What’s Happening with the Responsible Grain Code?

by | Feb 22, 2022

The CRSC is ready to listen to farmers on how best to prove grain farming’s sustainability.

When the Canadian Roundtable for Sustainable Crops (CRSC) asked for feedback last winter on its first draft of a voluntary code of practice for grain producers, producers responded with stiff criticism.

While the specific comments varied, the vast majority of respondents were opposed to the ‘Responsible Grain’ code as drafted: either stating it needed a major rewrite or questioning why it had been drafted at all.

In response, CRSC went back to the drawing board. After many months of intensive analysis and research, CRSC is now ready to engage with grain producers about what should — or should not — come next.

“There were some very fundamental questions that were asked by (consultation) participants around the need for and value of a code of practice,” says Susie Miller, CRSC’s executive director. “We committed to finding answers. What happens next depends on what farmers tell us from here. If there is a Code 2.0, it will be created in close cooperation with farmers.”

What’s the Responsible Grain Code?

Responsible Grain was intended to be a tool for Canadian grain, oilseed, and special crop producers to prove they operate according to sustainable, responsible production methods. Much like voluntary codes used in other agricultural commodities (such as Verified Beef Production Plus), most grain producers are already following the prescribed practices, so the focus was on the opportunity to build public trust and market access by showcasing the good work producers do. It was also designed to be proactive — a way of meeting the market’s demands before the market or government institutes its own rules.

“The idea behind a code is that it provides a degree of self-determination and industry leadership. It allows a response to sustainability pressures, but on our terms rather than someone else’s,” explains Miller. “It permits the showcasing of our performance in an accurately measured and science-based manner.”

In June, CRSC published a ‘What We Heard’ report summarizing the consultation period feedback. Many respondents feared a voluntary code would be a slippery slope to mandatory requirements. Others said the draft code focused on many ‘should not’ rules instead of celebrating the sustainability efforts producers already do. Some respondents stated that, while they weren’t opposed to the concept of a code of practice, they thought the specific practices listed in the draft were either unclear, too specific, or otherwise problematic. Many wondered whether there was any value in a code, particularly since – unlike beef – there would be no market premium for a verified sustainable product.

Through the summer, CRSC dug deep into finding answers to the many concerns and questions producers had posed. Miller interviewed more than two dozen companies about sustainability in the marketplace, talked to multiple government representatives about everything from international trade to upcoming funding priorities, and intensively researched sustainability, both as it applies to grain farming specifically and as it’s promoted in other commodities and jurisdictions.

“Farmers asked legitimate questions. The analysis we did through the summer was our attempt to respond to those questions,” says Miller.

The White Paper

Now, CRSC is ready to unveil a newly drafted ‘White Paper’ summarizing that research and analysis. The paper is divided into two distinct sections. The first section summarizes current and coming sustainability pressures. The second section answers questions specific to how a code of practice might function.

“This analysis can serve a lot of ends. It can provide general information to grain farmers on the (sustainability) pressures they are facing and what the future might look like. That’s valuable in and of itself. Whether or not that leads to an acceptance of a Code as a tool that is needed, that’s secondary and separate in the report.”

Cheryl Mayer, the Canadian Canola Growers’ Association’s director of policy development, gives credit to Miller and the CRSC team for the work they’ve done so far.

The Canadian Canola Growers’ Association (CCGA) “role in this is to ensure farmers are part of the consultation, that they have the opportunity to have their feedback heard, and that their feedback is thoroughly considered. I do think that was done by the CRSC. I think the CRSC took farmers’ concerns seriously and was right to take a step back to address those in terms of the timelines. We look forward (to seeing) the White Paper and having further conversations.”

Miller says that, in retrospect, CRSC should have started with the analysis and White Paper, prior to rolling out a draft code of practice.

“Those who we had around the table (when we drafted the Responsible Grain code) saw it as a need that we should take leadership to address sustainability issues, both from a public trust and market access perspective,” explains Miller. “But it was a faulty assumption that that perspective was widely shared.

“We based (the draft code) on our own knowledge and assumptions, and the assumption that a sufficient portion of the industry shared our knowledge and conclusions. Once we received the feedback from farmers on very fundamental questions, we realized that maybe we missed a step. If we could do it again, we’d do it the other way around.”

Future of the Responsible Grain Code

Whether industry chooses to move forward on a code of practice or another tool, and either on behalf of all grain producers or by commodity group, will depend on producer engagement from here.

“Our intention is to have broad conversations with farmers. We’re not consulting on the results, we want to engage in discussion,” says Miller.

“What I want farmers to know is that we heard you. We want to answer your questions and have a discussion. We don’t have any preconceived expectations about what’s next beyond having a conversation based on the data you requested.”

It’s critical that farmers engage in and provide authentic feedback to the upcoming discussions, says the CCGA’s Mayer.

“We really need to hear what farmers think and where they see value in all of this. Farmer feedback is absolutely critical in this whole discussion. There’s no value in (a code or any other tool) if there’s no farmer buy-in.

“We do have challenges in our industry with public trust and meeting the sustainability demands of food companies as to whether a code can address those, we first need to have a better understanding of those challenges and then we can discuss whether a code is the right way to go about addressing them,” she adds. “Is there enough value to go down that path? That’s what the discussion is about.”

While a code of practice is certainly not the only option available to grain producers, fostering and proving sustainable production practices is already necessary and will only become more critical, say both Mayer and Miller.

“Sustainability is everywhere. If you look at the landscape of major food brands, they’ve all made sustainability commitments,” says Miller. “It’s not enough for those food companies to focus only on their own performance. Now, the pressure isn’t just on how they manufacture, it’s also extending to responsible sourcing.”

“The concept that a code of practice (for grain farmers) might be a potential tool to help was conceived three years ago. In the intervening years, that need has only increased. If the decision is made that a code of practice is not the right tool, the challenge doesn’t go away.”

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