1. Purpose

Grain Trade Australia (GTA) is seeking Member feedback on a proposed revision of Technical Guideline Document No. 15 – Managing Chemical Residue Violations.

A marked-up version of the revised TGD is available here. It shows the proposed changes to the current version of this document.

2. Background

TGD No. 15 provides industry guidance on managing chemical violations, including the identification, confirmation, reporting and investigation of violations and the implementation of corrective action.

GTA has reviewed the TGD with input from an industry working group and relevant GTA Technical Committees. The review has retained the existing guidance on chemical residues in grain while extending the document to address atmospheric chemical violations associated with grain transport units. This may include road transport units containing grain in excess of phosphine Workplace Exposure Limits.

3. Major proposed change

The principal change is the inclusion of guidance for managing atmospheric chemical violations associated with phosphine and other fumigant gases.

These incidents may occur and be identified at receival or handling points through testing or monitoring.

The revised TGD provides additional guidance for receival agents faced with grain transport units found to contain atmospheric chemical concentrations exceeding applicable regulatory, workplace health and safety, customer, market-access or industry requirements. Examples include:

• phosphine detected in or around grain or a transport unit;
• atmospheric concentrations of phosphine or other fumigant gases exceeding an applicable requirement;
• fumigant tablets or pellets observed in a grain transport unit; and
• other chemical detections identified through receival testing or monitoring.

The proposed guidance is intended to support:

• worker health and safety;
• consistent receival and handling practices;
• appropriate isolation, testing and management of affected loads;
• traceability and incident investigation;
• proportionate reporting and escalation; and
• corrective action to prevent recurrence.

The revised TGD also outlines a practical response process covering the securing and isolation of a transport unit, verification of test results, initial incident categorisation, management of the grain, investigation, supplier notification and corrective action.

4. Status of the guidance

The proposed additions are industry guidance only. They do not prescribe a grain acceptance limit or replace:

• applicable workplace exposure limits;
• work health and safety legislation;
• approved chemical label directions;
• environmental or dangerous-goods requirements;
• customer, contractual or market-access requirements;
• site-specific risk assessments and safe-work procedures;
• company-specific policies and procedures; or
• directions issued by a regulator or emergency service.

Personnel safety remains the first priority.

5. Member consultation

GTA invites Members to review the attached marked-up draft and provide feedback on:

• the clarity and practicality of the proposed atmospheric chemical guidance;
• the proposed process for managing affected grain transport units;
  • the incident categories and proportionate responses;
  • testing, documentation, traceability and investigation requirements;
  • supplier notification, reporting and corrective action; and
• any operational or implementation issues that should be addressed before the TGD is finalised.

Member input will be considered in preparing the final revised TGD for approval by the GTA Board.

Please send feedback to submissions@graintrade.org.au by COB Friday, 30 October, with the subject line “Feedback – Draft revised TGD No. 15”.