The GIAC requests a review of the current grading standards/policies as it pertains to customer load orders for items currently being considered as “self-imposed limits”, to allow for grading/certification of these items as a function of the official grade and certificates.
Export customer requirements are evolving to include more specificity than the traditional FGIS grade factors/procedures allow. These requests that are not certified by FGIS personnel are then inserted as “elevator instructions” on the official load orders and require the loading elevator or a third party/independent lab to verify, thus causing duplicate management, grading and paperwork for items that are already being officially graded and documented by FGIS. This duplicity seems contrary to the AMS mission to create marketing opportunities for and help facilitate trade for US food and feed products.
Examples of typical load order requests that currently require “elevator instructions”:
- Heat Damage: Average 0.0% or less, Maximum 0.2% per sublot
- Protein average of 14.0 or more, with a Minimum of 13.8 for each sublot
Page 1-10 of Book III states it is the shipper’s responsibility to maintain and self-imposed limits on an average request. When “average” factor result inspection is requested, it is the loading elevator’s responsibility to meet the quality level specified in the contract. The final inspection certificate for “average” factors is based on the final factor average.
- WWH with WHCB not less than 25% average
Book 3 page 1-15: d. Average quality is not applicable to class, (except for grains where class is a grading factor) subclass and special grades. Breakpoints and starting values are applied to factors not applicable to average quality. Sublots exceeding the breakpoint are declared material portions.
Each of these above cases has a different technical reason for utilizing the “elevator instruction” method for adherence to the customer load order. However, in each case, they are factors that are already being graded and reported by FGIS for the official grade but are not indicated in any way by FGIS to the loading elevator. By using the “elevator instructions” method, the loading elevator personnel must notice the grade, and the only option is to EER the sublot should it not meet the specification of the elevator instruction. EER is an acceptable solution, however the intent of this review request is to have FGIS assist with reporting/certifying of the requested grade factors in accordance with the requested load order.
The GIAC recommends that a mechanism to report/certify all parts of a customer’s load order be implemented, specifically for grade factors currently using the “elevator instructions” section due to current Handbook policies and procedures.