- Is official commercial inspection service (OCIS) applicable to container shipments?
Answer: No, OCIS is not applicable to export shipments of grain.
- Combining containers
If the applicant does not specify they want composite sample analysis how many containers can be combined for single grade analysis.
Answer: The default is one grade, one certificate per container.
- Applicant selects containers to be averaged
If the applicant requests individual grades per container can they request an average of certain containers to form a booking.
Answer: Yes, we consider this a form of a composite sample. We refer to this as “average composite”. So, when an applicant specifies they want to use the composite sample method that includes “average composite”. The maximum number of containers that could be combined to form an average composite is 20.
- Loss of identity from overloaded container
An applicant notified us (official inspection agency) several containers that were officially inspected and weighed were overloaded and that grain had to be discharged before it could be shipped. Can the applicant remove some grain from the affected containers without having it deemed as “loss of identity” for the quality analysis? If so, how much can be removed?
Answer: There is no real definitive answer for how much can be removed. Professional judgment must be used to determine whether the lot has lost its identity.
- Options when a container has an odor
What are the applicant’s options for combining a container with an off-odor (sour) with other containers with no odor (ok) to make a composite sample.
Answer: The sample may not be combined with other “sound” grain to form a composite sample. The applicant may request a reinspection, appeal inspection, and board appeal inspection on the sample, may elect to discharge the grain from the container, receive separate certification for the container, or combine the sample with other samples (same class) that have the same type odor to form a composite sample. If the applicant elects to have a review inspection performed on the individual container then all containers that are sampled and inspected within the composite must be inspected at the same level.
- Allowing applicant one combination of containers
Can we honor a request to readjust the mix of containers in an “average composite” booking if the applicant is not satisfied with the average grade of the containers.
Answer: No. Once the applicant has provided official personnel with a list of containers to average for a booking and the certificate has been issued then the “average composite” analysis is considered complete. Official personnel should not honor a request for a new mix of containers for an average composite grade. All containers included in the “average composite” for the booking must remain intact as a unit.
- Options for containers with special grades
What are the applicant’s options if they are requesting a “composite sample” and a sample from an individual container is visually examined and determined to contain a special grade (e.g., garlicky in wheat)?
Answer: Containers that are loaded with grain that have a special grade designation may not be combined with other grain that does not have the same special grade assignment. However, they may be composited or graded as an “average composite” with other samples that are of the same grain class and contain the same special grade assignment.
The shipper has a composite sample load order identifying the special grade WAXY. Do we examine each sample in the composite to identify that WAXY is at least 95% present or just examine along with grade factors on the composite sample?
Answer: Perform the waxy analysis along with grade on the composite sample. If the corn does not meet the requirements for WAXY then all containers in the lot are considered as not waxy. The shipper can request review inspections on the composite sample if they are not satisfied with original WAXY result.
What are the applicant’s options if they are requesting a “composite sample” and grain from an individual container is visually examined and found to meet the sample grade criteria for the grain (e.g., excess number of stones).
Answer: The sample may not be combined with other “sound” grain to form a composite. Use this same criteria if the sampler sees any other obvious inferior condition, like odor, DLQ, or different kind of grain (e.g., more than 10% of soybeans in a corn sample).
- Containers with soybeans that are Purple Mottled or Stained
What are the applicant’s options if they are requesting a “composite sample” and grain from an individual container is visually examined and determined to meet the criteria for “Purple Mottled or Stained”?
Answer: Containers that are loaded with soybeans that have the special grade designation “Purple Mottled or Stained” may not be combined with other soybeans that do not have the same special grade assignment. However, they may be composited or graded as an “average composite” with other samples that are of the same grain class and contain the same special grade assignment.
- Change in condition after sampling
What should we do when compositing samples together for grade we find a sample containing insects after the earlier online condition inspection indicated no insects were present?
Answer: If the individual container sample meets the criteria for “infested” or sample grade due to insects do not combine the sample with other “sound” grain to form a composite. Notify the shipper that the container has undergone a change in condition. The applicant will then have the option of fumigating the container or receiving separate certification.
- Options when container grain is infested
What are the applicants options if during a condition inspection we find a container meeting the criteria for infested?
Answer: The applicant can elect to have the container fumigated, or receive certification for the individual container as “infested”.
- Limit for loading a booking
What is the maximum time span for the composite loading of a booking, from the loading of the first container to the completion of loading for the last container?
Answer: There is no specific time limit to load a booking, HOWEVER, if the containers are all sampled as one lot, they must be loaded in a reasonably continuous operation. We define this to mean that breaks in loading cannot exceed 88 hours. This means an applicant could load a container, take a break for up to 88 hours, load another container, take a break, etc. As long as there are no breaks in loading that exceed 88 hours. Also, the applicant must apply for a phyto certificate to APHIS within 30 days of the day that they were sampled. This restriction also applies if containers are loaded at different locations within an OSP territory. The applicant could load a container at Location A on Monday, load another container at Location B on Wednesday, and another container back at Location A on Saturday. This example would be acceptable for continuous loading under the 88-hour rule. Question #14 (change in condition after sampling)
- What should we do if a sample has undergone a change in condition between the time the container was sampled and the date that the samples were composited?
Answer: If the samples to be composited have undergone a change in condition then they should not be composited with other samples that are in sound condition.
