- Split Shipment by M/V.
How do you handle bookings where the lot is split and the applicant wants to redesignate part of a booking to a new booking. For example, the applicant has 20 containers graded (composite grade on all 20, or 20 individual grades averaged for one certificate) and designated as booking XYZ123, but only 15 of the containers from the booking make the ship. The remaining 5 containers were placed on another ship. The applicant is requesting that the remaining 5 containers be assigned to a new booking (e.g., ABC 456). Can we retract the original certificate for the 20 containers and issue a new certificate for the 15 containers and apply the 5 remaining containers to the new booking?
Answer: First and foremost – we do not reissue certificates because the applicant has restructured the components of the booking. Containers that are inspected as part of one lot (e.g., booking XYZ123) may not be renamed or included as part of a second lot (e.g., booking ABC456). The applicant can request a letterhead statement (GIPSA letterhead stationary) to identify container identifications involved in a split shipment. The letterhead statement must reference the certificate number and certificate date. The letterhead statement may also include a reference to the grade of the shipment (if it is a reference to the inspection certificate) or to the total weight of the lot (if it is a reference to the weight certificate). The applicant may also state the name of the vessel that carried the containers.
Statement example: “The following containers were graded as a U.S. No. 2 yellow soybean as identified by certificate number [show certificate number], dated [show date]. The applicant states that these containers were loaded onto the M/V [show vessel name].”
Following this statement, include the container identifications provided by the applicant. These container identifications must match the identifications, in part, on the referenced certificate.
The applicant may attach a copy of the referenced certificate to the letterhead statement. If another original certificate is needed by the applicant [one for each vessel], the applicant may request and receive a duplicate certificate.
- Split Shipment by Customer
Split shipments are allowed when bookings are split between vessels. Are we allowed to split shipments by customer also?
Answer: Yes. Use the following statement on USDA Letterhead: “The applicant states these containers were sent to Customer” in place of the statement: “The applicant states these containers were loaded onto the M/V show vessel name”.
- Number of containers allowed in a booking
What is the maximum number of containers that may be composited or averaged to form a booking?
Answer: The maximum number of containers that may be inspected as a single lot is 20. This is not necessarily a limit on the booking. A booking of 100 containers could be graded in groups of 20, and then certified together using combined lot procedures.
- Averaging container grades to make a booking
Can an applicant request individual grades on containers then ask for an “average composite” of containers to form a booking?
Answer: Yes, provided that all of the containers that will be combined are uniform with respect to condition (i.e., infestation, odor, sample grade factors, special grades).
- Certificate date
What certificate date should we use if we are grading individual containers to form an average composite ? Do we use the date of the applicants request or the actual date of the last inspection on the booking? For example: a booking of 20 containers (each graded individually) was started on April 6, 2013 and finished on April 9, 2013. The applicant requested an average composite for the booking on April 12, 2013. Which date, April 9 or April 12, do we show on the certificate?
Answer: The date that the last container was graded. In the above example the certificate date would be April 9, 2013.
- Number of separately graded certificates per booking
An applicant has requested two separate export certificates for a booking: one grade certificate from a “composite sample” made from representative portions of each container in the booking, and another from the “average composite” result from individually graded containers. Can we provide two separate certificates for the same booking with identical identifications?
Answer: No, only one export certificate is allowed for the booking. However, the shipper can request an average composite grade for export certification and then request a submitted sample inspection on the basis of a composite sample.
- Multiple sampling methods
Can a booking be inspected as a single lot if it is sampled by various sampling methods? If so, how would it be reported on the inspection certificate?
Answer: Yes, provided that the amount of sample representing the container is weighted according to the weight of the grain loaded into the container. Report all methods of sampling on the certificate.
- Multiple locations
Can a booking be inspected as one lot if it is loaded at multiple locations?
Answer: Yes, provided that the sampling service for all containers is performed by a single inspection agency within their assigned territory. We will not allow multiple agencies to sample containers within a booking and send the samples to another agency for inspection purposes.
