Language selection

Government of Canada Gouvernement du Canada

Search

Memoranda of the Canadian Grain Commission

Application of mineral oil to grain regulated by the Canadian Grain Commission

Trade memo number
2026-02
Date issued
2026-08-01

This memorandum provides supporting information to implement the Canadian Grain Commission Order Number 2026-28 respecting the application of mineral oil to grain.

Scope

The Canadian Grain Commission Order pertains to the application of mineral oil to grain, destined for the export market, at licensed terminal elevators in Canada that satisfy the requirements of the Order. Grain refers to only those seeds designated by regulation as a grain for the purposes of the Canada Grain Act (CGA). The Canadian Grain Commission Order does not permit:

  1. Application of mineral oil at any location other than licensed terminal elevators in Canada (e.g. primary elevators, feed mills, or processing facilities); or
  2. Any dust suppressant other than food grade mineral oil (e.g. canola, corn or soybean oil, or water).

Authority

The Canadian Grain Commission’s authority on dust suppression is pursuant to the CGA and Canada Grain Regulations (CGR). Subsection 104(d) of the CGA requires operators of licensed elevators to have the permission of the Canadian Grain Commission to “mix with any grain in the elevator any material other than grain”.

The Canadian Grain Commission allows licensed terminal elevators to apply food grade mineral oil to grain only at a maximum of 0.02% by weight as an aid in dust suppression during the receipt, handling and/or discharge of grain, in accordance with the terms and conditions of the Order.

Prohibition

Under section 104(d) of the CGA, it is prohibited for any operator of a licensed elevator to mix any material with grain, except other grain, unless it is permitted by the Canadian Grain Commission. Under section 105(c), it is prohibited for any person to sell, store or obtain inspection of grain that is “so treated, mixed or dealt with as to conceal its true characteristics”. The application of water to grain may conceal its true characteristics. Application of water to grain is not permitted by the Canadian Grain Commission.

Mineral oil specifications

Mineral oil applied to grain must meet food grade specifications as prescribed by Health Canada.

Section B.01.045 of the Food and Drug Regulations (FDR) requires that food additives that do not have specifications set out in Part B of the FDR meet the most recent specifications set out in the Food Chemicals Codex (10th ed. 2016) or the Combined Compendium of Food Additive Specifications. The Food Chemicals Codex is a compendium of standards for purity and identity for food ingredients, including food additives, published by the United States Pharmacopeia Convention. The Combined Compendium of Food Additive Specifications is prepared by the Joint Food and Agriculture Organization (FAO)/World Health Organization (WHO) Expert Committee on Food Additives and published by the FAO of the United Nations.

Questions related to the specifications as prescribed should be directed to Health Canada or the supplier of the mineral oil.

Initial request process

To have the Order apply, licensed terminal elevators must make a one-time request to the Canadian Grain Commission. The following information is required as part of the request process and the necessary form is attached:

  1. Terminal elevator making the request.
  2. A description and schematic of all equipment to be used in the application of mineral oil (e.g. storage tanks, oil pumps, lines, regulators, meters, application nozzles), including the number of application nozzles and the location where the application nozzles will be installed.
  3. The points at which the mineral oil will be applied at the terminal elevator:
    1. on receipt of grain
    2. during the handling and/or cleaning of grain, and/or
    3. on discharge of grain
  4. A detailed description of the measures in place for the terminal elevator operator to verify, on an ongoing basis, even application and that the application rates of mineral oil are within permitted tolerances.
  5. A detailed description of the measures in place, or the work instruction, to be followed in the event of excess application of mineral oil or mineral oil spills.
  6. Identification of visual monitors and/or devices that are accessible to Canadian Grain Commission staff for periodic verification of the application of mineral oil.
  7. The intended application rate for each application of mineral oil, expressed in a percentage by weight.
  8. The nature and type of records that will be maintained and made available to the Canadian Grain Commission upon request.
  9. A copy of documentation of the properties and specifications of the intended mineral oil which demonstrate that the mineral oil meets food grade specifications. and
  10. The density value of the intended mineral oil.

Upon receipt of an email or written acknowledgement from the Canadian Grain Commission that the initial request for the application of mineral oil is complete and approved, the Canadian Grain Commission Order will permit the operator of the licensed terminal elevator to apply mineral oil to grain, in accordance with the terms and conditions of the Order.

Requests should be submitted to Derek Bunkowsky, Chief Grain Inspector for Canada, at derek.bunkowsky@grainscanada.gc.ca.

