Alfalfa industry objections to tagging Roundup Ready alfalfa bales individually after a court order reversed the deregulation of the crop have led to additional options in identification requirements. Growers can now identify genetically modified alfalfa by lot, according to Tom Sim, director of the Biotechnology Regulatory Services’ Regulatory Operations Program under USDA-APHIS.

“The original administrative order that was issued in July had a requirement in it that each individual bale had to be tagged, and that was a hardship for producers who sell large quantities of alfalfa,” says Sim. “So the industry came to us and asked us if we could consider sales of hay by lot and if they could identify those lots by number of bales.”

On Dec. 18, APHIS issued a supplemental administrative order specifying mandatory practices that growers of Roundup Ready alfalfa would have to implement. Allowing growers to identify hay by lot made sense, Sim says.

“It would expedite the handling and sales of the product, wouldn’t put people in danger of climbing up on stacks trying to label each bale and would also reduce potential injury to animals, avoiding ingesting the wire or string from the tags on the bales,” Sim says.


According to the revised order, all Roundup Ready alfalfa and/or Roundup Ready alfalfa mixed with conventional alfalfa that leaves the farm it was produced on -- or that is taken from a reseller’s location -- must be clearly labeled by lot identification and documentation or by individual bale.

If a grower identifies Roundup Ready products by lot, vehicles transporting them must each bear a sign no less than 8.5 x 11” in size that’s marked “Roundup Ready Alfalfa.” The vehicles also must carry the following documentation:
1) Roundup Ready alfalfa designation.
2) Name, signature and address of buyer.
3) Name, signature and address of seller.
4) Name and address of hauler.
5) Lot number.
6) Unit count (number of bales).
7) Weight.
8) Scale and ticket number.
9) Shipment date.

Growers choosing to separately identify Roundup Ready alfalfa and/or Roundup Ready alfalfa mixed with conventional alfalfa must securely attach to each bale a tag marked “Roundup Ready alfalfa.”

The December order provided additional information on cleaning equipment, Sim says. “We didn’t have any provisions in the order from July about cleaning large square bale equipment, and we had some assistance from extension service people to cover that.”

The addition requires a grower, after baling Roundup Ready alfalfa, to eject any remaining material from a baler with an ejection system and leave it in the field just baled. Then at least one bale from a non-Roundup Ready alfalfa field must be made and marked, handled and stored with Roundup Ready alfalfa or be destroyed. Exterior parts to the large square baler must be swept, blown with forced air or washed.

Balers without ejection systems must make at least two non-Roundup Ready alfalfa bales in a non-Roundup Ready alfalfa field. Those bales also must be marked, handled and stored with Roundup Ready alfalfa or be destroyed. The exterior also must be swept, blown with forced air or washed.

For exact wording of the order, visit: www.aphis.usda.gov/brs/pdf/RRA_A8_final.pdf.