Enabling Agricultural Traceability through Data Interoperability

14 June 2024

Agricultural Traceability Branch
Trade & International Division
Department of Agriculture, Fisheries and Forestry
GPO Box 858 Canberra ACT 2601 Australia

Via: Credentials.innovation@aff.gov.au

Re: Data interoperability framework for agricultural traceability and product data

GrainGrowers welcomes the opportunity to provide comment on issues related to agricultural traceability and product data for our industry.

GrainGrowers represents Australian grain farmers with individual grower members across the country. We work to build a more profitable and sustainable grains industry for the benefit of Australian grain farmers, through our focus areas of policy and advocacy, grower engagement, thought leadership and active investment in future focused activities for all growers. Australian growers are at the heart of all that we do and the focus of our work.

The grains industry is a regional Australian powerhouse with 22,500 farm businesses growing around 50 million tonnes of grains, oilseeds and pulses each year for domestic and global customers. Our industry provides stewardship for an estimated 31 million hectares of land. In the 2022-23 growing season, Australian grain growers contributed $33 billion Gross
Value of Production (GVP) to the Australian economy.

GrainGrowers is committed to supporting innovation in the grain industry. Like many industries, innovation will be critical for agriculture to meet existing and future challenges, both on-farm and in markets. Data handling, interoperability and traceability are emerging opportunities for innovation, however there needs to be a clear understanding of the value proposition associated with these areas to enable industry to better engage in the discussion and articulate the risks and benefits.

Our industry is seeing an increase in the amount of data collected and available to inform management of farm businesses and drive innovation in our industry. GRDC’s Data
Partnerships initiative has recently made a range of data from GRDC funded research available to inform further research and produce new insights1. On farm there can be challenges with machinery interoperability and maximising the value derived from the data from modern machinery. Our markets are also increasingly looking to access data related to
Australian grain for many purposes, including understanding grain quality as well as assurances over the origin of grain. It is important to recognise that there is a tension between providing information to ensure access to a market, or to achieve a premium, with the cost of collecting, managing and supplying that information along with privacy and security risks. The experience of growers to date is that the justifications for increased

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Data partnership builds expertise to harness data treasure trove | Groundcover (grdc.com.au)
information have been vague and opaque, and promises of market premiums have remained elusive.

The framework being developed focuses on technical aspects of how data associated with agricultural produce is identified and organised. The key points raised in our submission are outlined below:

• Any framework should align with the National Farmers’ Federation (NFF) Farm Data
Code and its Farm Data Principles
• Data interoperability issues in the industry are broader than just traceability
• Consent from growers is required if the supply chain want greater access to grower
data
• Current data may be inappropriate for traceability purposes
• Adoption of a traceability framework will require a profitable application.

Any framework should align with the NFF Farm Data Code and its Farm Data
Principles
GrainGrowers acknowledges the principles (Section 2.22) established to guide the design and operation of the framework and would like to highlight the importance of data rights and privacy which is acknowledged in the Consultation Paper. As highlighted by the NFF Farm
Data Code3 which was developed in consultation with several agricultural industries, it is important that growers have confidence in how their data is collected, used and shared. The
Farm Data Principles set out in the NFF Farm Data Code should set the standard for how entities accessing farm data should behave and treat farm data, and these principles should be recognised in broader frameworks that relate to farm data. The way data is treated and managed by entities along the supply chain is critical to maintaining industry confidence.

Data interoperability issues in the industry are broader than just traceability
Most farms do not have the Information technology (IT) expertise to integrate and manage their data and rely on external software that has its own definitions and structure of data. For this reason, our industry is not able to provide technical input or critique the framework proposed. However, there is a growing frustration with problems related to interoperability and different proprietary technology and information systems being unable to ‘talk to each other’ in on-farm applications. A common example given is the difficulties in operating different ‘brands’ of farm machinery in combination because of proprietary systems, and then the associated challenges of migrating this data to farm management systems. This causes difficulties for on-farm data management and ability to implement precision agriculture systems, but also the ability of enterprises to manage and share data with external providers, the supply chain and ultimately customers.

In principle there is support for greater data interoperability because of the opportunity to reduce costs and duplication of data entry and management, and improve the value derived from the data. Accessing and utilising data directly from machinery for traceability applications is an opportunity, but it sits outside the experience and expertise of most growers. A focus on systems, frameworks and policy to improve on-farm productivity through improved data handling and maximising the benefits from this data to farm management, would be beneficial to industry.

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Data_Interoperability_Framework_Consultation_Paper.docx (live.com)
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Farm_Data_Code_Edition_1_WEB_FINAL.pdf (nff.org.au)
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Consent from growers is required if the supply chain seeks greater access to grower data
Grain Trade Australia’s Australian Grain Industry Code of Practice currently states that
“participants in the supply chain should have procedures in place to trace grain one step forward and one step back in the grain supply chain”4. In general, Australian growers operate on the understanding that traceability can occur on this basis, and the ability for product data to be available to all points on the supply chain has not been widely discussed.
Examples of the type of data currently collected at receival and managed by members of the grain trade is included at Attachment A. Implementation of mechanisms to enable traceability and the availability of this data along the supply chain requires further industry consultation and grower consent. With the development of farm machinery that can track and log on-farm activity there is the scope for greater amounts of information to be associated with grain, which raises concerns related to costs and privacy as well as what might constitute reasonable expectations from markets and the supply chain.

