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10. What action is to be taken if a shiplot of grain or a portion of the grain is found to grade weevily?
11. What kinds of inspections do not meet the requirements for export inspection under section 5 of the Act?
12. Who is responsible for the general direction and supervision of the grain inspection program under the Act?
13. What is the special multiple grade procedure, and how does it work?
14. How may an applicant obtain a reinspection if his request is filed later than the close of business on the second business day following the date of the inspection in question?
15. When shall a file sample be furnished to a Field Office?
16. How may errors be corrected which are found prior to the issuance of the certificate?
17. What shall the termination of license notice to the licensee include?
13. When is a person considered to be engaged in the merchandising of grain?
19. From what should official samples be protected ?
20. What should an inspector do if he has reason to believe that a sample(s) has been left unattended or if he believes that the sample(s) may not be representative of the grain in an identified lot?
Question 10. Describe the training procedures that are employed by official inspection agencies for licensed grain inspectors.
Answer. Training procedures for licensed grain inspectors vary between official inspection agencies. Official inspection agencies are charged with the primary responsibility for the training of licensed inspectors in section 26.100 (d) and (e) of the regulations under the C.S. Grain Standards Act. Vo formal training program has been prescribed by the Department for use by official inspection agencies in training of licensed inspectors. $ 26.100 Duties of official inspection agencios.
(d) Training and supplies. Each official inspection agency shall provide its licensed personnel with training, as needed, and adequate supplies of forms approved by the Administrator, the instructions (including grain inspection manuals and inspection procedures for “other criteria”) official grain standards, and other materials necessary for the conduct of official inspection functions.
(e) Obtaining licenses. Each official inspection agency shall assist its personnel in obtaining needed licenses for official inspection activities, and needed authorizations for affixing signatures.
Question 11. You stated in your testimony on June 19 that written examinations have been required for licensing since September 30, 1974. What kind of examination was required previous to that date?
Answer. The written examination required since September 30, 1974, was an examination for a license to perform official stowage examination of ships to receive grain. Prior to September 30, 1974, no examination for licensing to perform stowage examination was required.
Question 12. How many of the currently licensed inspectors have ever been subject to a written examination ?
Answer. All of the currently licensed inspectors have taken a written examination.
Question 13. Describe in detail your training program for Federal grain inspection personnel. Explain why it takes from 1 to 3 years to train a Federal grain inspector.
Answer. Our training program for Federal inspection personnel is described under No. 2* The expert grading of grain requires years of experience because of the various possible defects, discolorations, adulterations, moisture situations, and various other problems which can arise. Most grading decisions must be made on factors which are judgmental in nature—these skills can only be developed by time and experience. Many of these problems in grading factors emerge only once or twice in several years. It also takes much time to become proficient enough to grade at the speed necessary to accommodate the fast movement of grain in marketing channels. In addition, a multitude of other skills which are judgmental in nature must be learned, such as examining carriers for acceptability for loading of grain and the proper sampling of grain in the many types of carriers and of grain in motion. Identification of insects injurious to grain is another complex subject which inspectors must learn.
Question 14. What records do you require that official inspection agencies keep pursuant to section 12 of the U.S. Grain Standards Act?
Answer. Official inspection agencies are required to keep the following records:
(i) whether it is a government, trade, or private organization, or is sponsored by a government, trade, or private organization;
(ii) the name of each member of the sampling, inspection, and clerical staff and his capacity on the staff;
(iii) the scope of the license, if any, held by each employee under the act; and
(iv) the authorization to affix signatures, if any, held by each employee.
* See p. 183, and appendix B, p. 211.
Action is underway to require the retention of file samples of inspected grain.
Questions 15 and 16. What procedures do you have for auditing the records of official inspection agencies? When were these procedures initiated ?
Answer. There is no formal systematic procedure for auditing the records of OIA required to be kept under the United States GSA and regulations. The work records of the agencies are reviewed by Federal personnel on a daily basis. The reorganization of the Grain Division in November 1974 and the addition of national coordinators as part of the stafling has resulted in a procedure of further reviewing the records kept by OIA.
We are in the process of developing a procedure whereby we will audit the financial records of the agencies on an annual basis.
Question 17. What are the tolerances of inspection grades on shiplots and sublots (what percentage of grain is allowed to be of a lower grale)!
Answer. Il istorically the Grain Division has used export loading plans that allowed for variations in quality during loading. These allowances for export lots of grain are identified in the enclosed instructions for shiplot inspections. Basically, the plans allow for variations in results of sublot samples in loading of shiplots. The allowances are made in order to allow for sample variations that occur during continuous loading operations. Sublot results may go into the next lower grade within prescribed limits as set forth in the instruction.* No allowances are made for the shiplot average that is used for certification.
Question 18. Provide the number of shiploads of grain leaving C.S. ports in the last 10 years and the number of complaints registered by foreign buyers over the same period.
