While the November 2010 elections reduced the likelihood that some legislative initiatives adverse to agriculture would be passed in Congress, “the reality is that regulation could and would be used to achieve the goals of activists who are now in power,” says Kent Fountain, president of the National Cotton Ginners Association.
The Obama administration “has backed off some of the initiatives,” he said at the annual meeting of the Southern Cotton Ginners Association, held in conjunction with the Mid-South Farm & Gin Show at Memphis, “and we can hope that this change in tone will persist for the next two years.”
Nonetheless, says Fountain, a Georgia producer/ginner, there are key issues that the NCGA and its member organizations are monitoring closely. They include:
— Changes in Congress, in particular those for the House and Senate Agriculture Committees.
Industry leaders will have “a full agenda in educating new committee members, many of whom are freshmen lawmakers,” Fountain says.
“These new faces on committees, coupled with budget concerns and the World Trade Organization’s Brazil ruling, will have major implications for the 2012 farm bill debate and the cotton program.
“We’re already seeing the budget hawks taking shots at agricultural spending, and I assure you these arguments will continue throughout the budget debate, the appropriations process, and the writing of the new farm bill.
“Even with several pieces of onerous legislation and proposed rules either pulled or modified, there are a number of regulatory initiatives that may potentially have an impact on our industry,” Fountain says.
“It is important that we continue to maintain a strong working relationship with the National Cotton Council and rely heavily on its Washington staff.. Many of the regulatory issues that face ginners are being monitored by the council’s Technical Services Department.”
— Air quality concerns, ranging from the current implementation of regulations to climate change legislation and other issues.
“With prompting from the California Cotton Ginners Association three years ago, the decision was made that our industry should develop a plan to obtain accurate measurements of emissions from gins across the cotton belt,” Fountain says.
Sampling of gins has now been done in California, New Mexico, Texas, and Missouri, and this fall researchers will sample a gin in North Carolina.
“We’re hoping that during this first quarter 2011 that preliminary data from this study can be made available.”
Potential new air quality standard
A new national ambient air quality standard is being considered, he says, which would call for a decrease in the current course particulate matter threshold by roughtly 50 percent.
“This new standard could be significant,” Fountain says, “because it could put more regions of the cotton belt into a non-attainment status, causing gins to resort to more costly pollution controls. This possibility continues to be a major concern for our industry.”
— Occupational Safety and Health Administration-related proposals, which could have an impact on gins and other industry sectors.
In recent NCGA committee meetings, Fountain says, “We have been told by a former OSHA official that the agency’s philosophy has changed under the current administration, and that we are in an environment favorable toward both labor and labor unions.
“OSHA has shifted its focus to enforcement, we are told, and has increased both the frequency of inspections and fines for violations. Labor unions are pursuing many changes in the workplace environment and are using OSHA and its regulations to achieve their goals.”
A second former OSHA official has said that recordkeeping, respirable dust, and the implementation of combustible dust regulations “are OSHA priorities,” Fountain says.
“With OSHA’s target issues being the noise standard, the implementation of an illness/injury protection program, fall protection systems, and combustible dust, it is sobering to note that in two years’ tie we could have some type of rulemaking under way for each of these priorities.”
— Employment issues, such as overtime and bonuses, “tend to cause problems for many of our ginners,” Fountain says.
“The NCGA has updated our labor guide go assist ginners in adhering to labor regulations.” Various materials related to labor regs and employment of migrant laborers can be found on the organization’s website.
“With increased enforcement and the possibility of fines, it is incumbent upon ginners to insure that they are abiding by all labor laws and OSHA rules and regulations,” he says. “Our Ginners Labor Guide is an excellent resource for insuring compliance with these rules.”
Bale moisture restoration, measurements
— Bale moisture restoration and moisture measurements, and the fiber damage that can occur over time from excess moisture.
“Studies by Rick Byler, with the USDA Ginning Laboratory at Stoneville, Miss., have concluded that when restoring bale moisture, 7.5 percent wet basis is a reasonable upper limit for bale moisture content, but the 7.5 percent figure should not be considered a target for moisture content.”
Fountain said Byler has also done evaluations of various types of moisture measurement technologies, particularly hand-held meters.
“His analysis was that all meters are inherently inaccurate, with uncalibrated meters having a high error.”
Even after each meter was individually calibrated, the standard error was nearly 1 percent. In addition, a number of factors, such as bale weight, timing after moisture is applied, and ambient temperature, can influence the results of these specific measurements, Byler reported.
“We realize there were issues with an incredibly wet fall in 2009 and with bale moisture in some areas of the Southeast for the 2009 crop,” Fountain says. “These concerns prompted calls for a review of current policy.
“The National Cotton Council has asked the Memphis Cotton Exchange to review their rule pertaining to bale moisture, and it is our understanding that review is under way. The NCGA has also named a committee of ginners who will meet later this year to review moisture restoration and to make recommendations, if necessary.
— Fiber quality issues. The NCGA is “keenly aware of the importance of providing the highest quality fiber possible,” Fountain says, “and we are continuing to work with the USDA Ginning Laboratories and with Cotton Incorporated to insure that quality-related research is conducted.
“Our goal should be to produce the best quality fiber in the world, and in 2009 the NCGA began a dialogue with our foreign mill customers to promote the quality of U.S. cotton.
“We are committed to increasing fiber quality, and our industry is doing everything possible to insure that we are meeting the needs of our foreign customers. NCGA will make several presentations later this year to promoted U.S. cotton quality and to discuss several ongoing projects to improve fiber quality.
“To do this, we rely heavily on the ginning labs for much of the basic research that has brought fiber quality improvements,” Fountain says.
“With every federal agency’s budget being scrutinized, it will be even more important that we support the industry’s three USDA ginning labs. With the focus on quality and ginning efficiencies, it is imperative for our industry to work to keep our ginning labs adequately funded so they can continue their valuable work.