Seed Today - Q1 2009 - (Page 56)

Label Claims and Tolerances Tolerances should never be used to inflate label information This article is taken from a presentation by Larry Nees, Seed Administrator, Office of Indiana State Chemist & Seed Commissioner at the Indiana Crop Improvement Association’s (ICIA’s) 109th Annual Conference Feb. 5 - 6, 2009 in Indianapolis. label)—to the purchaser. ity of seed—a biological This “guarantee” attests to entity, one that’s living, the quality of the product. breathing, dying, and What do we consider to changing. be “labeling” for a seed It doesn’t make sense to product? In Indiana, any utilize exact test results and written, printed or graphic make them your guarantee. representations accompaFor instance, taking a 98 nying the seed lot compercent germination score prises the “labeling”. Anyfrom an analysis and makLarry Nees at the ICIA thing on the tag and/or bag ing your germination guar2009 Conference is included in that definiantee 98 percent doesn’t tion. seem too reasonable due to Label guarantees must be based on the variability of this biological entity test information obtained from an we call a seed. analysis of the seed lot prior to distriA guarantee should be established bution of the seed. Thought must be within a reasonable range of such a test given to establishing “reasonable” score to accurately represent the viabilguarantees for purity and germination. ity but provide a cushion of confidence Reasonable consideration should be that the guarantee stands a good chance given because of the natural variabilof being accurate. S tate and federal seed laws in the Unites States require the labeler to provide basic labeling information to purchasers of seed products that truthfully represent the quality of that seed in relation to identity, purity and viability. This information allows the consumer to make intelligent purchases of those seed products. So, in a sense, the labeler makes a “guarantee”—in writing (the Can Tolerances Be Used With Label Information? Tolerances are provided to account for the unavoidable variation in sampling and testing. Tolerances represent the expected or normal variation between two tests conducted independently of each other. In seed testing we routinely utilize “tolerances” to determine if one test is within reason of another. Perhaps a better term than “tolerance” is needed to represent this variability. I suggest we refer to it as “Permitted Analytical Variation”. We would say this is a permitted variation that is allowed when accounting for sampling and testing deviations from the measured dimensions. Tolerances are not to be applied prior to labeling by adding to the results found by a test. Tolerances should never be used for the purpose of inflating label information to show higher quality than is actually found by a test. Establishing “reasonable” guarantees based on accurate and truthful test results is a labeler’s way of building in a sensible tolerance for claims made. Response No. 561 56 First Quarter 2009 http://www.seedcounters.com

Table of Contents Feed for the Digital Edition of Seed Today - Q1 2009

Seed Today - Q1 2009 Contents Editor’s Notes Tri-State Seed LLC Blue Mountain Seed, Inc. Clearwater Seed According to ASTA Risa DeMasi Crystal Fricker AOSCA AOSA/SCST Oxbo International Hamer LLC Perten Insturments Taylor Products BinMaster Level Controls Dean Cavey Farmer Suicides in India: A Social Concern Unrelated to Bt Cotton Ad Index

Seed Today - Q1 2009

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