United States Department of Agriculture

Agricultural Marketing Service

Federal Grain Inspection Service

Directive 9180.78 September 30, 2013

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

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PROCEDURES FOR BULK GRAIN EXPORTED IN CONTAINERS

Contents

DIRECTIVE TITLE �����������������������������������������������������������������������������������������������������������������1

1. PURPOSE����������������������������������������������������������������������������������������������������������������������������

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

3. BACKGROUND��������������������������������������������������������������������������������������������������������������������

4. POLICY ��������������������������������������������������������������������������������������������������������������������������������

5. INSPECTION AND WEIGHING PROCEDURES �����������������������������������������������������������������

6. CERTIFICATION AND ADDITIONAL DOCUMENTATION ���������������������������������������������������

7. SUPPLEMENTAL INFORMATION ���������������������������������������������������������������������������������������

8.QUESTIONS �������������������������������������������������������������������������������������������������������������������������
FGIS Directive 9180.78 September 30, 2013

Page 2

1. PURPOSE

This directive is issued by the Federal Grain Inspection Service (FGIS) to provide 

procedures for the sampling, inspection, weighing, and certification of bulk grain 

exported in containers

2. REPLACEMENT HIGHLIGHTS

This directive is revised to establish the maximum number of containers that may 

be combined or averaged to form a single lot, define inspection options, restrict the 

inspection and weighing of lots to the official service provider’s area of responsibility, 

specify the 60-day retention period for file samples, and clarify certification procedures 

for container lots

This directive supersedes FGIS Directive 9180.78, “Procedures for Bulk Grain Exported 

in Containers”, dated 12-06-04

3. BACKGROUND

The U.S. grain industry has experienced a significant increase in the demand for grain 

exported in containers. Increased exports of containerized grain have, in turn, increased

the demand for USDA grain inspection services provided by FGIS and its official grain 

export service providers

Typically, the industry uses large reusable containers that may be 20 feet or 40 feet in 

length, 8’0” or 8’6” in width, and 8’6” or 9’6” in height to transport bulk or sacked grain. 

Large reusable containers are usually a metal truck/trailer body that can be detached 

from the chassis for loading into a vessel, a railcar, or stacked in a container depot. 

Sales contracts usually cover multiple container parcels known as “bookings” (i.e., 

grain in multiple large reusable containers that may be from different sources but are 

sold under a single sales contract and a single certificate) that are shipped to multiple 

end users, but collectively are considered a single lot. Unless exempted from official 

inspection and weighing requirements under the United States Grain Standards Act 

(USGSA), a sales contract must stipulate that the overall quality in a booking meets 

an official USDA grade standard. Accordingly, export grain sellers often request that 

Agricultural Marketing Service (AMS) combine inspection results from the individual 

containers and issue one official inspection certificate for the booking.

FGIS has developed the following policies and procedures to facilitate the marketing of 

bulk U.S. grain exported by containers from the United States.
FGIS Directive 9180.78 September 30, 2013

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4. POLICY

Bulk grain lots exported by containers are sampled, inspected, and certified as 

individual lots except when the contract contains specifications for certification based 

on multiple composite or average grade/average composite samples (see Section 5(2) 

and 5(3). In those instances, official personnel will sample and inspect containers as a 

combined-lot based on the contract inspection requirements

This directive applies to bulk grain exported by container to all destinations except 

Mexico and Canada. Refer to FGIS Directive 9180.59, Composite Sample Analysis fo

Combined Land Carrier Inspections, which was developed to comply with the United 

States - Mexico grain sampling protocol (NOM-028-FITO-1995)

Sacked grain procedures are contained in FGIS Directive 9180.41, Sacked Grain

5. INSPECTION AND WEIGHING PROCEDURES

Unless otherwise specified in the load order document, official inspection personnel 

will grade and certify containers as individual lots. Applicants may request composite

sample analysis or average grade/average composite analysis of export containers 

provided that the load order represents these provisions included in the export sales 

contract. Composite samples will be limited to a maximum of 20 containers. Inspection/

