of Soil Scientists
Mon-Fri, 8-5 p.m.
Office of Indiana State Chemist
© Copyright -
All Rights Reserved
SEASONAL ISSUES AND CONCERNS
following topics are some of the current issues/concerns that the office
of Indiana State Seed Commissioner has been involved with in regard
to inspectional observations and "frequently asked questions" received
from seedsmen and consumers in the state of Indiana. This listing will
be continually updated to address new issues and answer new questions
that surface during the current season.
Coloration on Treated Seed
area of concern particularly during the spring and fall seeding season
in 1996 involved the use of seed treatments and final appearance of treated
seed once pesticides had been applied to provide for protection from certain
diseases and organisms once the seed was planted. The concern is the lack
of "adequate coloration" applied
to treated seed to provide an adequate "contrast" to that of
The requirement to "dye" treated seed a contrasting
color is contained in regulations of the Federal Food, Drug,
and Cosmetic Act, administered by FDA in the United States. Section
2.25 of Regulation 408, which states, in part:
2.25 Grain seed treated with poisonous substances; color
identification to prevent adulteration of human and animal food.
... A suitable color for this use is one that is in sufficient
contrast to the natural color of the food seed as to make admixture
of treated, denatured seeds with good food easily apparent, and
is so applied that it is not readily removed.
The Office of the Indiana State Chemist & Seed Commissioner cooperates
with FDA under written contract to perform inspections and enforce various
regulations requested by FDA in the administration of the F,D, & C
Act. The major concern with improperly colored treated seed is the potential
for contamination of untreated grain, particularly when individuals are
tempted to dispose of a few remaining bags of treated seed leftover after
planting into a load of grain destined for the local elevator. It therefore
becomes a "food safety" issue requiring serious concern. With
this in mind, let's explore the issues surrounding this concern.
What's the problem?
During the fall planting season of 1996, OISC inspectors began
noticing several lots of wheat seed, labeled as being treated, but showing
no obvious signs of being dyed a contrasting color. This seemed to be
consistent with many of the new seed treatment products introduced into
the market within the past few years, along with some of the established
products that may have been reformulated. Apparently, the use of the
traditional dyes used for many years, have been replaced by newer "food
coloring" agents that are approved as "food grade" colorants.
That, coupled with the reduced rates of treatments used, apparently is
causing some seed that has been treated at recommended rates, to come
out of the treater with no coloration (red, blue, purple, green, etc.,)
showing on the seed. It has also been noticed that some specific varieties
of soft red winter wheat, namely Patterson, do not stain well with the
food colorants being used.
How can it be corrected?
Chemical suppliers of seed treatment products are suggesting
that the treater simply add some additional colorant to the batch
to provide a heavier concentration of the coloring agent. This
seems to adequately correct the problem and results in a product
that does come out with enough of a contrasting color to be distinguished
from untreated grain of the same kind. Perhaps other types of "surfactants" can
be used to enhance the final color, i.e., provide better coverage
to result in a better stained seed.
A word of Caution to the those who treat
Pay close attention to the final seed product coming out
of your treaters. Is it adequately colored? Can you detect an obvious
color difference between the treated seed and untreated grain?
Don't take things for granted. If it doesn't look right, make some
adjustments to compensate for the lack of coloration. The Office
of the State Chemist & Seed Commissioner will continue to monitor
this situation in the coming season to fulfill our obligations
to FDA in enforcing the F,D, & C Act. Seed lots encountered
by inspectors in retail channels which have been treated with pesticides
that show no obvious coloration will be handled appropriately to
avoid the potential for contamination of untreated grain.
Test Date Documentation Seed
laws require the labeler to state the "date of test" on
the label as an indication of "freshness" of the seed.
Section 4(h) of the Indiana Seed Law mandates the labeler to show "the
calendar month and year" the test was completed to determine
such percentages. That month and year should correspond to a test
that was completed on the lot to determine quality, on which label
claims were based. As an example, if the only test performed on the
lot was done in November 1995, it is a violation of this section
to show a test date of January 1996. The principle of "truth-in-labeling" applies.
About testing ....
The Indiana Seed Law requires that seed be tested to
document label guarantees. Section 6(a)(1) states: "It
is unlawful for any person to distribute agricultural or vegetable
seeds within this state (1) unless the test to determine the
percentage of germination required by sections four and five
shall have been completed within a nine (9) month period, exclusive
of the calendar month in which the test was completed immediately
prior to distribution."
Some key points made by this section include (1) a test must
be made to determine seed quality and to support label claims,
(2) the test to rely on would be the most "recent" one
made immediately prior to distribution, and (3) the test information
is valid for a period of nine months.
Who must do the testing?
The law does not require that testing be done by any
particular laboratory. It simply states that a test must be done.
This can include tests performed by a seed certification agency,
other commercial laboratories, the state laboratory, or an "in-house" laboratory
maintained by the seedsman.
for Relabeling Carryover Seed When
agricultural and vegetable seeds remain in the inventory of a distributor
after the germination test has expired (9 months) the seed must
be removed from sale or relabeled. New percentages of germination
and hard seeds, where applicable, and the new germination test
date may be entered on the tags previously attached to the seed
only if these items are inserted in such a way as to be clearly
legible and the old percentages of germination, hard seeds, and
the date of test are completely obliterated. In all cases where
such changes are necessary the attachment of new tags is advised.
The person upon whose premises the seed is located
shall be held responsible for obtaining the new test and for
subsequent relabeling of the seed.