Puzzling Truths In Labeling
The issue of seed testing uniformity is a complex and convoluted problem with many players and facets involved. There’s thousands of seed species, nearly a hundred labs, multiple testing methods, governance and compliance.
After having been in the seed testing industry for 34 years, I’ve seen just about everything. While I applaud the Association of Official Seed Analysts, the Society of Commercial Seed Technologists and the American Seed Trade Association for under-taking this issue, I caution that it’s not just about the diversity of seed species and testing methods.
From my perspective, the bigger issue is whose “truth” does a labeler use? But in reality, it doesn’t matter if a labeler chooses to use test results from Lab A versus Lab C because it’s the regulatory lab’s test results that are the “truth.” Right or wrong, perhaps more examples of wrong than right, the regulatory lab has the last say, and the company that printed the label either has to over label with that “truth” or remove the seed for sale, in addition to paying a fine.
“The bigger issue is whose ‘truth’ does a labeler use?”
— Sharon Davidson
Testing Within Tolerance
A recent example is a label developed from a blend sheet. Regulatory picked up a box to test and found that the percent annual ryegrass was out of tolerance, which led to the issuance of a stop sale. This same sample was sent to the federal laboratory in North Carolina and a private lab only to find that the federal laboratory, the private laboratory and the seed tag were well within tolerance. It was the regulatory lab that was out of tolerance.
When questioned, the regulatory lab reported that it followed the method in the AOSA Rules for Testing Seeds handbook, however the technician only tested 200 seeds instead of 400. This leads me to wonder what other short cuts are taken? Is there a dark room for fluorescence testing? How old is the blue black light used? Is the media Whatmans No. 1 filter paper? But all of these questions are irrelevant because the regulatory lab is always right.
Again, whose “truth” should be used for labeling because by the time all this was discovered, the seed was mislabeled to meet the stop sale demand and sold out.
The concept of achieving uniformity among seed testing laboratories is admirable but I believe a critical piece of the puzzle all comes back to dollars — funding for state mandated regulatory labs. In my conversations with folks from state mandated regulatory labs, I hear “we can’t do that; we don’t have funding, space or personnel.” While they might not have the funding, space or personnel, their reports are used to issue a stop sale. And that is a lot of money and in some cases results in the loss of a sales window.
I agree that there needs to be some kind of a “fix” to the whole system. There needs to be a way to remove regulatory authority from labs that are constantly out of tolerance. There needs to be a mechanism by which all labs are held accountable for their laboratory results. Besides those labs accredited by the International Seed Testing Association, there is currently not a mechanism in place. There needs to be a way to tease out the true quality of a lot when a discrepancy occurs instead of stop sale, re-label and fining a company.
What about sampling? Several organizations have sampling protocols, all of which include a trier that reaches at least the middle of the container, yet time and again, photographic proof that 6-inch thief triers are still being used. A test result is only as good as the sample provided.
What about the companies that purposefully shop tests? They know which labs do not find noxious weeds, always get higher purities and the highest germination. There are “go to” labs when the risk of a fine is less than the profit margin they stand to gain. Buy on one lab test, sell on another test is common practice in commerce.
There are a lot of pieces to this multi-dimensional puzzle, and uniformity is just one piece of one dimension.