here which I don't think there is. 

But I think it'd be helpful to have committee's 

support. I'm also curious if NEAGA would pick up 

any subcommittee's work and endorse it through 

their own organizations. I'm not sure if this is 

the right forum to ask that question. But that 

is something that might be another means to help 

push it with FDA.

 (Simultaneous speaking.)

 MR. FRIANT: I mean, on that front, I 

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would -- I mean, I'm not sure that many people 

know this. I chair the NGFA Grades and Weights, 

and the NEAGA Grades and Inspections Committee. 

So my intention would be to take this to those 

committees for review and input.

 And then the committees and respective 

staff would make some decisions on if and how to 

pursue this with FDA. I think we had talked 

about it as the committee, right, FDA wants to 

hear from industry. But I'm not sure that I 

shared that well or clearly with NGFA and NEAGA.

 So that's a key point that FDA would 

want to hear directly from industry. So I think 

the short answer to that, Tony, is yes, I think 

it would be something that NGFA and NEAGA would 

be interested in for sure, providing input and 

feedback and then some further discussion on how 

to approach it potentially with FDA. I think the 

only thing I wanted to raise, Arthur, before I --

(Simultaneous speaking.)

 MR. McCLUER: Nick, I was just going 

to say totally support what you're saying. As 

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chairman of the Grain Grades and Weights 

Committee, I think this is definitely -- this is 

the initial draft and this would be definitely at 

our next meeting. We would definitely put this 

on the agenda for review and kind of go through 

it. Matt -- Chairman Kerrigan is also a member 

of the Grain Grades and Weights Committee too. 

So I think that'd be a good opportunity for 

feedback from the members and something to take 

back to the full advisory committee as well 

because there may be some additional input for 

the advisory committee to consider too.

 MR. FRIANT: Thanks, Jess. So Matt 

and/or Arthur, I guess, from a procedural 

perspective, is it fair to say we would 

essentially -- as a subcommittee, we would still 

be operating under the current recommendation of 

forming the subcommittee, developing the draft. 

And so as a subcommittee, we could still work on 

it, whether that be subcommittee working with 

Barry and FDA or subcommittee working with trade 

associations, right? I see you shaking your 

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head, Arthur. So we can still operate under that 

current recommendation and we'll still be okay 

from a procedural perspective.

 MR. NEAL: Yeah, nothing is preventing 

us as a subcommittee from having a dialogue, 

sharing a perspective that's been developed to 

date. What we cannot do is take action on the 

document as a committee. That's the main thing 

we can't conduct business on.

 MR. FRIANT: Sure. Continuing to 

accept feedback from the committee is not 

considered business, though, right?

 MR. NEAL: Right. The subcommittee is 

still working.

 MR. FRIANT: Sure.

 MR. NEAL: That's no problem. And so 

what you're doing as a subcommittee, if you're 

complete -- if you've completed your work, you 

would then hand that work over to the full 

committee. And the full committee would take 

action to either endorse or modify or reject the 

body of work that the subcommittee has done. 

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You've not turned the body's work 

fully over to the committee is what I'm hearing. 

The subcommittee is going to continue generate 

input from the industry as well as facilitate 

dialogue to kind of gauge how open FDA is to 

entertaining some of these concepts. You're also 

going to work with other trade groups to garner 

more input and assess how people feel about those 

things. So the subcommittee is still working 

under a previous action that was taken at the 

last meeting. So we're good.

 MR. FRIANT: Thank you for that 

clarification, Arthur. I appreciate that.

 MR. NEAL: Yes, sir.

 MR. FRIANT: So with that, I mean, I 

would ask for the committee members that are on 

the phone this morning any questions that I or 

anyone else on the subcommittee could answer 

about what we've identified, the proposals that 

we're working on. Any questions or comments from 

the broader committee?

 (Simultaneous speaking.) 

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MR. KERRIGAN: I would just add for 

everybody listening here just backing up to the 

concept of why the subcommittee was formed and 

why these reconditioning procedures are, I guess, 

wanted or needed. Is it because of the sheer 

time that the FDA can take and the, I would say, 

inconsistent application of reconditioning plans 

from their own office to office across the 

country? Like I said, there was a successful 

model with aflatoxin already out there that had 

been approved.

 With that as far as what procedures 

could take, that could be under observation by 

FGIS to complete. And the idea was to replicate 

that across additional actual items from FGIS to 

FDA. Sorry, Bob, I think I spoke over you there.

 MR. SINNER: No, that's fine. And 

this may be pretty straightforward, Nick. On 

that third paragraph there under 6.4 under the 

wheat, does anything need to be qualified in that 

statement in regards to mycotoxins?

 A lot of times, IDK leads to molds and 

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mycotoxins. Does that -- because really it's 

stating that that grain can be moved directly 

into animal feed without reconditioning and not 

even needing to notify FDA. Is there anything 

there that needs to be qualified regarding 

mycotoxins?

 MR. FRIANT: You know what, Bob? 

That's a really good question. We did not talk 

about the mycotoxin piece. We were purely 

focused on just the insect damage kernels. So I 

think that's -- my answer would be that's 

something the subcommittee should maybe discuss a 

little bit further because we did not consider 

the mycotoxin piece.

 MR. SINNER: Okay.

 MR. FRIANT: But I appreciate that 

feedback for sure.

 MR. SINNER: Well, I mean, a lot of 

times, insect damage grain leads to molds and we 

all know that. And so I just wondered if that 

should be qualified with this in that statement.

 MR. FRIANT: If I could spell. Go it. 

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Yeah, we'll make sure we consider that. I 

appreciate that. Thanks, Bob.

 MR. SINNER: Good.

 MR. NEAL: Nick, I've got a question 

and this may be just because of my unfamiliarity. 

That particular highlighted paragraph, would FDA 

know why we are suggesting that in the case of 

wheat that we are suggesting that it can be 

elected that the wheat be diverted into animal 

feed without reconditioning? Would they 

understand why we would be recommending that?

 MR. FRIANT: That's a good question. 

Knowing FDA, it's probably not safe to assume 

that they would understand that which I think is 

probably where you're getting to a little bit 

with your question, right? Like, so what I think 

I hear you saying is maybe we need a little bit 

more why apply to this section.

 MR. NEAL: Yeah, let me -- so my 

perspective would be don't assume they know 

anything. And I'm not saying that they don't. 

But we know that there's turnover happening all 

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across the lane. And it will be best that if 

there's something that could appear to be 

digested and potentially be passed on and 

consumed by humans or animals. They need to 

understand why it --

MR. FRIANT: Sorry, I think you froze 

up on my end, Arthur.

 MR. NEAL: Was I frozen?

 MR. FRIANT: Yes, you froze up on us.

 MR. NEAL: Oh, man. Kendra said, I 

may be frozen. All right. I don't know. But I 

was just saying because we're diverting an 

actionable lot potentially to animals, we need to 

make sure we address the reason why it would not 

be an impact on human --

MR. FRIANT: Yeah.

 MR. NEAL: -- or animal health and 

safety. And FDA is going to be looking at things 

for that type of impact. When people get sick 

from it, when animals get sick from it, will it 

be passed on to somebody else?

 MR. FRIANT: Yeah, yeah, good call, 

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Arthur. I appreciate that for sure. Perhaps 

that's something that's actually needed more 

broadly. We might need to think about overall 

for all of these items why. We might need to 

defend why cleaning is an appropriate -- cleaning 

and screening is an appropriate reconditioning.

 So I appreciate it. I think that's 

good feedback, and I think you're right. We --

even just from my own seat it was probably making 

that assumption that FDA understood the grain 

business in general.

 MR. GOODEMAN: Nick, is the assumption 

that when things are reconditioned that the 

cleanings or screenings -- and I'm sorry if it's 

in here -- are they disposed or are they diverted 

to animal feed?

 MR. FRIANT: Yep, so we basically took 

it right from the aflatoxin document to say that 

they're not going to reenter the human food 

channels screenings. Maybe this needs to be 

expanded further to say any type could be 

diverted into animal feed. Doesn't necessarily 

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say that they have to go to just landfill or 

disposal.

 MR. GOODEMAN: Right, right.

 MR. FRIANT: And we also say contact 

the FDA office on other --

MR. GOODEMAN: Right.

 MR. FRIANT: -- specific disposition 

actions for the screenings.

 MR. GOODEMAN: If my understanding is 

accurate, the industry before was concerned if 

they were able to clean something, screen 

something, and then only have to worry about 

dealing with FDA on the clean portion, whatever 

it is, the ten percent of the -- or five percent, 

whatever it turns out to be versus and then being 

free to handle the clean cargo. That would 

address a big part of the issue, right?

 MR. FRIANT: Yeah, yeah.

 (Simultaneous speaking.)

 MR. GOODEMAN: -- follow up directly 

with FDA and what to do with the screenings. We 

were free to move the clean grain, the 

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reconditioned grain. And that would alleviate a 

lot of the problem, right?

 MR. FRIANT: Yeah, yeah. For sure 

being able to move the clean grain is the focus. 

But you're right. And frankly, we focus so much 

on what I would call the top portion of the 

document, the procedures --

MR. GOODEMAN: Yeah.

 MR. FRIANT: -- and some of the 

disposition, certainly open for suggestions, 

comments from anyone on that. And I think that's 

a good call out, Tony.

 MR. NEAL: Nick, would you mind 

sliding up to the previous page?

 MR. FRIANT: Without having both 

documents side by side, I can't say for sure. 

But most of this section was cut and paste right 

from the current aflatoxin reconditioning 

procedures.

 MR. NEAL: I think Tony -- go back up 

a little bit, Nick. Yeah.

 MR. FRIANT: This would've been an 

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addition or clarification here, right, for 

example.