Current data may be inappropriate for traceability purposes
It is not clear what product data would be sought to be included under the framework, and in many cases the format of the data that could be included is unclear or could be problematic.
As outlined in Attachment A there is a range of information that may be provided by growers or generated at receival. Amongst the information collected or reported are a range of variables where there are no standards or proprietary standards exist. Examples include:

Location: Location data for grain production does not have a consistent framework for reporting. This currently causes difficulties for developing a range of statistics related to regional grain production. However, recent requirements announced by Europe5 and the
United States (Renewable Fuel Standards RFS2) requiring data to track deforestation raises broader concerns for industry about the appropriateness of providing this type of information, and the extent to which these requirements may become a non-tariff barrier to trade.

Grain trading standards: Grain grade classifications for wheat, regularly used in the marketing of Australian wheat, have been registered as trademarks6 and their use outside of
Grain Trade Australia members is restricted. A variety of grain grade classifications exist or have the potential to be developed for different grain over time and data frameworks need to have the flexibility to incorporate or change classifications and standards over time.

Standardisation of methodologies and metrics: There are several metrics associated with grain production which are currently emerging, for which there are competing methods of measurement and reporting. One example is the use of carbon calculators to assess greenhouse gas emissions associated with crop production. Variability exists in the results produced by publicly available calculators and further work is required to ensure they accurately represent on-farm emissions in the Australian context7. It is important that implementing a traceability framework does not perpetuate the use of unrepresentative metrics and the use of standardised methodologies is promoted.

Physical grain assessment: The assessment of grain is currently undertaken by trained staff at receival, however there are moves towards automation of this process and greater adoption of technologies to assess grain at receival, including the use of image analysis (for example, the use of Zoom Agri technology to assess varietal purity of barley). This has the potential to generate new data and different data formats that will need to be accounted for,

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GTA_105617_CODE_BRO_10 WEB.pdf (graintrade.org.au)
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Deforestation Regulation implementation - European Commission (europa.eu)
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Member Update No.4 of 24 Trade Marks.pdf (graintrade.org.au)
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Carbon calculator report launched | Building a more profitable and sustainable industry for Australian growers (graingrowers.com.au)
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in addition to the possibility that the technology will operate and generate this information using proprietary standards.

These examples highlight a lack of data standards, restrictions in using existing classifications and standards as well as the emergence of new technologies that generate new and different types of data. This highlights the complexity of developing a framework for traceability and product data for the grains industry, as well as questions around the type of data that is available and required to support traceability.

Adoption of a traceability framework will require a profitable application
There are markets where provenance and traceability are critical, and when engaging with these markets there is an expectation that growers involved understand the data requirements and benefit from a premium or benefits from market access. On farm production systems (such as organic) and provenance are highly regarded and valued in some markets, justifying traceability. As noted in the consultation paper a move to greater traceability should create value for supply chain participants and be cost-effective and economical to adopt. However, applying requirements for traceability across all farms may result in growers bearing the cost of collecting and providing data without deriving significant benefit to the majority.

A clear value proposition needs to be developed to understand the opportunity from greater traceability and recording product data. AgTrace Australia8, through the Food Agility CRC, has indicated it would undertake work on the development of data standards and solutions to facilitate traceability. As a first step, this work must be to demonstrate the value of pursuing greater traceability and if the returns are likely to justify the investment and prioritise action in this area.

Conclusion
GrainGrowers would welcome further discussion with the Department of Agriculture,
Fisheries and Forestry regarding traceability and data in relation to the grains industry.
Please contact our Policy Manager, Technical Sam Nelson via sam.nelson@graingrowers.com.au for any further information regarding this submission.

Regards

Zachary Whale
General Manager Policy and Advocacy

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Homepage - AgTrace Australia
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Attachment A: Types of information collected at grain receival points

The types of information currently provided at grain receival is outlined below and has been compiled from several sources. With the development of farm machinery that can track and log on farm activity there is the scope for greater amounts of information to be associated with grain, which raises concerns related to costs and privacy as well as what might constitute reasonable expectations from markets and the supply chain. Grain Trade
Australia’s Australian Grain Industry Code of Practice currently states that “participants in the supply chain should have procedures in place to trace grain one step forward and one step back in the grain supply chain”. Australian growers rely on grain trade managing this information appropriately.

Types of data or declarations provided by growers when delivering at receival points.

Identifiers (national grower register number, trading name, contact name, phone number)

Commodity (commodity, variety, GM variety, season of production)

Location identifier (inconsistent formats)

Production system quality assurance declaration (compliance with requirements of Organic
Certification, International Sustainability & Carbon Certification – this reporting requirement is not consistently required, and standards may vary depending on the scheme)

Storage information (Storage quality assurance program, accreditation/certification number)

Chemical usage declaration (during planting, growing and since harvest usually related to specific active ingredients, either declaring chemical has not been used or used in compliance with label requirements)

Truck details (registration, type of vehicle, movement)

Types of information generated by the receiver at receival points.

Weight of load

Assessment of physical grain to determine compliance with receival standard and classification (quality test results could include protein, screenings, moisture, oil content, falling number and a range of other characteristics may be recorded in addition to classification according to Grain Trade Australia Standards)

Chemical residue testing (in line with National Residue Survey, may include grower load samples)

Varietal identification/confirmation of commodity

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