Responsibilities of the terminal grain elevator

Equipment and devices

As a general condition of licensing, section 16(b) of the CGR requires that an elevator operator “notify the Commission, in writing, of any functional alteration to the elevator building described in the application or any functional alteration respecting grain flows or sampling or control mechanisms, and of any addition to any equipment associated with the elevator, within 15 days after plans for the alteration or addition become available”.

The applicant must install and maintain equipment for application of mineral oil in accordance with the manufacturer’s guidelines. It is the responsibility of the applicant to ensure that all equipment, product and storage tanks meet any civic, provincial or federal legislative and regulatory requirements.

Application of mineral oil

Under the terms of the Order, mineral oil may be applied to grain upon receipt of grain into a terminal elevator, during the handling and/or cleaning of grain, and/or upon discharge of grain from a terminal elevator. However, the application of mineral oil must be performed prior to official sampling and weighing upon discharge of grain from the terminal elevator.

It is the terminal elevator’s responsibility to ensure that mineral oil is applied in a manner that provides for thorough mixing and promotes even coating of grain streams. If a terminal elevator chooses to apply two or more smaller quantities of mineral oil to the same lot of grain, the sum of all applications must not exceed 0.02% by weight of the grain.

Reporting and recordkeeping

Terminal elevators are required to report to the Canadian Grain Commission in the following manner:

Prior to loading a vessel with grain treated with mineral oil, the terminal elevator operator must notify the Canadian Grain Commission of mineral oil application as part of the current process for submission of Vessel Loading Orders to the Canadian Grain Commission. The Vessel Loading Order must now include all of the following information:

  1. Grain tonnages to be loaded and the intended average mineral oil application rate. Grain volumes must be reported in metric tonnes and mineral oil application rates in percentage by weight of grain loaded.
  2. A reference that mineral oil has been applied to grain only at a maximum of 0.02% by weight.
  3. Confirmation that the purchaser of the grain accepts the application of mineral oil.

If any anomalies with the application of mineral oil are experienced at any point in the mineral oil application process, as per section 76(1) of the CGA, such anomalies must be reported to the Canadian Grain Commission.

Notification and reports are to be provided to the respective Regional Manager of Inspection Services at:

Records

Records shall be maintained in a form readily available for inspection by the Canadian Grain Commission and must include all of the following information:

  1. Mineral oil application rates applied upon receipt, during handling, cleaning and/or upon discharge of grain in order that application rates and tonnage can be provided to the Canadian Grain Commission upon vessel hold completion.
  2. Volumes of mineral oil purchased.
  3. Quality properties and specifications of mineral oil purchased.
  4. Maintenance and/or replacement of equipment used in the application of mineral oil.

All records shall be kept for a minimum of two years.

Monthly reporting

All the following information shall be collected, recorded, and reported to the Canadian Grain Commission on a monthly interval:

  1. Name of the terminal elevator.
  2. Total tonnage of grain to which mineral oil was applied during the month.
  3. Quantity, in litres, of mineral oil applied to that tonnage of grain during the month.
  4. Copies of all documentation indicating the mineral oil supplier’s name, address and date of delivery, litres of mineral oil supplied, and product data to demonstrate that the mineral oil meets food grade specifications in Canada and density values.
  5. Average application rate of mineral oil applied, expressed in percentage by weight of grain.

The information for each month shall be provided no later than seven calendar days from the end of that month (e.g. information for January shall be reported no later than seven calendar days into February).

Monthly reports are to be submitted to Derek Bunkowsky, Chief Grain Inspector for Canada, at derek.bunkowsky@grainscanada.gc.ca.

Monitoring and enforcement

The Canadian Grain Commission will review all monthly reports submitted by terminal elevators to ensure compliance to this policy. Authorized Canadian Grain Commission representatives must be permitted access to terminal elevator premises and records on request for compliance purposes.

In addition, the Canadian Grain Commission may, on an ad-hoc basis, analyze a portion of the sample obtained during the official sampling, to verify that the amount of mineral oil compounds present is within compliance. If Canadian Grain Commission monitoring indicates that levels of mineral oil compounds are not within acceptable tolerances, terminal elevators will be notified.

Inquiries

Questions related to this memorandum should be directed to Derek Bunkowsky, Chief Grain Inspector for Canada, at 204-297-8541 or by email at derek.bunkowsky@grainscanada.gc.ca.

Derek Bunkowsky
Chief Grain Inspector for Canada
Industry Services
800-303 Main Street
Winnipeg MB  R3C 3G8

Page details

2026-08-13