 MR. NEAL: Yeah, yeah. And that's 

what I was about to say is that we have to really 

reiterate what it is we're trying to do to help 

them carry out their responsibilities. And we're 

looking at this as an SOP which is fine. I think 

for us when we sit down to talk with them, we'll 

need to present it as such that we're not trying 

to necessarily get you out of the way.

 We're really trying to help facilitate 

your work as well as streamline the food supply 

chain yet maintain a keen eye and concern for 

human and animal -- we're not in safety. So we 

can't necessarily be deputized by them. But 

we're trying to honor their work considering 

loose constraints and things of that nature and 

see whether or not this can fit into their plan 

for carrying out oversight in this space.

 And so I see this more of an SOP. 

We'll probably have to have another kind of cover 

that really explains what it is we're trying to 

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do. But we have already conveyed to them our 

desire to work with them, the reason why we need 

to work with them. But when we do finalize this, 

we want to make sure it's packaged so that they 

can digest it the way we intend them to.

 MR. FRIANT: I think that's a good 

comment, Arthur. So I've captured that here, 

right, clear responsibilities. I'll have FGIS 

help me facilitate FDA's work. Streamline 

grains, I think those are all good, good 

language.

 And then also what I heard you say is 

whether it's a cover letter or preamble or 

something along those lines that gives more that 

clarification guidance because you're right. The 

discussions that we as a subcommittee either with 

Barry or through Barry or directly might have 

with FDA, those people might change three, six, 

nine months, years, whatever down the road. So 

yeah, I'm definitely following what you're saying 

on that.

 MR. NEAL: Yeah, and another thing I 

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see that's really critical and important and 

beneficial with this is that it can also be used 

as a way of facilitating a consistency in the 

midst of change, changing staff. It helps to 

reduce that learning curve because we'll be 

taking some of that responsibility on for them 

but communicating with them. I think -- and I 

don't if it is in here. I think that whatever we 

do on their behalf, there needs to be a 

responsibility that we document it and convey 

that to them so that they are aware of the 

decisions that have been made.

 MR. FRIANT: Yep, so I think to your 

point, Arthur, I think that is covered here.

 MR. NEAL: Yeah, you got it. You got 

it.

 MR. FRIANT: Now there might be some 

question and debate on which that be clear enough 

for FDA going forward, right? Is there something 

more that they would want. But yea, you're 

absolutely right in terms of we don't want 

anybody from FDA coming back to FGIS or the 

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industry saying, well, we didn't know you did 

that.

 MR. NEAL: You got it. Thanks.

 (Simultaneous speaking.)

 MS. COOPER: I just had a question. 

So you mentioned a lot of the language came from 

the existing policy. For discussion purposes, I 

think it would be helpful to do a document where 

it's clear what the additions or changes are.

 MR. FRIANT: Yes.

 MS. COOPER: Either attract changes --

MR. FRIANT: I'm not going to try and 

do that.

 MS. COOPER: No, not right now.

 MR. FRIANT: Not in this venue. But 

I think I can do that with the work that we did, 

Janice, where you can see the tracked changes. 

If not, we can probably work with someone to get 

that to you so you can see it more clearly.

 MS. COOPER: And then I think it would 

just present that maybe you're not proposing that 

may differences, that there's a lot of the policy 

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already there. You're just tweaking it. And I 

think that that might be an easier sell with FDA. 

I don't know. Just from an editorial standpoint, 

I didn't know what was existing versus what was 

being changed, so --

MR. KERRIGAN: Was this as much of a 

change as it is a new document? I realize that 

we've copied and pasted the aflatoxin with it. 

So I guess that would be my question knowing that 

we've added so much. We've based it off the 

aflatoxin, but do we want to show it as a change? 

Or do we want to show it as a new document 

because of everything else that's been added to 

it?

 MS. COOPER: And I'm just unfamiliar 

with the procedure. So I didn't know.

 MR. FRIANT: Yeah, great -- I think 

great point, Janice, from you and I think great 

question, Matt, from you. Maybe that's some 

additional discussion that the subcommittee could 

have on the best way. Because I think your 

intention, Janice, is spot on, right? 

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Demonstrate to FDA what we're 

proposing for other actionable items is 

consistent with what's already been in place for 

aflatoxin which we clearly know is a food and 

feed safety issue, right? So I think your mind 

is in the right place. How we do that, yeah, 

Matt. It might be a good question.

 Is it good enough to do like track 

changes? Or do we need some sort of additional 

comparison document? That's a valid question. 

So I think as a subcommittee, maybe we need to 

regroup on that piece. What I'm hearing, I've 

heard it from Arthur now and I hear it too now 

from you, Janice, is the story that we need to 

tell FDA, right?

 We can't just go in front of FDA and 

say, here it is. This what we want to do. But 

why, how, the importance, like, there's as much 

to that story and that preamble or cover letter 

or introduction, whatever we want to call it, 

that's going to matter down the road when the 

next person at FGIS or the next person at FDA 

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sees this that wasn't part of this subcommittee 

or committee work.

 MS. COOPER: And maybe what I'm 

suggesting is already going to be covered in what 

Arthur suggested in the preamble and the 

explanation. And maybe that will be sufficient. 

So it was out of -- really out of ignorance that 

I kind of asked the question about how the 

document -- how much of the document is current 

language and what is being proposed. So you can 

handle that in lots of different ways per Matt's 

comment. So just I think clarification is the 

goal of all this discussion.

 MR. FRIANT: A hundred percent agree 

with you. Like I say, I'm not going to embarrass 

myself in front of everybody with my IT skills to 

pull up the track changes. But I think we can 

start from there. I think that's a good point.

 MR. KERRIGAN: A question in talking 

about kind of the preamble and discussing or 

trying to lay out the basis for animal and human 

food safety was, are we aware of a document that 

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covers that currently for when the aflatoxin 

procedures were put in to kind of see how that 

was laid out. Or was that kind of pre- and 

basically all done, I guess, verbally or through 

staff?

 MR. FRIANT: And that'd be a question, 

I think, for Tony maybe. As long as I've been in 

my role, I think that's what's been in place.

 MR. GOODEMAN: What was it again, 

please, Nick?

 MR. FRIANT: So do we know any of the 

basis for how the aflatoxin reconditioning 

procedure was established and agreed to?

 MR. GOODEMAN: I think much like this. 

I think it was an issue and didn't want to have 

to wait probably -- I'm guessing here, probably 

during some high aflatoxin years and not having 

to wait for a bunch of bins to be tied up when 

the reconditioning procedure was going to be 

likely the same. I think there's also some 

research about the broken corn -- the broken 

kernels containing a higher concentration of 

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aflatoxin and prompting the cleaning to be 

allowed, then the retesting. It's --

MR. KERRIGAN: That --

(Simultaneous speaking.)

 MR. GOODEMAN: -- for a long time, 

though.

 MR. KERRIGAN: That research is just 

kind of maybe the question that kind of proves 

that. As we think about the preamble or trying 

to explain why the cleaning is available, and I 

understand it's a little bit different with 

aflatoxin and mycotoxins and then the whole 

grain, the broken pieces versus taking out the 

physical pieces in the case of, like, animal 

filth, right? It's a very obvious one-to-one.

 We were just kind of curious. Either 

it's something to go off of or if we are going to 

include aflatoxin with this as a rewrite versus 

two separate documents, we don't want to lose 

where we are with aflatoxin by combining them 

which may be a strategy with the subcommittee. 

Maybe they do need to be two separate documents 

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so that way we don't muddy the waters of 

aflatoxin of somebody new reviewing it and 

thinking that that's a new procedure as well.

 MR. GOMOLL: Let me chime in for a 

second. That has been one of my challenges. 

I've been trying for the last probably at least 

two years now to track down information about 

when the aflatoxin procedure came into practice.

 And I can't find any documentation 

from talks when it happened. I've been looking. 

I've been chatting with people that have been 

around. I just know it's been in place since at 

least the '90s.

 MR. FRIANT: So you got to track down, 

like, Dave or --

MR. GOMOLL: Right. And I know there 

was some information from Bob Lijewski's archives 

about some changes that were made where I know 

there was a recent -- well, at least in terms of 

history, a more semi-recent change to allow 

multiple passes over the cleaner where I think 

originally I think it was one pass. And then the 

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changes made to say, okay, as many passes as you 

want, but we're still only going to test it once.

 MR. GOODEMAN: Yeah. And I think it's 

very fair to say it's over 20 years, right, 

Barry, that this has been in place, the aflatoxin 

recondition?

 MR. GOMOLL: Yeah, in some of the 

research, I did find some writing from Dr. 

Charlie Hurburgh from, like, 1993 it was dated 

where he referenced this aflatoxin reconditioning 

procedure, so at least since then.

 MR. FRIANT: I know Charlie actually 

mentioned to me he was going to try and be on 

today. I don't know if he's here. But I think 

it's fair we could open it to his comments if he 

is here. And I don't see him.

 No, and so I appreciate this. I think 

this is all great feedback and great questions. 

And what I am hearing is we get into the first of 

the new calendar year. We've got some continuing 

work for the subcommittee to address on this one 

which was the whole purpose for bringing it up 

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for discussion today. So I guess any other 

comments, questions, feedback from folks on the 

committee?

 MR. CAPPER: Nick, this is Lee Capper 

with FGIS. Just a comment for clarity. Up above 

where we're talking about responsibility, Bob 

called out the FOM and then later also called out 

the delegated state as applicable. As you're 

preparing this, just make sure that where the 

delegate states are appropriate, that's also 

included.

 MR. FRIANT: Okay. So in the --

definitely in the responsibility section, right?

 MR. CAPPER: Yeah, right there. The 

first part of that highlight says FOMs. But I 

think perhaps it's meaning to say both, field 

office managers and delegate state officials, at 

the top of the second page. Or if it's not, it's 

not.

