United States Department of Agriculture

Agricultural Marketing Service

Federal Grain Inspection Service

Directive 9180.50 May 1, 1997

Distribution: FGIS, OSP, Industry Originating Office: FMD PPMAB

The U.S. Department of Agriculture (USDA) prohibits discrimination in its programs on the basis of race, color, 

national origin, sex, religion, age, disability, political beliefs, and marital or familial status. (Not all prohibited 

bases apply to all programs.) Persons with disabilities who require alternate means for communication of program 

information (Braille, large print, audiotape, etc.) should contact USDA’s TARGET Center at (202) 720-2600 (voice and 

TDD).

To file a complaint, write to the USDA, Office of Civil Rights, Room 326-W, 1400 Independence Avenue, SW, 

Washington, DC 20250-9410, or call (202) 720-5964 (voice and TDD). USDA is an equal employment opportunity 

employer.

CHECKCOUNTING, OBSERVATION OF LOADING, AND CHECKLOADING SERVICES

Contents

CHECKCOUNTING, OBSERVATION OF LOADING, AND CHECKLOADING SERVICES 1

1. PURPOSE ............................................................................................................................2

2. REPLACEMENT HIGHLIGHTS ............................................................................................2

3. POLICY ................................................................................................................................2

4. DEFINITIONS .......................................................................................................................2

5. SAFETY................................................................................................................................2

6. APPLICATION AND WORK RECORDS ..............................................................................3

7. PROCEDURES ....................................................................................................................3
FGIS Directive 9180.50 April 1, 1997

Page 2

1. PURPOSE

This directive establishes the policies and procedures for performing and certificating

checkcounting, observation of loading, and checkloading services under the Agricultural

Marketing Act of 1946 (AMA).

2. REPLACEMENT HIGHLIGHTS

The directive supersedes FGIS Program Directive 918.50, dated 3-22-91. This directive

is updated to reflect organizational changes, new numbering system, and new format 

but does not revise policy.

3. POLICY

Section 868.31 of the regulations under the AMA provides for the performance of

checkcounting, observation of loading, and checkloading, upon request.

4. DEFINITIONS

a. Checkcounting. This service consists of official personnel determining the total

number of filled outer containers in a lot.

b. Observation of Loading. This service consists of official personnel observing that

an identified lot has been moved from a warehouse or carrier and loaded into 

another warehouse or carrier.

c. Checkloading. This service consists of official personnel performing a stowage 

examination, determining the number of filled commodity containers loaded aboard 

the carrier, determining the condition of the containers loaded aboard the carrier, 

and sealing the carrier if sealable.

5. SAFETY

The requirements in this section are mandatory for FGIS employees. All others are

strongly encouraged to also follow the guideline.

a. General. Official personnel shall comply with all pertinent Occupational Safety and

Health Administration requirements (e.g., 29 CFR 1917-1918) and Section 7, 

“Safety,” of FGIS Program Directive 9180.48, “Stowage Examination Services.”

b. Warehouse. When performing checkcounting and checkloading, do not climb up

on pallets. At all times, remain aware and careful of moving vehicles (forklifts etc.).
FGIS Directive 9180.50 April 1, 1997

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6. APPLICATION AND WORK RECORDS

a. Application for Service. Application for these services may be made verbally or in

writing. When requested by a field office manager, use FGIS-955, “Application 

for Inspection Under the Agricultural Marketing Act of 1946,” for written requests 

involving AMA commodities. Applicants must inform official personnel of any 

hazardous conditions that may exist.

b. Work Records. Official personnel shall maintain a work record that contains all

information needed to prepare official certificates or official reports for each service 

performed. FGIS-991, “General Services Worksheet,” or FGIS-992, “Services 

Performed Report,” should be used whenever practicable, but any locally-generated

form may be used as a work record provided it contains the required information.

7. PROCEDURES

a. Checkcounting.

(1) Determine the number of containers in the lot by counting each container

or pallet in the lot. If pallets are counted, multiply the number of complete 

pallets by the number of containers on each complete pallet. Determine the 

number of incomplete pallets in the lot and the total number of containers 

on each pallet. Add the total number of containers found on the incomplete 

pallets to that of the complete pallets.

