- What goes in Box 23, “Concentration Level,” of the 921-2?
Answer: Number of grams per cubic (cu) feet (ft).For example, 45g/cu.ft., or 36g/cu.ft. Do not record numbers like “canisters” or “pellets;” the concentration of grams/cubic feet is the critical number.
- Is 45g/cu. ft required if the fumigator can attain the 750 parts per million by volume (ppmv) at a lower dosage?
Answer: No. Per instructions outlined in the Policy Bulletin Board Notice, for DDGS shipped in containers, only the ppmv is important.Record the application concentration in grams per cubic feet.Even though the application concentration is not required for a phyto, APHIS seeks this information as part of the work records.
- Do we need to state 750ppmv anywhere on the 921-2?
Answer: No. The statement that “The inspected lot conforms to the requirements for DDGS for export to Vietnam” is sufficient. APHIS will make the necessary declarations on the actual phytosanitary certificate. The basic premise of this protocol and this statement is that, even though there are many components, if the conforming statement is on the 921-2, then APHIS and FGIS agree that ALL parts of the protocol were followed. No additional, duplicative statements are necessary on the 921-2.
- Does the Official Service Provider have to witness the fumigation?
- Are any additional remarks required?
Answer: Yes. APHIS has requested that Box 17, “Remarks,” state the city and state of the fumigation. For example, “Fumigated in Kewanee, IL” (the FGIS policy and 921-2 instrucitons will be updated to reflect this change).
- Is the Official Agency (OA) required to seal the containers after sampling but before fumigation (for example, if the container is transported to another location for fumigation)?
Answer: No. Sealing the containers is not a requirement, unless that service is requested by the applicant.
- Can the fumigation pellets be applied before or during loading?
Answer: No, the fumigation must be applied after loading because the pellets must be exposed to air to activate. However APHIS is confirming with fumigation manufacturers and applicators to confirm.
- What is center mass monitoring, and why is it important?
Answer: Center mass monitoring is a critical component of the protocol. This means that monitors must be buried into the product (not just laying on top between the walls).The monitor cannot be placed on the bottom of the container before loading (though APHIS is confirming with manufacturers and applicators to confirm).
Proposed definition: Center mass monitoring – a monitor buried into the center of the product, at least 3 feet from the top of the DDGS and at least 3 feet from the top, sides, or bottom of the container. (Please comment on this proposed definition for APHIS review.)
- What date should be recorded as the “date of fumigation” in Box 19 on the 921-2?
Answer: Official Personnel should record the date they witnessed the fumigation. APHIS notes that for Vietnam, there is a 30-day requirement to get a phyto after the product is inspected.
- When does the clock start on the 3, 4, or 5-day (72, 96, or 120-hour) exposure period?
Answer: The clock starts when the container achieves the 750ppmv at center mass.That is Day 0 (or Hour 0). The exposure time starts at the first reading of 750ppmv.
- If an Official Agency knows for a fact that a component of the protocol is not being followed, even if the discrepancy is not an area which is normally confirmed or verified by FGIS, what should they do?
Answer: The adherence to the protocol is critical. FGIS is acting as APHIS’ eyes and ears in the field. If there are any confirmed discrepancies with the protocol and what the OA knows to be factual, note on the 921-2 that the lot does NOT conform and contact FGIS immediately.
- What should we do if a lot does NOT conform?
Answer: Write the statement that “The inspected lot does not conform to the requirements for DDGS for export to Vietnam.” ALSO, note WHY the lot does not conform (e.g., “failed stowage exam,” “no pest management plan,” or “no netting available”).
- How many readings (on one container) can be below 750 ppmv?
Answer: Just one – there can be one reading between 500-749 ppmv.But if the reading dips below 500 ppmv, the fumigator must apply more fumigant and the clock restarts when it achieves 750 ppmv.
- How should the netting be affixed to the container?
Answer: There are no requirements for how the netting must be attached or affixed. But the netting should be secured in some manner to prevent gaps or holes where insects could enter.
- What is the required distance to witness the fumigation?
Answer: Safety is the top priority. Follow the direction of the licensed fumigator in accordance with label instructions. The only FGIS requirement is that the Official Personnel directly witness the application of the fumigant and can be reasonably certain that the fumigant was applied as stated by the fumigator.
- How were/are these procedures communicated to industry?
Answer: APHIS worked closely with the U.S. Grains Council (USGC); fumigant applicators and manufacturers; the USDA Foreign Agricultural Service; and Vietnamese officials to develop this protocol. If there are any industry questions about specifics of the protocol outside of these FGIS instructions, we encourage them to contact USGC or APHIS.
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