 MR. FRIANT: I agree, and I think 

that's a good call out because in delegated 

states, it would be their officials more likely 

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correctly. Okay. Yeah, I think we can address 

that too as a subcommittee. Okay, Mr. Chair. I 

think unless there's any other questions or 

comments, the subcommittee has direction on 

continuing forward with this. And we'll keep 

working under our current program.

 MR. KERRIGAN: Okay. Well, appreciate 

everybody's comments and time on this for the 

members of the subcommittee, members of the 

overall GIAC as well as the staff in assisting 

with this. It's been a big help and, like I say, 

a lot of work. And we'll see where we get to 

with it.

 MR. FRIANT: I'll echo those comments 

real quick. A big thanks to the subcommittee 

members for taking extra time. I really do 

appreciate that and a special call out for Barry 

and his work and communications with FDA. Also 

really appreciate that.

 MR. KERRIGAN: Absolutely. Okay. As 

we've discussed, we do not have a quorum. We 

will not have a quorum today. But we do have 

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another opening here for potential for public 

comments before we move in towards the final 

section of our meeting, if there are any. There 

weren't any yesterday. We'll kind of give a few 

brief moments here to see if anybody has anything 

that they'd like to discuss.

 MR. McCLUER: Hey, Matt. I do have 

one follow-up questions from yesterday for Arthur 

regarding the fee reviews that I guess I just 

want to make sure for clarification I was on the 

same page. I always think of the national and 

local tonnage fees, right? The five-year roll in 

average.

 And you're talking reviews. I'm 

assuming it's some of the other fees, the 

Schedule B fees. I mean, some of the things such 

as the -- just like we're talking, the testing, 

aflatoxin testing, and some of those other 

services. Is that correct?

 MR. NEAL: I'm not quite sure I fully 

understand the question.

 MR. McCLUER: The question I'm just --

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I'm following up on a statement that you made and 

I'll go back here. It was you said that -- where 

did I write this down? You said that we're going 

to be reviewing the fees. So you made a 

statement saying reviewing the fees. And so --

MR. NEAL: Yeah, so --

MR. McCLUER: -- I just want to make 

sure when you're saying reviewing the fees I'm 

understanding what particular fees you're going 

to be reviewing.

 MR. NEAL: Yeah, so we'll need to do 

a periodic review of the fees that we have set 

for the services that we provide. The national 

tonnage fee, that formula is set.

 MR. McCLUER: Yeah.

 MR. NEAL: The reality is that we are 

-- we've been operating at a discount for about 

six years now. And so we will not be able to 

continue to provide service at the current fees 

that we have set. I'm not saying anything is 

going to happen.

 Something may not happen. But for the 

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last six years, we've been spending more than 

we're generating in revenue. And so at some 

point, we have to review the fees that we have 

set to do an overall look at what fees we're 

charging for services.

 MR. McCLUER: Correct. So we're not 

talking those fees that are part of the five-year 

rolling average. We're talking the other service 

fees that are -- correct. I mean, is there --

can you give me an example just to make sure what 

we're talking of? What would be an example of 

another fee?

 MS. RUGGLES: Hourly fees, mycotoxin 

fees, appeal fees.

 MR. GOODEMAN: Any kind of unit fees, 

right?

 MR. McCLUER: Okay, okay.

 MR. GOODEMAN: And hourly. And the 

breakdown between non-contract and contract, 

they've been both -- I don't want say the same 

but proportionally the same to one another for 

many years. And so we're due for a look to see 

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if the non-contract rate should be higher or 

lower and if the contract rate should be higher 

or lower respective to our costs for maintaining 

those -- really for maintaining non-contract 

availability.

 MR. McCLUER: Okay. That's what I 

thought and I just wanted to confirm, right, that 

those are the specific type of fees that were 

being referred to. And so reviewing that, will 

that be something that'll be provided to the next 

official advisory committee meeting as part of 

the review, I mean, if there's going to be any --

if you decide to -- I guess if there's a decision 

to be made, whether they're going to increase and 

when will that be announced when we have January 

rulemaking?

 MR. NEAL: Yeah, that's a totally 

different process. There's a lot of education 

and review that has to happen internally inside 

of USDA. And we'll be engaging with industry as 

we embark upon that process.

 So this is not something that's going 

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to happen swiftly. It's not something that's 

going to happen secretly. So just stay tuned. 

We're just sharing with you all kind of where we 

are. That was really the whole point of stating 

it is that we're at a point where we really have 

to review the fees that we have set so we don't 

continue operating at a loss like we are.

 MR. McCLUER: Okay.

 (Simultaneous speaking.)

 MR. GOODEMAN: And Arthur, if we do 

make any changes, that'd be done through 

rulemaking, right?

 MR. NEAL: It'd be done through the 

Federal Register.

 MR. McCLUER: Beforehand, were you 

doing the research and getting feedback from 

stakeholders, correct, before you --

MR. NEAL: Say that again, Jess.

 MR. McCLUER: I said before you go 

into the formal rulemaking process, you'd be 

soliciting feedback from stakeholders to as 

you're going through this review, correct? 

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MR. NEAL: So the process we will be 

working out internally and we'll be communicating 

how we'll proceed because this is the first time 

we'll be doing this, I think, in a very long 

time. It's kind of overall periodically. So how 

we solicit the comments, when we solicit the 

feedback, that piece, we don't have worked out 

just yet. But when we do, we'll engage in a 

dialogue so that folks can have a clear 

expectation of how the process will flow. But it 

will not be done in the dark.

 MR. McCLUER: Okay. No, that's 

helpful. I appreciate that clarification.

 MR. KERRIGAN: I think we have a 

question from Mr. Mark Tess.

 MR. TESS: Yeah, this is Mark Tess 

from Charm Sciences. And I apologize for not 

being on the call yesterday. But I had a comment 

about a procedure and submission guidelines for 

evaluation of technology for the official grain 

inspection. And my question is, does the ITE 

process going to apply to existing quality 

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factors such as mycotoxin testing where there's 

already a procedure in place for validating test 

kits?

 MR. JHEE: No, no. You're already --

MR. TESS: Okay. And that -- sorry, 

go ahead.

 MR. JHEE: Since the mycotoxin test 

kit program is already an established program, it 

doesn't fall within the purview of it.

 MR. TESS: Okay. And that won't 

affect, like, future readers that companies, 

manufacturers may submit. Or my other question 

would be, is it going to affect, like, new 

mycotoxins if FGIS determines that there's a need 

to have a criterion specification for T-2/HT-2 or 

the possibility of ergot alkaloids in the future?

 MR. JHEE: I think we'll probably have 

to address that latter question once that type of 

technology is revealed in terms of being a 

possible use in the industry.

 MR. TESS: Okay.

 MR. JHEE: Tim, any other thoughts 

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from your perspective, Tim Norden?

 MR. NORDEN: Yes, I would say if it's 

a new technology for detecting mycotoxins, 

whether it'd be some kind of beam that you're 

aiming through the grain stream or you're taking 

some grain dust or some brand-new technology, 

that would fall, I think, under the ITE directly. 

But if it falls within our existing mycotoxin 

test kit evaluation program where the -- that 

technology, then we already have that in place. 

So it wouldn't fall under the ITE.

 MR. TESS: Okay. We have several 

different people here reading the purpose and 

scope. And some of us really thought the way 

that you're commenting on this whereas others 

kind of thought it may affect current procedures 

as well. So I don't know if perhaps there needs 

to be better clarification or more clarification. 

Or Charm may just not have been privy to some of 

this information prior to reading this document.

 MR. NORDEN: Yes, Section 4 covers 

that. But we'll read that statement and make 

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sure that -- we make sure that it's clear. It 

says that approvals of rapid mycotoxin and 

biotechnology testing methods are performed 

through the FGIS rapid test kit evaluation 

program.

 And then it says, for more 

information, there's a link there. But I 

understand your point. We could clarify that and 

make it even more transparent there, I think.

 MR. TESS: That is how I interpret it. 

And I appreciate your comment. But I know later 

in the document there was a comment that unless 

specifications already exist. So other people 

read that as could still be implicated in terms 

of following this procedure. So thank you for 

your clarification, though.

 MR. NEAL: And by reminded too that 

this document, once it is released, will be open 

for comment.

 MR. TESS: Thank you.

 MR. NORDEN: Great question. 

Appreciate it. 

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MR. KERRIGAN: Any other comments or 

questions from the field?

 (No audible response.)

 MR. KERRIGAN: I'm not hearing 

anything. I would like to, Arthur, put you on 

the spot a little bit to talk a little bit, to 

explain to the group where we're at as far as the 

committee selection members, just kind of advise 

on timing. We're right in the process. We know 

that it is a long -- can be a long process and 

what that means for our quorum, if you could, 

please.

 MR. NEAL: Great question. We checked 

again this morning. And the nominations are with 

the Secretary. I can't put a definitive time 

frame on the decision. But if I had to guess, 

before our next meeting we should have our new 

members appointed.

 We're at the end of the appointment 

process in terms of him making the selections. 

And so I don't think we'll be faced with the 

current challenge that we are. We're also going 

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to begin working on the new committee charter to 

make sure we're ahead of that timeline.

 And we'll start going out for an 

announcement for new committee members next year 

as well. So we'll have a full slate of work 

ahead of us. But in terms of the five members 

that we need, I believe that we will have them 

appointed before we meet again. That's my 

belief.

 MR. FRIANT: Hey, Arthur, to that 

point, will the -- the selection process, I 

guess, would also include some alternates. I 

know in the past, we would have alternates that 

could fill in if folks were unavailable or 

retired or left the committee or whatever. Will 

we go back to trying to have alternates in the 

future do you think?

 MR. NEAL: Great question. Based on 

legal review that we've received, the alternates 

are not authorized by statute. And so we've been 

informed that we can no longer do alternates.

 MR. FRIANT: Okay. Thanks for sharing 

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that. I appreciate that.

