Record Keeping Requirements
RECOMMENDATIONS FOR "COMPLETE RECORD" REQUIREMENTS:
Using Federal Seed Act Regulation 201.2(1)(1) as a guideline, the following items should be a part of the "complete records" for each lot of seed sold.
1. LABEL COPY maintain a copy of the original label, and any modifications made to it during the time of distribution.
2. ORIGIN source of the seed lot, i.e., grower, field location, broker, wholesaler, etc. Where did the seed originate from?
3. VARIETY records should verify the variety of the seed. This would include verification of private lines (the true variety designation, how it is sold to you). This information should be maintained even though the seed may be sold under the "variety not stated" labeling option.
4. TEST INFO include copies of the results of all laboratory tests performed for purity and germination, and any other additional tests made.
5. CONDITIONING Cleaning, handling, bulking, storage, etc. Include dates of when particular tasks were performed, and perhaps a "cleaning sequence" log, verifying when a lot of seed moved through the conditioning plant.
6. TREATMENTS substance used, rates of application, dates of treatment, etc. If treatment was done by another person, indicate so and obtain that information from the treater.
7. SALES maintain a record of all sales of each lot, and include lot numbers on sales invoices.
8. SAMPLES maintain a file sample for each lot for 1 year after final disposition of the lot.
RECORD KEEPING REQUIREMENTS FOR SEEDSMEN
Businesses are constantly burdened with requirements of both Federal and State laws to maintain records of your business activities to document various things. Although we might think some of these requirements are frivolous and a "nuisance," in the long run it pays to keep good records to "verify" what you've done. Such documentation is a part of "Good Business Practices." It makes sense to cover yourself in the unlikely event that some customer comes back to you with a complaint against your product. If his claim is "poor germination" with the seed he bought, can you document that the seed lot was indeed of good quality? If you had maintained records of lab tests performed to support your original label claim for the seed you at least can document your reasons for the label guarantees.
It makes sense to maintain some "basic" records in the seed business. It's also a requirement of the Indiana Seed Law and the Federal Seed Act to maintain records relating to the origin, identification, sales and distribution of seed products. Under the Indiana Seed Law, Section 15-4-1-7 refers to the record keeping and file sample requirements. It is worded as follows:
"Each person whose name appears on the label as distributing agricultural and vegetable seeds subject to this act shall keep for a period of two (2) years complete records of each lot of seed distributed and keep for one (1) year a file sample of each lot of seed that is distributed after final disposition of said lot...."
What are "complete records"? This sounds like an all-inclusive term that covers absolutely everything you would ever need to know. Sounds simple, but not necessarily so. The seed law further defines the term "record" as:
"The term "record" shall mean all information relating to the shipment or distribution of a lot of seed and includes a file sample of each lot of seed."
So what kinds of specific records are seedsmen required to maintain? Fortunately, the Federal Seed Act provides us with a bit more guidance and many more specifics about record keeping. The definition of "complete record" under the FSA Regulations, contained in Section 201.2(1)(1) states:
"The term 'complete record' means information which relates to the origin, treatment, germination, and purity (including variety) of each lot of seed transported or delivered for transportation in interstate commerce.... Such information includes seed samples and records of declarations, labels, purchases, sales, cleaning, bulking, handling, storage, analyses, tests, and examination."
INDIANA SEED LAW REQUIREMENTS
Records: shall be kept for a period of 2 years for each lot of seed distributed after final disposition of said lot.
File Sample: shall be kept for a period of 1 year for each lot of seed distributed after final disposition of said lot.
FEDERAL SEED ACT REQUIREMENTS
Records: shall be kept for a period of 3 years for each lot.
File Sample: shall be kept for a period of 1 year for each lot after final disposition of lot.