Chemical residues, heavy metals and mycotoxins are in the spotlight thanks to a new Australian export hay project


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Funded by AgriFutures Australia through its Export Fodder Program the project provides advice to the Australian export fodder industry about regulations and changing market requirements for chemicals, heavy metals and mycotoxins.

Independent consultant Gerard McMullen is leading the project and said education right across the supply chain was crucial to ensure compliance with regulations as fodder is used in the food chain.

“You’ve got to be ahead of the game these days,” he said. “For example, when supplying fodder into a market you don’t need them finding unwanted residues as they won’t want your fodder. They will go to another market, and you’ve lost a market and that takes a hell of a lot to get back.”

Fodder growers have been meeting strict maximum residue limits (MRL), through compliance with chemical label directions for many years.

Due to the large number of chemicals potentially used, and the cost of testing, not all export fodder consignments are tested for residues, but Mr McMullen said it didn’t mean standards could drop.

“The purpose of the project is to provide exporters with the export regulations that apply and the potential impact of any changes to those regulations,” he said. “The onus is on exporters, they have to make sure residues on exports meet market requirements. If unsure, testing should occur to ensure the fodder industry is squeaky clean and can be shown to at least comply with Australian label directions.”

The project started six months ago. Most days, Mr McMullen receives notifications about changes to market requirements. He determines if they are relevant for the Australian industry and then informs fodder exporters about the changes and how to meet the new requirements.

This rigorous monitoring helps keep markets open for Australian fodder, but it also plays a larger role in protecting the food chain.

“The importing countries are relying on Australian exporters and Australia’s great reputation for complying with regulations and food safety,” he said.

“Even if a market does not have specific regulations, there is a requirement for the industry to at least follow Australian label directions and for compliance with Australian MRLs. I’d also recommend exports comply with international standards such as those set by Codex for fodder.”

The Codex Alimentarius Commission (CODEX) sets international chemical MRL, heavy metal and mycotoxin standards for many commodities, including fodder.


This is the first time Mr McMullen has worked with the fodder industry. His career has focused on quality assurance in the grain industry, including Q&A Manager for the AWB where he was in charge of hygiene, set standards for quarantine, chemical residues and heavy metals. Since leaving AWB 15 years ago he has consulted to the grains industry, concentrating on customer requirements and interpretation of standards.

Approached by AgriFutures Australia to work in the fodder industry, Mr McMullen felt the project “fitted nicely” as grain and fodder growers are often the same.

He’s a member of the Grain, Plant and Plant Products Export Industry Consultative Committee which liaises with government about what’s required to export products from Australia.

Mr McMullen is also the Chair of the National Working Party on Grain Protection.

Describing his role in the fodder industry as a “learning curve” he’s been working closely with Agsmart using the FodderSafe tools to ensure everyone has the most up to date information and can adapt rapidly to changing regulations.

He said fodder exporters, who receive commodity vendor declarations from suppliers stipulating what chemicals were used, sit in the middle of the supply chain and are responsible for their own risk management.

Unlike grain, there’s no formal government monitoring of residues in fodder exports.

“The relative lack of ability for exporters to blend fodder means it is really important growers complete their declaration accurately so the fodder exporter can make risk assessments about the supply of a particular fodder to a particular market,” he said.

This article is by the Australian Fodder Industry Association (AFIA) and was first published in its Focus on Fodder Winter edition.

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