 MR. KERRIGAN: Thanks, Arthur. I just 

got a question back. It is regarding the 

discussion yesterday with AMS Transportation and 

the -- how this group might be able or FGIS might 

be able to assist with some of these shuttle 

train rail transportation scheduling.

 Obviously the STB is tackling a lot of 

it. But comments are always welcome. And I 

guess there's kind of an open question to this 

group or to FGIS as far as what we can or can't 

do or should or should not do maybe, whether it'd 

be from FGIS, whether it'd be from the GIAC, if 

that's something we take up, if that could be in 

a recommendation or if there's any thoughts on 

that, I guess.

 MR. NEAL: I'll speak just from a 

general perspective. National Grain and Feed 

Association works very closely with 

transportation and marketing on filing comments 

on behalf of ag shifters as it pertains to these 

type of ag transportation issues. However, 

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everybody here may not be a part of NGFA.

 At the same time, as you saw 

yesterday, the transportation and marketing team, 

not familiar with everybody either that's 

represented in this meeting. And the on the 

ground examples helps them gain a better 

perspective and insight to the issues so that 

they can help convey concern to the surface 

transportation or along with National Grain and 

Feed and others. A lot of the other are producer 

associations that participate in those 

proceedings that the Surface Transportation Board 

facilitates around these ag transportation 

issues.

 I would encourage folks that if you 

got data, if you're collecting data concerning 

the impact of transportation on the agricultural 

operations, begin collecting it and sharing it 

with those who are commenting on behalf of 

agriculture. And particularly, you may want to 

start engaging that process too as a GIAC or as 

individual committee members and represent your 

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organizations or with NGFA because they've been 

carrying this torch for a while.

 And I think it's a difficult situation 

to break through in terms of getting more 

transparency. But we never know when we will 

break through with the right type of engagement 

and data. So that's just a general comment that 

I have because the more people that understand 

the impact that it's having, you never know what 

type of outcome it may yield in the 

deliberations.

 MR. McCLUER: And Arthur, thank you 

very much for that, for your work on this issue. 

We do have a Rail Shipper/Receiver Committee. 

And in fact, we're in the process right now of 

drafting comments to submit to STB on the first 

mile/last mile issue.

 And many of the topics that were 

discussed yesterday regarding the metrics, right, 

I know that Jimmy brought up regarding the 

metrics. A lot of those issues are being 

addressed in those comments that'll be submitted. 

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So you are correct. We're very much involved in 

this.

 We have several transportation-related 

committees within the association. So if there 

is any -- and I think many of the issues that are 

raised, as you said, are very important to our 

members. And so I think any additional as Arthur 

mentioned, any of the non-NGFA members that are 

on here that participate in the advisory 

committee or stakeholders that are participating, 

anything that you want to submit to the STB, we'd 

be happy to address maybe some of the questions 

that you may have on some of these issues.

 MR. NEAL: I know you didn't ask that 

directly. That's really a decision you'll all 

have to deliberate on. But the reality is that 

data is key in this process. And the more 

economic impact that can be demonstrated, I think 

the better off and the stronger the arguments are 

for greater transparency in the process that we 

know has been impacting action.

 MR. KERRIGAN: I appreciate those 

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comments, Arthur and Jess both. And I, Arthur, 

you keyed in on something that this group does 

more there. It's made up of more than just grain 

shippers that may be an NGFA member.

 I think my recommendation on this 

given that it seems to get getting a lot more 

traction, we know that things don't happen 

quickly, is maybe we put this as a tentative 

agenda item for the next meeting if we're going 

to have one in the spring to discuss if there is 

a role, what that role would look like from the 

GIAC given our broad membership on the committee 

itself to either pull in support, information, 

and questions that may already be out there. Or 

if there's anything that we can help groups or 

even the GIAC itself gather data and information 

to submit as well. Speaking of agenda items for 

the next meeting, we know that the FGIS FDA MOU 

subcommittee will continue work and will likely 

be on the next meeting as well.

 Are there any other topics that 

anybody can think of that we want to make sure at 

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this point in time that make it to the meeting or 

we'll want to consider for the meeting? The 

group itself will likely have a call for agenda 

items prior to the Federal Register notice as 

well. But I did want to give others the 

opportunity while we all are here together to 

bring something up. Janice?

 MS. COOPER: We traditionally get a 

report on progress on implementing prior 

recommendations from the committee. And I know 

we worked on several of those action items. But 

it would just be nice to do a recap of former 

recommendations and what the status is. I think 

that's usually an agenda item. So we'd just like 

to see that back next time.

 MR. KERRIGAN: Okay. Anything else? 

Did your hand come back up again, Janice? I 

looked down for a second there.

 (No audible response.)

 MR. KERRIGAN: Okay. With that, 

again, I want thank Janice is the vice chair of 

this committee, Nick who's the secretary of this 

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committee, as well as the rest of the members for 

the robust discussion, the ongoing work outside 

of just this day and a half meeting here. 

Obviously, it takes time. It takes effort on a 

volunteer basis.

 So I do want to thank the group. I 

want to thank FGIS staff as well as all of the 

other members who are probably not on today who 

you did line up to speak and give some updates to 

the group as well as the other -- we're up to 65 

total participants here, group and the peanut 

gallery, so to speak, who chimed in to learn as 

well as discuss and bring items to our attention. 

So any closing comments from Arthur or anybody 

else?

 MR. NEAL: I just want to commend the 

committee on its focus and dedication and 

commitment and your attention. During virtual 

meetings, it's not always the easiest. But I 

mean, I really appreciate everybody's attention 

and engagement on the topics.

 I appreciate the comments that were 

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offered on the items that were on the agenda. I 

do believe our next meeting will be more fruitful 

from the standpoint of participation, 

recommendations. The goal is to be hybrid where 

we're in person and virtual next meeting.

 Let's all send positive thoughts 

across the countries that Omicron does not take 

legs and grow so that we can engage in a more 

familiar way. I just want to say that it's an 

honor and a pleasure to be a part of this 

industry. NEAGA had a meeting down in New 

Orleans and celebrated resilience of the grain 

industry.

 And I can honestly say that this is a 

resilient body. And we are glad to serve you. 

We look forward to continuing to work 

collaboratively with you.

 And we've still got challenges ahead 

of us. But I believe we're going to work through 

each and every one of them successfully as we 

dialogue and keep lines of communication open and 

keep open minds. So I appreciate how you all 

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have supported FGIS, and we will continue to do 

our very best to support you. Thank you.

 And I want to thank Kendra as well for 

helping to organize the meeting. It's a lot that 

goes on behind the scenes. And she is a 

perfectionist at times.

 And so it can get a little stressful. 

So we thank Kendra for all of her effort and we 

thank all of the division directors and staff for 

their contributions to updates on activities at 

FGIS. Thank you all.

 MR. KERRIGAN: Anybody else?

 (No audible response.)

 MR. KERRIGAN: With that, I'll 

entertain a motion to adjourn this meeting.

 MR. AYERS: So moved.

 MR. KERRIGAN: We've got several of 

them. All right. You get a big part of the day 

back for everybody. Thank you very much, and 

we'll see you on the next go around.

 (Whereupon, the above-entitled matter 

went off the record at 12:12 p.m.) 

