Mycotoxin Monitoring in the FSMA Era

Ethanol plants gear up systems to document compliance. This article appears in the October print issue of Ethanol Producer Magazine.
By Susanne Retka Schill | September 20, 2016

Ethanol producers have long known that in certain years, mycotoxins will be an issue because any that come in with the whole grain get tripled in the outgoing distillers grains. This year, there is an added dimension as plants figure out how to adapt the systems they’ve used for years to satisfy the hazard analysis and record keeping requirements of the Food Safety Modernization Act.

Charles Hurburgh, head of the Iowa Grain Quality Initiative, participated in the first training seminars on FSMA compliance for ethanol producers. There is a range of preparedness in the industry as FSMA kicks in, he says. “Most understand that it’s more a matter of documentation and making the procedure consistent. Plants that have solid records of inbound corn and outbound DDGS testing may well be able to avoid having formal preventive controls. But, they have to keep the program going, even in low-toxin years, even if at a lower sampling frequency.”

A good mycotoxin program starts before the new crop starts coming, says Erin Bowers, postdoctoral associate working with Hurburgh, with monitoring crop development and any emerging quality concerns.  “You don’t need to test for every mycotoxin every year,” she says. “The fungi that produce these mycotoxins like different weather.”  Aflatoxin is seen most often in hot, dry conditions, frequently in the South.  DON (deoxynivalenol or vomitoxin) is found when growing seasons are cool and wet. Three other mycotoxins of concern are fumonisin, zearalenone and ochratoxin. There are other molds in growing or stored grain that can cause quality problems for ethanol production, but these five are of concern for the DDGS because they can cause negative health impacts in animals. Each mycotoxin has its own limits that vary by the species being fed and the age of the animal.

When the new crop starts coming in, test more frequently, she suggests, and keep a control chart—a running average of test results to establish what the normal level for the season will be. If the control chart shows stable, very low or undetectable levels, the level of monitoring could be reduced. “If they do have a mycotoxin issue that year, they’re going to have to implement some safety plan,” she says. “If some truckloads are coming in at 12 parts per billion aflatoxin, and it’s being seen more often, there needs to be a plan.” That could include tighter acceptance criteria or more intense testing protocols.  “FSMA does not prescribe how to evaluate grain lots for mycotoxins,” she says. “In the preamble to the animal food law, it even says you don’t have to test every load of grain. The requirement is that it does need to be evaluated for hazards, so every facility is going to have some sort of evaluation method that they can justify and use to protect their purchasers.”

Sample Strategy
Getting the right sampling procedure is important. One study found the level of aflatoxin can be so high in a single kernel that eight of those kernels in a bushel of corn would put the whole lot over the 20 parts per billion limit.  “That is very extreme,” Bower says, and would be uncommon, “but that shows you how small of a level of contamination can cause a problem. Doing a high level of representative sampling is a pain, but sometimes it is necessary.” 

Research-based best practices for getting good representative samples are found in the Federal Grain Inspection Service’s mycotoxin sampling handbook. Another resource is available on the website of the United Nations Food and Agriculture Organization, Bower says. Using the FAO mycotoxin tool, one can enter the grain, the type of mycotoxin and characteristics of sampling plans to see how they will impact detection. The FGIS procedure describes how to properly collect multiple probes from a truck or rail car. The probe samples are combined, mixed and divided and at least 10 pounds are ground, from which a subsample is taken for the mycotoxin test.

In the past decade, several manufacturers have developed rapid test kits that use a solvent to extract the mycotoxins from the representative ground sample and a test strip to detect the presence and level of the targeted mycotoxin. While the manufacturers of mycotoxin testing kits have cut the time needed for the actual test, Bower points out, “it doesn’t cut back on all the sample preparation time.”  
For a commercial facility handling 100 or more trucks per day, collecting a 10-pound sample from every truckload for testing is not practical, Bower adds. In addition to the volume and time, there’s the cost. It can range from $3,000 to $7,000 to get set up for rapid testing on site, plus the consumable test strips cost around $18 to $25 each. “You want to have a plan, because it gets expensive to shoot from the hip,” Bower says. “If all you’re going to do is scoop some grain off the top of a truck and grind it, you might as well not test. It’s not worth your $20. Proper sampling is important to get reliable results.”

Rather than testing individual trucks, most facilities use composite samples. Hurburgh explains that normally the probe sample for a truck is divided with one portion going to the moisture meter. The remainder is combined in a 5-gallon pail. At the typical sample sizes used for grading, about 15 loads will provide a 10-pound sample to be ground for mycotoxin testing. He suggests getting more use from the composite samples by tracking other quality factors using NIR technology, or sending it to a federal or commercial lab to compare with in-house results. 

Another check on the effectiveness of the program to monitor incoming grain is accomplished by monitoring outgoing DDGS. It can be a good check, as the incoming corn has been thoroughly mixed through the process, making the DDGS a far more homogenous product. In many cases, the rapid tests used for corn can be used for mycotoxin testing of DDGS, with some modifications. 

In years of low mycotoxin risk, the intensity of sampling and testing can be reduced. “Every facility is different,” Bowers says. “It depends on your market. For instance, if your DDGS go to cattle, they are a lot more tolerant to mycotoxins than pigs are.” Documenting the program is important. “That control chart, testing and documentation is proof that you’re monitoring and evaluating the grain. You keep that and you can show how you justified your decision: We were testing this many times a day, here is what we were seeing. We tested our outbound product and here’s what we were seeing. It showed us we had set limits at the beginning of the process for receiving grain that were protective enough that our DDGS fell below any of these questionable or potentially hazardous levels.”

FSMA’s provision for a recall plan, should a hazardous situation occur, has led to a new recommendation for ethanol plants. “Make sure that at some point to go bin empty to create a cutoff point,” Bower suggests. “The whole point is that, if there is a food safety outbreak and it’s traced back to your facility, you’re going to have a recall. Are you going to have account for the sale of 100,000 tons or 10,000 tons?”    

Traceability is a live topic in the industry, Hurburgh says. “A lot of thought is going in that direction because there are commercial benefits as well as supporting recall potential.” Most bulk handling systems, however, are not designed for traceability. “There are things you can do, especially if you aren’t trying to track something that is very small or has low margin for error,” he says. “For example, if you are tracing mycotoxins to some level of tolerance, the errors introduced by simply leaving the cone of dry corn in the bottom of a bin as opposed to going to completely empty might not be a problem. These will all be documentation issues from the FSMA perspective.”

Hurburgh and Bowers were part of the industry committee that developed a training curriculum for those responsible for FSMA compliance at ethanol plants. The first of the training sessions were held this summer, and Hurburgh has been an instructor. “I have come to see that the biggest FSMA related challenge for ethanol plants will be supply chain requirements placed on them by buyers,” he says, “not compliance activities and supply chain management inside the plant.”

The industry is stepping up to the challenge. “I see commitment among the plant people to make the ethanol industry the best in agriculture at meeting FSMA and product safety standards,” Hurburgh says.

Author: Susanne Retka Schill
Managing Editor, Ethanol Producer Magazine