Answer. Information on the actual number of shiploads is not available. The attached table reflects total grain exports (in thousand bushels) during calendar years 1964 through 1974. (See attachment.)
Information on the number of complaints registered by foreign buyers is available only for the past few years. During the period December 1971 to July 1975, the Department has received 87 complaints involving 146 shiploads of grain. Details of these complaints will be made available to the committee, if desired.
Total (thousand bushels)
1974 1973 1972 1971 1970 1969 1968 1967 1966 1965 1964
2, 880, 129 3, 511, 882 2, 318, 813 1, 705, 66.7 1, 826, 241 1, 403, 833 1, 634, 090 1, 692, 151 2, 071, 586 1, 744, 057 1, 622, 235
*See GR Instruction 918-27, p. 194 anıl appendix C, p. 264.
Question 19. What procedure does the grain inspection branch have for safeguarding the integrity of the samples of grain?
Answer. The procedures are as follows:
1. Determine that licensees follow all procedures described in the attached copy of GR instruction 918–27, “Supervising Shiplot Grain Inspections."
2. Determine that licenses follow the same procedures as followed by Federal personnel when performing appeal inspections.
3. Perform unannounced visits to sampling locations. This gives the supervisor an opportunity to observe the sampler's work and correct, on the spot, any deficiencies noted. It also makes the sampler cognizant of the likelihood of imannounced visits at any time.
4. Obtain independent samples after the licensed sampler—by a direct comparison of the sample we obtain with that the licensed sampler obtained from the same lot, we can evaluate the integrity of his work.
5. Give oral and written tests to the licensed sampler to determine that they are aware of safeguarding provisions. Appeal inspection: A. Ships—Federal personnel :
1. Checktest all mechanical sampling equipment and analytical equipment at frequent intervals to insure accuracy.
2. Man the sampling equipment at all times and supervise licensed samplers.
3. Periodically check sample delivery systems and sample bags (if used) for condition.
4. Check grain frequently for condition (odor, infestation, grade) as it moves on shipping belts or as it collects in a sampling hopper.
5. Make sure samples are properly identified.
6. Maintain custody of samples at all times or lock them in a secure place when custody is not maintained. B. Cars, Trucks, barges. Federal personnel :
1. Insure that proper sampling techniques are employed.
3. Keep samples safe from weather and manipulation to preserve their condition as sampled.
GR Instruction 918-27
April 19, 1974
U.S. DEPARTMENT OF AGRICULTURE— AGRICULTURAL MARKETING
SERVICE, GRAIX DIVISIOX, HYATTSVILLE, MD.
Action by: Field Office Supervisors, Regional Directors, and the Board
of Appeals and Review, Grain. Information for: Official Inspection Personnel and Interested Parties
in the Grain Industry.
SUPERVISING SHIPLOT GRAIN INSPECTIONS
A. Establishes procedures for supervising the inspection of grain loaded into or unloaded from ships; and B. Separates and defines the procedures as follows:
Two-man supervision (when two individuals are used—one to supervise the sampling and the other to supervise the grading).
One-man supervision (when one individual is used to supervise the sampling and/or grading).
Heavy workloads in our field offices and personnel reductions have caused us to change our methods of supervision. One-man supervision has been recommended to routinely supervise the sampling and grading of grain loaded into or unloaded from ships. One-man supervision is generally used to obtain supervision samples at the time the grain is sampled by the licensed sampler. At most locations the samples are taken to the field office for supervision grading. The exception occurs at locations where the samples are piped from a diverter-type mechanical sampler into the inspection laboratory. This allows the supervision of sampling and grading during loading and usually eliminates the grading of samples in the field oilice. The use of one individual to supervise the inspection of shiplot grain increases the onsite supervision coverage and is an approved method of supervising shiplots and other types of grain inspections. Official samples may be obtained for supervision and for review when problems arise on shiplot inspections. One problem of one-man supervision samples worked in the field office is delay in analysis. Therefore, samples should be analyzed as promptly as practicable after loading. Until about 2 years ago—and in special situations since then-two-man supervision was generally used to supervise the sampling and grading of grain loaded into or unloaded from ships. Two-man supervision eliminates the analysis of samples in the field office but reduces the supervision coverage that can be performed at one time. When full supervision is necessary for all or a portion of a shiplot inspection, two-man supervision is generally used.
III. PROCEDURE FOR ONE-LAN SUPERVISION
A. When to use one-man supervision.—One sampling supervisor shall be used to supervise the sampling of shiplot grain inspections except where conditions are such that one-man supervision is impracticable; for example, difficult grade determinations are to be made or full supervision is warranted for all or a portion of a shiplot inspection. At elevators where sampling is performed at several widely separated sites, it may be necessary to use more than one supervisor to obtain samples of the complete lot. This is also to be considered one-man supervision.