An Equal Opportunity Provider and Employer

Agricultural

Marketing

Service 

Federal Grain Inspection 

Service

Field Management 

Division 

1400 Independence Ave. 

SW, Stop 3630

Washington, D.C. 20250

Voice (202) 720-0228

Fax (202) 690-3951

Hotline 1-800-998-3447

Reference #228 January 29, 2010

TO: FGIS POLICY BULLETIN BOARD

FROM: Robert Lijewski, Acting Director

 Field Management Division 

SUBJECT: Limiting Analysis of Lots Containing Deleterious Substances,

and Testing Plant Environmental Material Collected During Plant 

Sanitation Inspection.

ORIGINATING OFFICE: Policies, Procedures, and Market Analysis Branch

1. PURPOSE

This memorandum is issued to provide information on the limitation of 

the review inspection of processed commodity samples.

This memorandum also expands the laboratory testing requirement of 

environmental material collected as part of plant sanitations of facilities 

that produce or intend to produce certain processed commodities for 

USDA’s food assistant programs. 

2. BACKGROUND

The Farm Service Agency (FSA), an agency of the United States 

Department of Agriculture administers specific commodity programs 

designed for voluntary production adjustment; resource protection; 

and price, market, and farm income stabilization. Included in these 

programs is the responsibility to purchase food items for use in 

domestic and overseas (export) feeding programs.

Some food items purchased by FSA must meet specific bacteriological 

requirements, such as bacteria count, E. coli, Salmonella, and 

Staphylococcus aureas. The food items requiring bacteriological 

testing includes the following products:

Corn Soy Blend, Export Soy Fortified Bulgur, Export

Corn Soya Milk, Export Soy Fortified Rolled Oats, Export

Instant Corn Masa Flour, Domestic Soy Fortified Sorghum Grits, Export

Instant Corn Soya Masa Flour, Export Wheat Soy Blend, Export

Instant Corn Soya Milk, Export Wheat Soy Milk, Export

Soy Flour Full Fat, Export
Page 2

When as a result of testing by the Commodity Testing Laboratory 

(CTL) a sample of the above products exceeds the bacteriological 

limits specified in FSA documents, the applicant may request an 

appeal inspection, provided the original inspection result was negative 

for salmonella. If the sample was salmonella positive, the review 

inspection is limited to a retest of the file sample. No appeal inspection 

may be obtained.

Additionally, applicants must produce products in a salmonella free 

facility. This is determined by FGIS performing a plant sanitation 

inspection of plants that are processing or intend to process products 

requiring USDA inspection for quality. As part of the plant sanitation 

inspection, FGIS collects environmental samples drawn from 

locations in the facilities that may harbor organisms or where contact 

with the product is or could be made by human or other sources of 

contamination. Currently, CTL is required to test the environmental 

samples for the presence of only salmonella, although the facility may 

harbor other harmful organisms that could possibly contaminate the 

product being produced by the plant.

FGIS has established the following policy to ensure that USDA 

purchases quality products produced in environmentally safe facilities.

3. POLICY

CTL will not perform an appeal analysis on lots containing a 

deleterious substance. FGIS considers Salmonella, E. Coli, Coagulase 

Positive Staphylococci, Staphylococcus aureas, and bacteria count in 

excess of 50,000 as deleterious substances.

Additionally, CTL will analyze all environmental samples collected 

during plant sanitation inspection for the same deleterious substances 

required to be tested in the product.

4. EFFECTIVE DATE

The above policy is effective on January 29, 2010.

5. FILING INSTRUCTIONS 

File this policy memorandum in the Processed Commodities 

Handbook and the Sanitation Handbook.

6. QUESTIONS 

Direct any questions concerning this policy to

AMS - FGIS Policies Procedures Market Analysis Branch