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ability 12:4,13 

able 6:6,6,8,10 26:11 

27:4 42:18 52:5,6 

above-entitled 60:21 

absolutely 30:21 40:20 

accept 19:11 

account 10:13 

accurate 26:10 

acting 8:15 

action 14:15,17 19:7,21 

20:10 55:21 57:11 

actionable 6:17 7:7 9:8 

9:10 10:5,17 11:3,12 

12:5,11 13:1,19 14:6 

24:13 33:2 

actions 26:8 

activities 60:10 

actual 6:11 21:15 

add 16:3 21:1 

added 32:10,13 

addition 28:1 

additional 11:3 18:11 

21:15 32:20 33:9 55:7 

additions 31:9 

address 24:14 26:17 

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55:12 

addressed 54:22 

adjourn 60:15 

Administrator 2:15 

advise 50:8 

advisory 1:3 6:13 15:16 

18:10,12 44:11 55:9 

advocates 16:8 

affect 47:11,13 48:16 

aflatoxin 10:10,16 

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ag 52:21,22 53:13 

agencies 8:9 13:21 

agency 13:12 

agenda 5:13 18:5 56:9 

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ago 10:1,2 

agree 34:14 39:20 

agreed 35:13 

agricultural 2:14 53:17 

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ahead 4:8 6:1 47:6 51:2 

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aiming 48:5 

alkaloids 47:16 

alleviate 27:1 

allow 37:20 

allowed 36:2 

alluded 9:7 

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and/or 18:14 

animal 10:8,13 11:14 

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animals 24:4,13,20 

announced 44:15 

announcement 9:21 

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answer 17:14 20:18 

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anybody 30:22 41:5 

56:22 58:14 60:12 

apologize 46:17 

appeal 43:14 

appear 24:2 

applicable 39:8 

applicant 12:22 

application 21:7 

apply 23:18 46:22 

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appointment 50:19 

appreciate 9:1,2 20:13 

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approach 17:18 

appropriate 25:5,6 

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approvals 49:2 

approved 6:16 9:13 

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archives 37:17 

arguments 55:19 

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asked 34:8 

assess 20:8 

assist 52:6 

assisting 40:10 

association 52:19 55:4 

associations 18:22 

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assuming 14:18 41:15 

assumption 25:10,12 

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attention 58:13,18,20 

attract 31:11 

audible 4:15,17 5:1,9 

50:3 57:19 60:13 

authorized 51:20 

availability 44:5 

available 36:10 

average 41:13 43:8 

aware 30:11 34:22 

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60:16 

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back 5:11 14:9 18:10 

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backing 21:2 

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basically 10:20 11:1 

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basis 6:18 34:21 35:12 

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belief 51:9 

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beneficial 30:2 

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better 10:4 48:18 53:6 

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bins 35:18 

biotechnology 49:3 

bit 11:19 22:13 23:15 

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body 19:22 59:15 

body's 20:1 

brand-new 48:6 

break 54:4,6 

breakdown 43:19 

brief 41:5 

bring 13:15 57:7 58:13 

bringing 15:15 38:22 

broad 56:12 

broader 14:9 20:21 

broadly 25:3 

broken 35:21,21 36:13 

brought 54:20 

bunch 35:18 

business 19:9,12 25:11 

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Caledonia 1:13 

calendar 38:20 

call 3:11 4:8 5:19 7:2 

11:7 24:22 27:6,12 

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46:18 57:3 

called 39:7,7 

Capper 2:11 39:4,4,14 

captured 29:7 

Cargill 1:16 

cargo 26:16 

carry 28:6 

carrying 15:18 28:19 

54:2 

case 14:8 23:7 36:14 

caught 7:2 

celebrated 59:12 

Center 1:14 

certainly 14:11 27:10 

CFSAN 7:21 

Chad 1:13 4:18 

chain 28:13 

chair 1:7 3:12,15 6:2,21 

17:2 40:2 57:21 

chairman 18:1,6 

challenge 50:22 

challenges 37:5 59:18 

CHAMBERS 1:13 4:19 

Champaign 1:11 

chance 12:18 

change 13:3,10,15 

29:18 30:4 32:7,11 

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changed 32:5 

changes 8:11 31:9,11 

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changing 30:4 

channels 8:8 25:20 

charging 43:5 

Charlie 38:9,12 

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charter 51:1 

chatting 37:11 

checked 50:13 

Chief 2:11 

chime 37:4 

chimed 58:12 

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clarity 39:5 

clean 26:11,13,16,22 

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cleaner 12:9 13:1,2 

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cleaners 12:14,17 

cleaning 25:5,5 36:1,10 

cleanings 25:14 

clear 29:8 30:18 31:9 

46:9 49:1 

clearly 17:11 31:19 

33:4 

closely 52:19 

closing 58:14 

collaboratively 59:17 

collecting 53:16,18 

combining 36:20 

come 15:12,21 57:17 

comes 8:20 

coming 30:22 

commend 58:16 

comment 29:7 34:12 

39:5 46:18 49:11,12 

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commenting 48:15 

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comments 3:17 5:22 

14:12 20:20 27:11 

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commitment 58:18 

committee 1:3,9 6:12 

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committee's 16:14 

committees 17:5,6 55:4 

communicating 30:7 

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communication 59:21 

communications 40:18 

companies 47:11 

company 1:15 11:12 

comparison 33:10 

complete 19:18 21:14 

completed 19:18 

concentration 35:22 

concept 12:7 21:3 

concepts 16:1 20:6 

concern 28:13 53:8 

concerned 26:10 

concerning 53:16 

concrete 8:7 

condition 10:11 

conditions 12:8 

conduct 19:9 

confirm 44:7 

conflicts 5:10 

consider 12:2 18:12 

22:13 23:1 57:2 

considered 7:6 19:12 

considering 15:3 28:16 

consisted 6:20 

consistency 30:3 

consistent 13:4 33:3 

constraints 28:17 

consumed 24:4 

contact 26:4 

containing 35:22 

continue 20:3 42:19 

45:7 56:19 60:1 

continued 9:2 

continuing 7:20 19:10 

38:20 40:5 59:16 

contract 43:19 44:2 

contributions 60:10 

conversations 15:9 

16:1 

convey 30:10 53:8 

conveyed 29:1 

COOPER 1:14 4:13 

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34:3 57:8 

copied 32:8 

corn 12:17 35:21 

correct 9:21 41:19 43:6 

43:9 45:17,22 55:1 

correctly 40:1 

costs 44:3 

countries 59:7 

country 21:9 

couple 4:6 10:1,2 11:7 

cover 13:19 14:5 28:21 

29:13 33:19 

covered 30:14 34:4 

covers 35:1 48:21 

criterion 47:15 

critical 30:1 

curious 16:15 36:16 

current 7:5 10:15 14:2 

18:17 19:2 27:18 34:9 

40:6 42:19 48:16 

50:22 

currently 4:5 13:18 

14:1 35:1 

Curt 4:20 6:22 

CURTIS 1:15 

curve 30:5 

cut 14:1 27:17 

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damage 10:10 22:10,19 

Danville 1:11 

dark 46:11 

data 53:16,16 54:7 

55:17 56:16 

date 19:7 

dated 38:9 

Dave 6:21 37:15 

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day 58:3 60:18 

deal 11:16 

dealing 26:13 

debate 30:18 

DECEMBER 1:5 

decide 44:13 

decision 44:13 50:16 

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dedication 58:17 

deer 10:9 

defend 25:5 

definitely 8:17 16:7 

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definitive 50:15 

delegate 39:10,17 

delegated 39:8,21 

deleterious 10:11 

deliberate 55:16 

deliberations 54:11 

Demonstrate 33:1 

demonstrated 55:18 

DENISE 2:17 

Department 1:1,21 

depending 8:2 

deputized 28:15 

Deputy 2:15 

desire 29:2 

detecting 48:3 

determine 7:7 

determines 47:14 

develop 6:15 

developed 14:8 19:6 

developing 18:18 

dialogue 19:5 20:5 46:9 

59:21 

differences 31:22 

different 34:11 36:11 

44:18 48:13 

difficult 54:3 

digest 29:5 

digested 24:3 

direct 12:4 

direction 40:4 

directly 11:13,18,20 

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26:20 29:17 48:7 

55:15 

directors 60:9 

discount 42:17 

discuss 5:20 22:12 

41:6 56:10 58:13 

discussed 16:2 40:21 

54:19 

discussing 14:21 34:20 

discussion 3:14 5:14 

7:16 10:9 12:12 13:12 

14:13 17:17 31:7 

32:20 34:13 39:1 52:4 

58:2 

discussions 7:18 8:16 

9:4 15:9 29:16 

disposal 26:2 

disposed 25:15 

disposition 14:4 26:7 

27:10 

dissension 16:13 

diversion 12:1 

divert 11:13 

diverted 23:9 25:15,22 

diverting 24:12 

division 2:12,13 60:9 

DLQ 10:12 

document 19:8 25:18 

27:7 30:10 31:8 32:7 

32:12 33:10 34:9,9,22 

48:20 49:12,18 

documentation 37:9 