- Corrected certificates/letterhead statements
Three weeks ago we inspected and certified several carlots of peas that would be later transshipped into containers in the Pacific Northwest. Now, the applicant for service called and requested “Corrected” certificates for the railcars because they wanted the following information “Applicant states that the peas were loaded into containers ABC and XYZ” added to the certificates. Should we issue “Corrected” certificates or can we issue a letterhead with the requested information.
Answer: Do not issue corrected certificates for the carlots. Do not include statements such as “Applicant states that the peas were loaded into containers ABC and XYZ” on the certificate. After the carlots are graded, promptly provide the certificates for grade to the applicant. It will be the responsibility of the shipper to provide documentation to the buyer that the railcars were transloaded into containers.
- 922 Inspection Volume Report
When numerous containers are loaded, but certificated as only one inspection, how is this reported on the 922 Inspection Volume report? If reported individually, are we paying user fees on all 20 containers, or just the one composite inspection?
Answer: Report multiple containers loaded as a composite the same way that you would report a unit train of 20 railcars that are loaded under cusum, or railcars graded as a composite or combined lot. A unit rate is applied by the official agency for each container included in the composite, and a user fee is also applicable for each container.
- Even though, at the applicant’s request, we are inspecting only one combined sample to issue the certificate, should we be charging for each individual container included in the composite sample?
Answer: Yes, this is basically the same as railcar loading. You charge a fee per unit, whether it is graded individually or within a composite. I believe that many of the official agencies charge a flat rate of approximately $16 per container (individual grade analysis or composite analysis) and also charge an hourly fee for each sampler at a loading location.
- We are sampling a processed product (soybean meal) and performing a phytosanitary inspection. We complete an “Insects in Grain Report”, FGIS 921-2, and forward the report to the shipper. Is it necessary to complete an AMA certificate for the sampling service and furnish a copy to the shipper?
Answer: Issue a certificate upon the request of the applicant for service. If the applicant does not request a certificate it will still be necessary to input the information into the certificate program for the purpose of supplying the inspection data to the Inspection Data Warehouse (IDW).
- Grading and certifying prior to selection
When performing composite sample analysis, can the official service provider grade and certify individual containers prior to the applicant selecting which carriers to combine for composite?
Answer: No, however the applicant can request submitted sample analysis or official commercial inspection service (OCIS) analysis of the containers (components) prior to designating the containers selected for a composite. Another option may be “average composite” grading, where each carrier is graded, but not certified. Then, the applicant selects which carriers they would like to combine and average on one certificate.
- Combining lots when load order specifies limits on factors
Can you combine a single lot (20 containers) of #2 Yellow Corn that has a moisture of 14.5% with a single lot (20 containers) of #2 Yellow Corn that has a moisture of 15.5% and meet the load order requirement of “maximum of 15% moisture”?
Answer: No. If the load order specifies a maximum of 15% moisture, a single lot of 14.5% cannot be combined with a single lot of 15.5% even if it is the same grade because the 15.5% moisture exceeds the 15% limit. However if the load order is silent on moisture then the two could be combined and a mathematical average would be performed equaling 15% moisture.
- Combining average grade/average composite with composite lots
Can you combine an average grade/average composite single lot with a composite grade single to form a combined-lot certificate?
Answer: Yes, an average grade/average composite single lot can be combined with a composite grade single lot as long as long as the combined-lot procedures that are outlined in Code of Federal Regulations 800.85 and FGIS Directive 9180.78 are followed.
- With the new Combined Lot procedures, how should we identify a booking of 100 containers broken up into 5 single lot certificates of 20 each? Should we call them Booking 123ABC #1, Booking 123ABC #2, etc.?
Answer: Identify the lot at the applicant’s request. Currently, booking numbers are used to identify container lots. It is acceptable to continue this practice. At the applicant’s request, identify the lots by the booking number, or any subdivision thereof (sublot 1, sublot 2, group A, etc.). Continue to identify all the containers in the lot in the remarks section of the certificate.
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