- Holding samples for grading
We have sampled containers and performed condition inspections but the shipper has not declared a booking number or offered instructions whether they want the containers graded on an individual basis, or composite basis, or a composite average basis. How long should we hold these samples?
Answer: If no instructions are forwarded by the shipper within a week of sampling the container contact the shipper and request grading instructions. If the shipper fails to provide grading instructions then grade the sample and issue a domestic inspection certificate and a weight certificate for the container. Remember that for containers to be certified as a single lot, they must be loaded in a reasonably continuous operation, which means no breaks to exceed 88 hours.
- Sampling & grading a booking
We are sampling and grading a booking of that consists of 19 containers. The licensed samplers are checking the samples for odor, insects, and condition as the containers are loaded. If the sampler detects an odor he/she will “flag” the sample ticket to alert the agency inspector to check the sample for odor at the grading lab. Only the samples that have been “flagged by the sampler are checked by the inspector before they are composited for grading purposes. All other samples that the sampler determined to be “OK” in regards to odor are not individually checked for odor before being composited.
Is this the proper procedure for determining odor on samples that are composited for a booking?
Answer: No. The licensed sampler on site is responsible for making an onsite check for condition, odor, and insect infestation on all containers. “Flagging” samples that are suspected of having an “off” odor is a good practice and is part of the inspection process. However, the check for odor is only considered as a cursory check and will serve to alert the shipper of the preliminary result for odor and provide the inspector at the grading lab with a ‘heads-up” to potential problems or suspect odors in the sample. Ultimately, it is the responsibility of the inspector to check each individual sample for odor prior to combining samples to form a composite type sample for grade analysis. Only samples that are “OK” in respect to odor may be combined to form a composite sample.
- Sampling with an on-line device
While sampling with an on-line type sampling device (pelican, D/T sampler) the sampler detects a cut or portion of the grain in the collection bucket has a sour, musty, or COFO odor. Does sampler or inspector make the final determination for odor on the grain in the container if this occurs?
Answer: The inspector is ultimately responsible for making the determination on odor. The sampler will be responsible for maintain a separate portion of the grain that is suspected of having an “off” odor from the remainder of the sample that is “OK” in respect to odor.
- Sampling multiple containers
Based on composite sampling where an unspecified number of containers would be combined as a single sample for inspection, should infestation, odor and heating checks be made during online sampling when using an ellis cup or pelican, or performed in the lab (except heating) under more stable conditions?, or would this apply only to d/t sampling?
Answer: Ideally, the checks for infestation, odor, and condition should be done at the loading site. This will provide the shipper with a heads-up that there is a potential problem. However, if your sampling crew is not adept at making some of these determinations then I would suggest that they bring the entire sample back to the lab for an inspector to make the determination(s). Ultimately, it is the responsibility of the inspector grading the composite to make sure that proper determinations on odor, insects, and condition are being made.
- What percentage of a sample should be kept when up to 20 containers might be included as 1 inspection? Would the percentage of grain added to the composite sample truly represent the condition of the container it was taken from when loading takes place over 1 week or more?
Answer: Even though the samples are checked during the loading process for odor, infestation, and condition, they should be checked again when they are composited, especially when the compositing takes place days after the grain was initially sampled. If the applicant requested composite sample analysis of 20 containers, and the total quantity required for testing and file amounted to 7,500 grams (including aflatoxin analysis) you would be required to save a proportionate amount from each sample (375 grams per container if they are all approximately the same size) to attain the target amount of 7,500 grams. If all of the containers were approximately the same size, and the samples were approximately the same size, I would blend all of the samples together through the cargo divider to get my 7,500-gram portion.
- A 30 car train is loading as cu-sum and then sent to a container yard and the grain is then transferred to containers. Can the grade from the cu-sum be applied to the containers or does the commodity need to be inspected again? This all takes place within a couple of days.
Answer: We will allow the shipper to use the cu-sum grade of grain provided that all of the railcars are loaded into the same booking, and no other grain (sourced from bins, trucks, etc.) is added to the container lot. Additionally, all grain from rail cars must be loaded into the containers-no leftover grain in railcars. In addition to monitoring the loading process, you would have to establish an IP protocol and verify that the grain was transloaded into xyz containers. The transloading point would be ideal for performing the insect check-the clock (30-day period for phytos) would start running for the phyto certificate on the basis of the inspection at the time of loading the container as opposed to the date that the railcar was loaded.
- We are sampling 3 bookings under the same contract number for one customer at different locations. The applicant has made a request to have the samples from the 3 separate bookings combined to form a composite sample. The composite sample would represent the 3 bookings and the inspection certificate would represent the 3 bookings.
Can we combine different bookings to form a composite sample?
Answer: No. Since the applicant presented the containers as 3 separate bookings they must be inspected as separate units. If the applicant wants to combine the results of the 3 bookings to receive a single certificate representing the 3 bookings they must request combined lot certification. Official personnel must follow the requirements for combined lot certification as stated in section 800.85 of the USGSA regulations. Also, the maximum number of containers in a lot is capped at 20 containers.
- If we are grading containers under Average Composite, and a sample turns out to be a different class or kind of grain than what was requested, is it acceptable to combine in the composite?
Answer: No. To maintain the integrity of the official system, flag any samples that do not appear to meet the criteria for kind of grain, class, or subclass, and inspect the sample before combining in a composite. Only flag samples where there may be an obvious discrepancy over the load order requirement. Do not composite samples that do not meet the criteria for kind of grain, class, or subclass.