documents 27:16 36:19 

36:22 

dogs 8:14 

doing 7:15 19:17 45:16 

46:4 

domestic 13:20 

Dr 38:8 

draft 9:19 10:19 18:3,18 

drafting 54:16 

droppings 10:9 

due 11:12 43:22 

dust 48:6 

E

early 8:18 

easier 32:2 

easiest 58:19 

echo 40:14 

economic 55:18 

ED 2:13 

editorial 32:3 

education 44:18 

effort 58:4 60:8 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
63 

EGT 1:17 

either 19:21 29:16 

31:11 36:16 53:4 

56:13 

elect 11:13 

elected 23:9 

Elevator 1:13 

elevators 11:4 

eligible 13:6 

embark 44:21 

embarrass 34:15 

encourage 53:15 

endorse 16:16 19:21 

engage 46:8 59:8 

engagement 54:6 58:21 

engaging 15:22 44:20 

53:21 

Engel 1:15 4:20,21 6:22 

entertain 60:15 

entertaining 20:6 

entire 14:18 

ergot 47:16 

especially 8:19 

essence 6:14 

essentially 10:15 13:17 

13:20,22 14:4 18:16 

EST 1:6 

established 35:13 47:8 

evaluation 46:20 48:9 

49:4 

everybody 4:4 6:4 21:2 

34:16 53:1,4 60:19 

everybody's 40:8 58:20 

example 12:17 28:2 

43:10,11 

examples 53:6 

Excellent 8:22 

excreta 10:13 

Executive 2:17 

exist 49:13 

existing 31:7 32:4 

46:22 48:8 

expanded 13:19 25:21 

expanding 14:5 

expectation 46:10 

explain 36:10 50:7 

explains 28:22 

explanation 34:6 

extra 40:16 

eye 5:12 28:13 

F

faced 50:21 

facilitate 20:4 28:11 

29:9 

facilitates 53:13 

facilitating 16:1 30:3 

facility 6:16 11:16 

12:16 

fact 54:15 

factors 47:1 

fair 18:15 38:4,15 

fall 47:9 48:7,11 

falls 48:8 

familiar 11:22 12:14 

53:4 59:9 

far 21:12 50:7 52:11 

Farmers 1:13 

FDA 5:15 6:2,17 7:6,15 

7:20 9:2 13:13 14:21 

15:9,13,17 16:8,20 

17:8,9,12,18 18:21 

20:5 21:6,16 22:4 

23:6,13 24:18 25:10 

26:5,13,21 29:18 

30:19,22 32:2 33:1,15 

33:16,22 40:18 56:18 

FDA's 29:9 

Federal 45:14 57:4 

fee 41:9 42:14 43:12 

feed 11:14,18,20 12:5 

22:3 23:10 25:16,22 

33:5 52:18 53:10 

feedback 15:13,17 

17:17 18:9 19:11 

22:17 25:8 38:18 39:2 

45:16,21 46:7 

feel 20:8 

fees 41:12,15,16 42:4,5 

42:8,9,12,19 43:3,4,7 

43:9,13,14,14,15 44:8 

45:6 

feet 12:1 

FGIS 2:15 5:15 6:2 7:6 

7:10 13:7,12,16,16 

14:20 21:14,15 29:8 

30:22 33:22 39:5 

47:14 49:4 52:5,11,13 

56:18 58:7 60:1,11 

FGIS-FDA 3:14 

field 2:12 39:16 50:2 

figure 8:7 

filing 52:20 

fill 51:14 

filth 10:8 36:15 

final 41:2 

finalize 29:3 

find 37:9 38:8 

fine 21:17 28:7 

first 12:22 38:19 39:15 

46:3 54:16 

fit 10:16 11:2 28:18 

five 26:14 51:6 

five-year 41:12 43:7 

flexibility 11:19 

flow 46:10 

focus 27:4,5 58:17 

focused 22:10 

folks 9:18 11:21 12:14 

14:10 39:2 46:9 51:14 

53:15 

follow 26:20 

follow-up 41:8 

following 10:20 29:20 

42:1 49:15 

follows 13:7 

FOM 39:7 

FOMs 39:15 

food 25:19 28:12 33:4 

34:22 

Foods 1:20 

foreign 10:12 

formal 15:6,10 45:20 

formed 6:19 21:3 

former 6:14 57:12 

forming 18:18 

formula 42:14 

forum 16:18 

forward 30:19 40:5 

59:16 

found 11:8,11 

frame 50:16 

frankly 27:5 

free 26:16,22 

Friant 1:16 3:15 5:5 6:3 

7:12 8:22 9:18 10:2 

15:21 16:5,22 18:13 

19:10,15 20:12,15 

22:7,16,22 23:12 24:6 

24:9,16,22 25:17 26:4 

26:7,18 27:3,9,15,22 

29:6 30:13,17 31:10 

31:12,15 32:17 34:14 

35:6,11 37:14 38:12 

39:12,20 40:14 51:10 

51:22 

front 9:3 16:22 33:16 

34:16 

froze 24:6,9 

frozen 24:8,11 

fruitful 59:2 

full 11:21 13:6 18:10 

19:19,20 51:5 

fully 20:2 41:20 

further 17:17 22:13 

25:21 

future 47:11,16 51:17 

G

gain 53:6 

gallery 58:12 

garner 20:7 

gather 56:16 

gauge 20:5 

general 25:11 52:18 

54:7 

generate 20:3 

generating 43:2 

getting 23:15 45:16 

54:4 56:6 

GIAC 3:12 40:10 52:13 

53:21 56:12,16 

give 41:4 43:10 57:5 

58:9 

given 7:13 56:6,12 

gives 29:14 

glad 59:15 

goal 34:13 59:4 

GOMOLL 7:11,17 37:4 

37:16 38:7 

GOODEMAN 2:12 16:3 

16:6 25:12 26:3,6,9 

26:20 27:8 35:9,14 

36:5 38:3 43:15,18 

45:10 

Grades 17:2,3 18:1,7 

grain 1:3,11,18 6:17 

10:10,12 11:4,12 12:8 

12:9 13:5 15:15 18:1 

18:7 22:2,19 25:10 

26:22 27:1,4 36:13 

46:20 48:5,6 52:18 

53:9 56:3 59:12 

grains 29:10 

greater 55:20 

ground 53:6 

group 5:14 11:6 13:15 

14:19 50:7 52:5,11 

56:2 57:3 58:6,10,11 

groups 20:7 56:15 

grow 59:8 

guess 8:3 14:8,12 

18:14 21:4 32:9 35:4 

39:1 41:9 44:13 50:16 

51:12 52:10,16 

guessing 35:16 

guidance 29:15 

guidelines 46:19 

H

half 58:3 

hand 19:19 57:17 

handbook 10:21 14:3 

handle 26:16 34:11 

happen 42:21,22 44:19 

45:1,2 56:7 

happened 37:10 

happening 23:22 

happy 55:12 

head 19:1 

health 24:17 

hear 5:11 6:5 8:20 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
64 

15:14 17:10,13 23:17 

33:13 

heard 29:12 33:13 

hearing 16:9 20:2 33:12 

38:19 50:4 

help 16:7,19 28:5,11 

29:9 40:11 53:8 56:15 

helpful 16:10,14 31:8 

46:13 

helping 60:4 

helps 30:4 53:6 

Hey 41:7 51:10 

high 35:17 

higher 35:22 44:1,2 

highlight 39:15 

highlighted 23:6 

history 37:20 

hit 8:4 

hold 8:12 

honestly 59:14 

honor 28:16 59:10 

hopefully 9:13,18 

hourly 43:13,18 

human 24:15 25:19 

28:14 34:21 

humans 24:4 

hundred 34:14 

Hurburgh 38:9 

hybrid 59:4 

I

idea 21:14 

identified 20:19 

IDK 11:12,17 21:22 

ignorance 34:7 

impact 24:15,19 53:17 

54:9 55:18 

impacting 55:21 

implementing 57:9 

implicated 49:14 

importance 33:18 

important 11:9 30:1 

55:6 

importantly 11:19 

include 36:18 51:12 

included 39:11 

inconsistent 21:7 

increase 44:14 

individual 53:22 

industry 8:11,12 15:10 

15:12,14,17 16:9 

17:10,13 20:4 26:10 

31:1 44:20 47:20 

59:11,13 

information 37:7,17 

48:20 49:7 56:13,16 

informed 51:21 

initial 18:3 

Innovation 2:11 

input 17:5,16 18:11 

20:4,8 

insect 10:10 22:10,19 

inside 44:19 

insight 53:7 

inspection 1:3,11,18 

13:6 15:16 46:21 

inspections 13:7,8 17:3 

Integrity 2:16 

intend 29:5 

intention 7:4 17:4 32:22 

interested 17:16 

internally 44:19 46:2 

interpret 49:10 

introduction 33:20 

involved 55:1 

issue 15:15 26:17 33:5 

35:15 54:13,17 

issues 52:22 53:7,14 

54:21 55:5,13 

it'd 16:9,14 45:13 48:4 

52:12,13 

ITE 46:21 48:7,11 

item 12:11 56:9 57:14 

items 7:6 9:9,10 10:4 

10:17 11:3 13:20 14:7 

21:15 25:4 33:2 56:17 

57:4,11 58:13 59:1 

J

Janice 1:14 4:12 31:17 

32:18,22 33:14 57:7 

57:17,21 

January 44:15 

Jess 18:13 45:18 56:1 

JHEE 2:13 47:4,7,17,22 

Jimmy 1:21 4:14 54:20 

join 5:4 

K

keen 28:13 

keep 5:12 40:5 59:21,22 

Kendra 2:14 9:14,20 

24:10 60:3,8 

kernels 22:10 35:22 

Kerrigan 1:7,17 3:12 

4:3,12,14,16,18,20,22 

5:2,7,10 14:16 18:6 

21:1 32:6 34:19 36:3 

36:7 40:7,20 46:14 

50:1,4 52:2 55:22 

57:16,20 60:12,14,17 

key 8:4 17:12 55:17 

keyed 56:2 

kit 47:8 48:9 49:4 

kits 47:3 

KLINE 2:14 9:17,22 

knowing 16:10 23:13 

32:9 

Kuhl 1:18 4:22 6:22 

L

lack 10:4 

laid 35:3 

landfill 26:1 

lane 24:1 

language 29:11 31:6 

34:10 

large 10:13 

lay 34:21 

leads 21:22 22:19 

learn 58:12 

learning 30:5 

Lee 2:11 39:4 

left 8:14 51:15 

legal 51:19 

legs 59:8 

let's 6:14 59:6 

letter 29:13 33:19 

light 15:1 

Lijewski's 37:17 

line 58:9 

lines 29:14 59:21 

link 49:7 

list 4:9 

listed 14:1 

listening 21:2 

little 11:19 22:13 23:15 

23:17 27:21 36:11 

50:6,6 60:7 

LLC 1:17 

local 41:12 

locations 13:20 

long 35:7 36:5 46:4 

50:10,10 

longer 51:21 

look 6:10,15 7:5 43:4 

43:22 56:11 59:16 

looked 9:8,8 57:18 

looking 24:18 28:7 

37:10 

looks 4:9,10 5:3 

loose 28:17 

lose 36:19 

loss 45:7 

lot 6:17 8:11 11:11,13 

12:5 13:1 16:12 21:22 

22:18 24:13 27:2 31:6 

31:22 40:12 44:18 

52:8 53:10 54:21 56:6 

60:4 

lots 34:11 

lower 44:2,3 

M

main 19:8 

maintain 28:13 

maintaining 44:3,4 

making 25:9 50:20 

man 24:10 

Management 2:12 

managers 39:17 

manufacturers 47:12 

Mark 46:15,16 

marketing 1:14 2:14 

52:20 53:3 

Matt 6:4,21 18:6,13 

32:19 33:7 41:7 

Matt's 34:11 

matter 10:12 33:21 

60:21 

Matthew 1:7,17 3:12 

McCLUER 17:21 41:7 

41:22 42:7,15 43:6,17 

44:6 45:8,15,19 46:12 

54:12 

mean 16:22 17:1 20:15 

22:18 41:16 43:9 

44:12 58:20 

meaning 39:16 

means 16:19 50:11 

mechanical 12:14 13:2 

meet 51:8 

meeting 1:6 6:9,11,13 

7:19 8:17,21 9:21 

14:11 18:4 20:11 41:3 

44:11 50:17 53:5 56:9 

56:18,20 57:1,2 58:3 

59:2,5,11 60:4,15 

meetings 58:19 

member 18:6 56:4 

members 7:20 18:9 

20:16 40:9,9,16 50:8 

50:18 51:4,6 53:22 

55:7,8 58:1,8 

membership 56:12 

mentioned 6:21 31:6 

38:13 55:8 

messages 8:3 

methods 49:3 

metrics 54:19,21 

middle 11:10 

midst 30:4 

mile 54:17 

mile/last 54:17 

mind 27:13 33:5 

minds 59:22 

minutes 4:6 

Missouri 1:21 

model 21:10 

modified 11:2 

modify 10:16 19:21 

molds 21:22 22:19 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
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moments 41:5 

