Memoranda of the Canadian Grain Commission

Storage of grain on the ground, in bunker storage, or other storage alternatives

Trade memo number

2026-05

Date issued

2026-08-01

The purpose of this memo is to remind licensees that paragraph 16(a) of the Canada Grain Regulations requires that the operator of a licensed elevator store all grain received in an elevator building.

The Canadian Grain Commission can, in most circumstances, exempt a licensed elevator from the regulation prohibiting storage of grain outside of an elevator building. To be considered for such an exemption, elevators must submit a written request to the Canadian Grain Commission, advising:

• how the grain will be stored — on the ground, in bunker storage, in grain bags, in railcars, or other method
  • bunker storage is defined as a structure that is part of the premises of a licensed elevator, but not part of the elevator itself
  • to be considered bunker storage, the structure must be fully enclosed and have a concrete, asphalt, or other prepared base^{Footnote 1}, rigid and self-supporting sidewalls, door(s), and a cover
  • all non-concrete or non-asphalt bases for bunker storage that have not previously been approved by the Canadian Grain Commission must be inspected and approved by the Canadian Grain Commission prior to an exemption being granted
• the kind and quantity of grain to be stored outside of the elevator building
• the date that grain to be stored outside the elevator building will be received and the date that this same grain will be discharged

The responsibilities of elevator operators are the same for grain stored outside of the elevator building and for grain stored in the elevator building. Upon delivery of the grain to be stored outside of the elevator building, a primary elevator receipt, grain receipt, or cash purchase ticket must be issued to the party delivering the grain. Depending on how the grain is being stored and/or the type of structure being used, security requirements may be impacted.

Once all grain that was stored outside of the elevator building is shipped, the elevator operator must advise the Canadian Grain Commission in writing.

Requesting an exemption

Requests for exemptions and follow-up information regarding shipping of grain should be sent to:

Sanjiv Sharma, Program Manager, National Inspection Procedures and Regulatory Compliance, sanjiv.sharma@grainscanada.gc.ca

It is necessary to apply for an exemption for each occurrence of grain that will be stored outside the elevator building.

The Canadian Grain Commission may monitor shipments from exempted facilities for quality problems. Failure to request an exemption for grain stored outside an elevator building may result in licence suspension.

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