BY HARRISON ASHLEY
From Cotton Grower Magazine – December 2016
Throughout 2016, the National Cotton Ginners Association (NCGA) addressed a number of regulatory issues, and continued efforts on educating the industry’s workforce and preserving cotton quality.
This included NCGA’s work to protect a hard-earned reputation for having the cleanest cotton in the world by continuing to emphasize to ginners that all plastic contaminates must be eliminated. A renewed effort is underway to train gin employees on proper round module handling and wrap removal. In addition, gins are being advised that they need better communication with producers to rid fields of potential contaminants such as plastic shopping bags and black plastic, which is used as ditch liners and in vegetable production.
The NCGA continues to support research that addresses quality issues and concerns by working with the USDA Ginning Laboratories and with Cotton Incorporated. The NCGA worked recently with the National Cotton Council (NCC) to help secure needed increases in gin laboratory funding. The House Appropriations Committee included language that referenced the importance of our gin laboratories, and the Senate Appropriations Committee has directed that an additional $1.5 million be allocated to those facilities. Research at those laboratories is critical for improving lint quality and for increasing ginning efficiency.
Cotton gins have been required to register as a facility under the 2002 Biosecurity Act and most recently under the Food Safety and Modernization Act. Accordingly, the NCGA and the NCC met with the Food and Drug Administration (FDA) to explain that gins are an extension of harvest and produce two raw agricultural commodities (RAC) – cotton lint and seed.
The FDA has since released a draft guidance that acknowledges that the gins perform the same function regardless of ownership, and that gins do not transform a RAC into a processed food. The draft guidance gives gins that are solely engaged in ginning an additional 16 months to comply, and FDA is considering whether and how FDA should address other concerns expressed by the NCGA.
Ginners will be dealing with new and updated regulations in the year ahead with changes in the Occupational Safety & Health Administration’s reporting requirements. In addition to commenting on the proposed rule, the NCGA will be following the implementation of the now final rule closely.
The NCGA and member gin associations are actively working on training materials for help in preventing accidents in the gin. Considerable time is spent each year in training gin employees in the safe operation of gin equipment. In 2015 and 2016, there were new Department of Labor rules and changes brought about by interpretations of existing rules that may affect gins. These changes have implications on overtime pay and gin employee classifications.
The NCGA is confident that its ginner schools are fulfilling this need. This is evidenced by the fact that the three 2016 ginner schools attracted a total of 246 students. With the assistance of the USDA and gin equipment manufacturers, the NCGA will continue to manage these annual gin schools and maintain the Cotton Ginners’ Certification Program. That includes continuing to provide timely topics in the school’s continuing education curriculum, which are equally important to certified ginners and gin managers.
Looking ahead to 2017, the NCGA will continue helping its member gins maximize the efficiencies they have accrued so U.S. cotton can continue to be the world’s preferred fiber.
Ashley is Vice President, Ginners Services, National Cotton Council of America and Executive Vice President, National Cotton Ginners Association