months 29:19 

morning 4:3 7:10 20:17 

50:14 

morning's 6:11 

motion 60:15 

MOU 3:14 5:15 6:2 7:6 

7:7,15 9:8 56:18 

move 6:14 26:22 27:4 

41:2 

moved 22:2 60:16 

muddy 37:1 

multiple 12:13 13:2,4 

13:19 37:21 

mute 8:5 

mycotoxin 10:21 14:3 

22:9,14 43:13 47:1,7 

48:8 49:2 

mycotoxins 21:21 22:1 

22:6 36:12 47:14 48:3 

N

national 41:11 42:13 

52:18 53:9 

nature 28:17 

NEAGA 16:15 17:3,11 

17:15 59:11 

NEAL 2:15 15:1 19:4,13 

19:16 20:14 23:4,19 

24:8,10,17 27:13,20 

28:3 29:22 30:15 31:3 

41:20 42:6,11,16 

44:17 45:13,18 46:1 

49:17 50:13 51:18 

52:17 55:14 58:16 

necessarily 11:20 

14:15 25:22 28:10,15 

need 9:15 11:5 15:14 

21:20 23:17 24:4,13 

25:3,4 28:9 29:2 33:9 

33:11,14 36:22 42:11 

47:14 51:7 

needed 21:5 25:2 

needing 22:4 

needs 22:5 25:20 30:9 

48:17 

never 54:5,9 

new 12:3 32:7,12 37:2,3 

38:20 47:13 48:3 

50:17 51:1,4 59:11 

NGFA 17:2,11,15 53:1 

54:1 56:4 

nice 57:12 

NICHOLAS 1:16 

Nick 3:15 4:6,7,8 5:3,16 

6:1 7:11 14:16 16:4 

17:21 21:18 23:4 

25:12 27:13,21 35:10 

39:4 57:22 

nine 29:19 

nominations 50:14 

non-contract 43:19 

44:1,4 

non-NGFA 55:8 

Norden 2:16 48:1,2,21 

49:21 

Northern 1:18 

notice 57:4 

notify 22:4 

number 12:21 

O

observation 21:13 

obvious 36:15 

obviously 13:19 14:17 

52:8 58:4 

offered 59:1 

office 21:8,8 26:5 39:17 

Officer 2:11,16 

official 13:21 14:14 

44:11 46:20 

officially 12:19 15:12 

officials 39:17,22 

Omicron 59:7 

once 5:18 8:6 15:11 

38:2 47:18 49:18 

one-to-one 36:15 

ones 9:11 

ongoing 58:2 

open 5:21 13:11 14:11 

20:5 27:10 38:15 

49:18 52:10 59:21,22 

opening 41:1 

operate 19:1 

operating 18:17 42:17 

45:7 

operations 53:18 

opportunity 18:8 57:6 

order 1:6 3:11 

organizations 16:17 

54:1 

organize 60:4 

original 13:6 

originally 37:22 

Orleans 59:12 

outcome 54:10 

outside 58:2 

overall 7:14 12:3 25:3 

40:10 43:4 46:5 

oversight 28:19 

P

P-R-O-C-E-E-D-I-N-G-S

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p.m 60:22 

packaged 29:4 

page 3:9 27:14 39:18 

41:11 

paragraph 21:19 23:6 

part 8:18 9:20 10:14 

12:22 15:6 26:17 34:1 

39:15 43:7 44:11 53:1 

59:10 60:18 

participants 58:11 

participate 53:11 55:9 

participating 55:10 

participation 59:3 

particular 23:6 42:9 

particularly 10:9 53:20 

pass 12:22 37:22 

passed 24:3,21 

passes 12:13 13:4 

37:21 38:1 

paste 14:2 27:17 

pasted 32:8 

peanut 58:11 

peanuts 8:10 

people 17:1 20:8 24:19 

29:18 37:11 48:13 

49:13 54:8 

percent 26:14,14 34:14 

perfectionist 60:6 

performed 49:3 

periodic 42:12 

periodically 46:5 

person 3:12 33:22,22 

59:5 

perspective 18:15 19:3 

19:6 23:20 48:1 52:18 

53:7 

pertains 52:21 

pertinent 7:16 

phone 20:17 

physical 36:14 

pick 16:15 

piece 12:20 14:4 22:9 

22:14 33:12 46:7 

pieces 36:13,14 

place 9:5,12 33:3,6 35:8 

37:12 38:5 47:2 48:10 

Plains 1:18 

plan 10:7,11,15,21 

28:18 

plans 6:16 7:8 8:1 9:5 

21:7 

please 16:5 35:10 50:12 

pleasure 59:10 

point 17:12 30:14 32:18 

34:18 43:3 45:4,5 

49:8 51:11 57:1 

points 11:7 

policy 7:21 13:8,10 

31:7,22 

portion 26:13 27:6 

position 13:11 16:11 

positive 59:6 

possibility 7:22 47:16 

possible 47:20 

posted 9:22 10:19 

potential 13:9,10 41:1 

potentially 13:13 17:18 

24:3,13 

practice 37:8 

pre- 6:15 9:12 35:3 

pre-approved 7:8,22 

9:5 10:6,11,15 

preamble 29:13 33:19 

34:5,20 36:9 

preparation 13:22 

preparing 39:9 

prescriptive 11:22 

present 28:9 31:21 

Presiding 1:7 

pretty 4:9 16:8 21:18 

prevent 15:22 

preventing 19:4 

previous 13:5,10 20:10 

27:14 

prior 14:10 48:20 57:4,9 

privy 48:19 

probably 13:14 14:13 

23:13,15 25:9 28:21 

31:18 35:16,16 37:6 

47:17 58:8 

problem 19:16 27:2 

procedural 14:22 18:14 

19:3 

procedure 12:15 13:5 

13:21 32:16 35:13,19 

37:3,8 38:11 46:19 

47:2 49:15 

procedures 12:4 13:16 

21:4,12 27:7,19 35:2 

48:16 

proceed 46:3 

proceedings 53:12 

process 9:6 10:14 

11:22 12:10 44:18,21 

45:20 46:1,10,22 50:9 

50:10,20 51:11 53:21 

54:15 55:17,20 

producer 53:10 

program 2:17 40:6 47:8 

47:8 48:9 49:5 

progress 16:2 57:9 

prompting 36:1 

proportionally 43:21 

proposals 20:19 

proposed 34:10 

proposing 13:3 31:21 

33:2 

proves 36:8 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
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provide 42:13,19 