(2) Discrepancies between warehouse and inspection personnel should be 

resolved by recounting together such portions of the lot where discrepancies 

exist. This requires cooperation on the part of inspection and warehouse 

personnel. If counts cannot be resolved, use the inspector’s count for 

certification.

(3) Certification. Record the number and type of containers in the “Remarks”

section of the inspection certificate as follows:

“(number) (container) were loaded aboard the carrier.”

Note: Modification of this statement is acceptable as long as the field 

office manager approves the statement.
FGIS Directive 9180.50 April 1, 1997

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b. Observation of Loading. Verify that an identified lot at rest in a warehouse is 

removed from the warehouse and loaded into a carrier.

Certification. Show one of the following statements in the “Remarks” section of

the certificate.

“Observed (commodity, Lot # ) being loaded aboard the carrier on (date(s)).”

“Observed (commodity, Lot # ) being moved from (barge) to (hold number(s)) on 

(date(s)).”

“Observed (commodity, Lot # ) being loaded aboard the carrier in (hold number(s)) 

on (date(s)).”

Note: A stowage examination must be performed in order for the carrier’s 

name and stowage space to be shown on the certificate. Modification of 

these statements is acceptable as long as the field office manager approves 

the statements.

c. Checkloading.

(1) Examine the stowage space of the carrier in accordance with FGIS Program 

Directive 9180.48, “Stowage Examination Services.”

Dismiss the checkloading service if the carrier’s condition could contaminate 

or damage the commodity to be loaded. If the applicant elects to load the 

unfit carrier, report the situation on the Form FGIS-992, “Services Performed 

Report,” and the applicable statement on the inspection certificate (see 

paragraph (5) (d) for statement).

(2) Count the containers in the carrier in accordance with the established 

checkcounting procedures (paragraph a of this section).

(3) Observe the condition of the commodity and containers for any changes in

condition or any damage from handling. During loading, note any containers 

that are wet, torn, leaking, damaged, or improperly sealed on FGIS-992.

(4) Seal the carrier doors promptly after loading is completed, if sealable, and not 

seal numbers on work record. If the carrier is partially loaded and completion 

of loading is postponed until a later time or date, seal the doors, if sealable, 

until loading is resumed.
FGIS Directive 9180.50 April 1, 1997

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(5) Certification. Issue FGIS-993, “Commodity Inspection Certificate,” or 

FGIS-932, “Rice Inspection Certificate,” according to certification procedures 

in the Processed Commodities Handbook; Dry Bean Inspection Handbook; 

Dry Peas, Split Peas, and Lentils Handbook; or the Rice Inspection Handbook.

When checkcounting and checkloading are performed in conjunction with 

a quality inspection service, certification of results may be reported on one 

certificate or, upon request by the applicant, on separate certificates. 

Show the quantity checkloaded in the “Quantity” block of the certificate. Show 

the applicable statement in the “Remarks” section of the certificate.

(a) Checkloaded into one carrier.

“Checkloaded, (date); carrier, (carrier identification); seal(s), (seal

identification if sealed).”

or

“(number and kind of containers) checkloaded; (date); (carrier

identification); (seal identification if sealed).”

(b) Checkloaded into more than one carrier. The above statement should be 

repeated identifying each carrier loaded.

(c) More than one lot checkloaded into the same carrier.

Lot No. No of Containers *

 --- ---

 --- ---

Total: ----

* The weight of each lot may also be shown.

(d) Lot loaded into unfit carrier.

“Commodity in (carrier identification) was not checkloaded because the

carrier was unfit due to (reason(s)).”

(e) Damaged containers. When damaged containers are loaded aboard

the carrier, the applicant may select one of the following additional 

certification statements:

 “Carrier contains (number) (type of damage, e.g., wet, torn, etc.) containers.”
FGIS Directive 9180.50 April 1, 1997

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If this statement is used, report the total number of good and damaged 

containers loaded aboard the carrier in the “Quantity” block and indicate 

the number of damaged containers in the statement. 

“Carrier contains an additional (number) (type of damage, e.g., wet, torn, 

etc.) containers.”

If this statement is used, report only the total good containers loaded 

aboard the carrier in the “Quantity” block and indicate number of 

damaged containers in the statement.