provided 44:10 

providing 17:16 

public 3:17 5:22 10:1 

10:19 41:1 

pull 6:11 34:17 56:13 

purely 22:9 

purpose 15:15 38:22 

48:13 

purposes 31:7 

pursue 17:8 

purview 47:9 

push 16:20 

pushed 8:11 

put 7:12 14:18 18:4 

35:2 50:5,15 56:8 

Q

qualified 21:20 22:5,21 

quality 46:22 

question 14:22 16:18 

22:8 23:4,12,16 30:18 

31:5 32:9,19 33:7,10 

34:8,19 35:6 36:8 

41:21,22 46:15,21 

47:12,18 49:21 50:13 

51:18 52:3,10 

questions 14:12 20:17 

20:20 38:18 39:2 40:3 

41:8 50:2 55:12 56:14 

quick 7:9,14 16:4 40:15 

quickly 56:8 

quite 41:20 

quorum 5:20 15:4,11 

40:21,22 50:11 

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rail 52:7 54:14 

raise 17:19 

raised 55:6 

rapid 49:2,4 

rate 44:1,2 

read 11:5 48:22 49:14 

readers 47:11 

reading 48:13,20 

real 7:9 16:4 40:15 

reality 42:16 55:16 

realize 32:7 

reason 24:14 29:2 

reasonably 9:11 

recap 57:12 

received 51:19 

receiving 8:2 

receptive 8:2,6 

recognize 13:9 

recommend 14:19 

recommendation 6:12 

6:19 14:21 15:7 18:17 

19:2 52:15 56:5 

recommendations 5:21 

57:10,13 59:4 

recommending 23:11 

recondition 38:6 

reconditioned 25:13 

27:1 

reconditioning 6:16 7:8 

9:5,12 10:7,20 11:2 

11:14,17 12:3,15 14:2 

21:4,7 22:3 23:10 

25:6 27:18 35:12,19 

38:10 

record 60:22 

reduce 30:5 

reenter 25:19 

referenced 38:10 

referred 44:9 

regarding 5:14,15 

14:17 22:5 41:9 52:3 

54:19,20 

regards 21:21 

Register 45:14 57:4 

regraded 12:19 

regroup 33:12 

reiterate 28:5 

reject 19:21 

released 49:18 

remember 12:16 

reminded 49:17 

remove 11:17 12:11 

replicate 21:14 

report 57:9 

reporting 14:9 

represent 53:22 

represented 53:5 

requirements 14:3 

research 35:21 36:7 

38:8 45:16 

resilience 59:12 

resilient 59:15 

respective 17:6 44:3 

response 4:15,17 5:1,9 

50:3 57:19 60:13 

responsibilities 13:17 

28:6 29:8 

responsibility 30:6,10 

39:6,13 

rest 58:1 

retested 12:19 

retesting 36:2 

retired 51:15 

revealed 47:19 

revenue 43:2 

review 13:7,8 14:10 

17:5 18:5 42:12 43:3 

44:12,19 45:6,22 

51:19 

reviewing 37:2 42:4,5,8 

42:10 44:9 

reviews 41:9,14 

rewrite 36:18 

road 29:19 33:21 

ROBERT 1:20 

robust 58:2 

role 35:8 56:11,11 

roll 4:8 5:19 41:12 

rolling 43:8 

RUGGLES 2:17 43:13 

rulemaking 44:16 45:12 

45:20 

run 12:7,9,16 

Ryan 1:18 4:22 6:22 

S

safe 23:13 

safety 24:18 28:14 33:5 

34:22 

sample 13:21 

saw 5:3 53:2 

saying 12:9 16:7 17:22 

23:17,21 24:12 29:20 

31:1 42:5,8,20 

says 39:15 49:2,6 

SB&B 1:20 

scenes 60:5 

Schedule 41:16 

scheduling 52:7 

Science 2:13 

Sciences 46:17 

Scientific 2:16 

scope 48:14 

Scoular 1:15 

screen 11:10 12:21 

26:11 

screener 12:10 

screening 25:6 

screenings 25:14,20 

26:8,21 

screens 6:9 

search 4:7 

seat 9:1 25:9 

second 8:13 37:5 39:18 

57:18 

secretary 50:15 57:22 

secretly 45:2 

section 10:22 11:2 

13:18 23:18 27:17 

39:13 41:3 48:21 

seeing 9:19 

seen 10:18 

sees 34:1 

selection 50:8 51:11 

selections 50:20 

sell 32:2 

semi-recent 37:20 

send 59:6 

sent 9:20 

separate 36:19,22 

separator 12:10 

serve 59:15 

service 1:19 42:19 43:8 

services 41:19 42:13 

43:5 

set 13:7 42:12,14,20 

43:4 45:6 

shaking 18:22 

share 9:14,15 15:10 

shared 17:11 

sharing 19:6 45:3 51:22 

53:18 

sheer 21:5 

shifters 52:21 

Shipper/Receiver

54:14 

shippers 56:4 

short 17:14 

show 6:6,6 32:11,12 

shuttle 52:6 

sick 24:19,20 

side 27:16,16 

Simultaneous 15:20 

16:21 17:20 20:22 

26:19 31:4 36:4 45:9 

Sinner 1:20 4:16 21:17 

22:15,18 23:3 

sir 4:11 20:14 

sit 28:8 

situation 54:3 

six 29:18 42:18 43:1 

size 13:21 

skills 34:16 

slate 51:5 

sliding 27:14 

solicit 46:6,6 

soliciting 45:21 

somebody 24:21 37:2 

SOP 28:7,20 

sorry 5:5 6:9 7:1,12 8:4 

8:15 21:16 24:6 25:14 

47:5 

sort 7:22 10:6 12:10 

13:1 33:9 

space 8:4 28:19 

speak 52:17 58:9,12 

speaker 4:5 

speaking 15:20 16:21 

17:20 20:22 26:19 

31:4 36:4 45:9 56:17 

special 40:17 

specific 26:7 44:8 

specifically 10:22 

specification 47:15 

specifications 49:13 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
67 

spell 22:22 

spend 12:6 

spending 43:1 

spoke 21:16 

spot 7:13 32:22 50:6 

spring 56:10 

staff 2:9 17:7 30:4 35:5 

40:10 58:7 60:9 

stakeholders 45:17,21 

55:10 

standpoint 15:11 32:3 

59:3 

start 11:9 34:18 51:3 

53:21 

state 39:8,17 

statement 21:21 22:21 

42:1,5 48:22 

states 1:1 39:10,22 

stating 22:2 45:4 

status 57:13 

statute 51:20 

stay 13:17 45:2 

STB 52:8 54:16 55:11 

steps 14:13,15 

story 33:14,19 

straightforward 21:18 

strategy 36:21 

stream 48:5 

streamline 28:12 29:9 

stressful 60:7 

stronger 55:19 

subcommittee 3:15 

5:15,17 6:2,5,15,19 

6:20 7:4,5,19 9:7 10:5 

11:8 14:7,17 18:16,18 

18:19,20,21 19:5,13 

19:17,22 20:3,9,18 

21:3 22:12 29:16 

32:20 33:11 34:1 

36:21 38:21 40:2,4,9 

40:15 56:19 

subcommittee's 16:16 

sublot 11:11 

submission 46:19 

submit 47:12 54:16 

55:11 56:17 

submitted 54:22 

substantive 13:15 

successful 21:9 

successfully 59:20 

sufficient 34:6 

suggested 34:5 

suggesting 23:7,8 34:4 

suggestions 27:10 

supply 28:12 

support 16:15 17:22 

56:13 60:2 

supported 60:1 

surface 53:8,12 

swiftly 45:1 

T

T-2/HT-2 47:15 

tackling 52:8 

taken 15:5 20:10 

takes 58:4,4 

talk 22:8 28:8 50:6 

talked 11:8,15 12:20 

17:8 

talking 8:10 12:6 34:19 

39:6 41:14,17 43:7,8 

43:11 

talks 7:20 37:10 

team 53:3 

technology 2:13 46:20 

47:19 48:3,6,10 

tell 33:15 

ten 26:14 

tentative 56:8 

term 10:4 

terms 30:21 37:19 

47:19 49:14 50:20 

51:6 54:4 

Tess 46:15,16,16 47:5 

47:10,21 48:12 49:10 

49:20 

test 38:2 47:2,7 48:9 

49:4 

testing 41:17,18 47:1 

49:3 

thank 20:12 49:15,20 

54:12 57:21 58:6,7 

60:2,3,8,9,11,19 

thanks 6:3,4 8:22 14:16 

18:13 23:2 31:3 40:15 

51:22 52:2 

that'd 18:8 35:6 45:11 

they'd 41:6 

things 8:7 10:7 20:9 

24:18 25:13 28:17 

41:16 56:7 

third 21:19 

thought 10:5 44:7 

48:14,16 

thoughts 15:10 47:22 

52:15 59:6 

three 29:18 

THURSDAY 1:5 

tied 35:18 

Tim 47:22 48:1 

timeline 51:2 

times 8:1 12:7,18 13:2 

21:22 22:19 60:6 

timing 50:9 

TIMOTHY 2:16 

today 5:12 6:4 38:14 

39:1 40:22 58:8 

today's 6:9 14:10 

Tom 5:7,10 

tonnage 41:12 42:14 

Tony 16:5 17:14 27:12 

27:20 35:7 

top 10:3 27:6 39:18 

topic 10:9 

topics 54:18 56:21 

58:21 

torch 54:2 

total 58:11 

totally 17:22 44:17 

touch 8:19 

tough 15:4,5 

track 33:8 34:17 37:7 

37:14 

tracked 31:17 

traction 56:7 

trade 18:21 20:7 

traditionally 57:8 

train 52:7 

transparency 54:5 

55:20 

transparent 49:9 

transportation 52:4,7 

52:20,22 53:3,9,12,13 

53:17 

transportation-related

55:3 

try 8:17 9:14,16 11:17 

31:12 38:13 

trying 28:5,9,11,16,22 

34:21 36:9 37:6 51:16 

tuned 45:2 

Tunnell 5:8 

turned 20:1 

turnover 23:22 

turns 26:15 

tweaking 32:1 

two 36:19,22 37:7 

type 24:19 25:21 44:8 

47:18 52:22 54:6,10 

types 7:8 10:3 11:3 

U

U.S 8:12 

unavailable 51:14 

understand 23:11,14 

24:5 36:11 41:21 49:8 

54:8 

understanding 26:9 

42:9 

understood 25:10 

unfamiliar 32:15 

unfamiliarity 23:5 

unified 16:11 

unit 43:15 

UNITED 1:1 

update 5:14 7:14 

updates 58:9 60:10 

USDA 2:9 15:14 44:20 

use 47:20 

usually 57:14 

V

valid 33:10 

validating 47:2 

venue 31:15 

verbally 35:4 

verbiage 11:1 

version 9:19 

versus 26:15 32:4 

36:13,18 

vice 57:21 

Videoconference 1:7 

virtual 58:18 59:5 

volunteer 58:5 

W

wait 35:16,18 

waiting 4:7 5:2 

walk 5:16 

wanted 17:19 21:5 44:7 

wants 17:9 

war 15:19 

wasn't 6:8,10 7:1 34:1 

waters 37:1 

way 28:10 29:5 30:3 

32:21 37:1 48:14 59:9 

ways 34:11 

website 10:1,19 

weeks 10:1,2 

Weights 17:2 18:1,7 

welcome 52:9 

went 9:9 10:18 60:22 

weren't 41:4 

wheat 1:14 21:20 23:8,9 

wife 8:14 

WILLIAMS 1:21 

wondered 22:20 

work 5:15,17 7:14 9:2 

9:13 15:5 16:16 18:19 

19:18,19,22 20:1,7 

28:12,16 29:2,3,9 

31:16,18 34:2 38:21 

40:12,18 51:5 54:13 

56:19 58:2 59:16,19 

worked 6:5 46:7 57:11 

working 7:22 15:2 

18:20,21 19:14 20:9 

20:20 40:6 46:2 51:1 

works 52:19 

worry 26:12 

would've 27:22 

wouldn't 48:11 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
68 

wrap 5:22 

write 42:3 

writing 38:8 

X

Y

yea 30:20 

year 8:18 38:20 51:4 

years 29:19 35:17 37:7 

38:4 42:18 43:1,22 

yesterday 5:11 41:4,8 

46:18 52:4 53:3 54:19 

yield 54:10 

Z

0

1

11:00 1:6 4:2 

12:12 60:22 

16 1:5 

1993 38:9 

2

2 12:21 

20 38:4 

2021 1:5 

3

4

4 3:12 48:21 

41 3:17 

5

6

6 3:15 10:22 

6.4 10:22 21:19 

65 58:10 

7

8

9

90s 37:13 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
 

69

C E R T I F I C A T E 

This is to certify that the foregoing transcript 

In the matter of: Grain Inspection Advisory Committee

Before: USDA

Date: 12-16-21

Place: teleconference

was duly recorded and accurately transcribed under 

my direction; further, that said transcript is a 

true and accurate record of the proceedings. 

-----------------------

Court Reporter 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com