Weighing of containers included in a composite must also be loaded in a reasonably 

continuous operation, with breaks in loading not to exceed 88 hours. Samples may 

only be composited with samples loaded within an official service provider’s area of 

responsibility. If multiple locations are used to form a composite, the break in loading 

should not exceed 88 hours among all locations

a. Sampling. Containers are sampled either directly from the container after it i

loaded using a grain probe, as the grain is loaded into the container using an 

online sampling device (Ellis cup, pelican sampler, or diverter sampler), or prior to 

loading the container by sampling the grain while it is in another storage container 

(bin, railcar, or truck). If the sample is obtained prior to loading the container, the 

inspection certificate will contain a statement to indicate this.

Note: Probe samples must hit the bottom. ‘Bottom not sampled’ is not 

acceptable for export shipments.

When sampling for a composite sample analysis, check the sample representing 

each container for condition (odor, heating, sample grade criteria, and insects) 

then combine the samples which are “OK” for the condition factors. Samples

obtained from multiple carriers are combined proportionally to the size of the 

carrier to form the composite sample. To be combined as one composite sample,

the containers must be loaded in a reasonably continuous operation. Any breaks in 

loading a composite sample that exceed 88 hours are not considered reasonably 

continuous. If the 88-hour restriction is exceeded, composite all samples up to the

point where continuous loading ended. If unusual circumstances necessitate a

break of longer than 88 hours, contact the Field Office Manager.
FGIS Directive 9180.78 September 30, 2013

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Individual containers that are “infested” but otherwise “OK” for condition may be 

combined, at the option of the shipper, with other samples to form the composite 

sample. However, the shipper must fumigate the “infested” containers to remove

the infested designation from the inspection certificate.

FGIS fumigation procedures for land carriers are found in Chapter 3 of the 

Fumigation Handbook. Inspection certificates will indicate when a container is 

fumigated

b. Inspection. The quality of grain loaded in containers is based on samples obtaine

during the official sampling process. The quality may also be determined based on 

an earlier official inspection result of the carrier from which the grain is transferred 

to the container. That is, official personnel may transfer the grade information 

of a domestic certificate (e.g. truck lot to containers) to an export certificate if 

the condition has not changed and identity has not been lost since the domestic 

inspection. Further, the domestic lot must not have a “bottom not sampled”

condition in order to use the information for export purposes

The applicant can choose to have each container graded as an individual lot, use 

composite sample analysis, or use average grade/average composite analysis. 

Combined-lot procedures can be used to further combine multiple carriers on 

a single certificate. If the applicant requests multiple containers on a single 

certificate, the applicant has several options for certification.

(1) Individual Lot

When inspecting each container on an individual basis, each container will 

represent one lot and a certificate will be issued for each container.

(a) Review Inspection

Applicants may request review inspections (reinspection, appeal 

inspection, or board appeal inspection) for each lot/container.

(b) Combined-Lot

When the inspection of all containers has been completed, the applicant 

has the option of requesting combined-lot procedures for certifying 

multiple carriers of similar grade on a single certificate (see Code of 

Federal Regulations (CFR) 800.85). For example, if the first, third, and 

fifth container all grade U.S. No. 2 Yellow Soybeans, these containers 

can be combined on one certificate.

Note: Two single lots of different grades may be combined if load 

order indicates the lower of the grades or better. For example if 

the combined lot load order indicates a grade of ‘U.S. No. 3 or 

better Yellow Corn’, lots graded as U.S. No. 3 Yellow Corn can be 

combined with lots graded as U.S. No. 2 Yellow Corn with a final 

grade of U.S. No. 3 or better Yellow Corn.
FGIS Directive 9180.78 September 30, 2013

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(2) Composite

The applicant can request official personnel to combine or composite samples 

from a maximum of 20 containers into one sample for analysis for certification 

called Composite Sample Analysis

To form a composite sample from multiple containers, official personnel 

must sample each individual container from locations within the Official 

Service Provider’s area of responsibility in a reasonably continuous 

operation and examine the container for odor, insects, and condition. All of

the containers that are combined must be uniform with respect to condition 

(i.e., infestation, odor, sample grade factors, special grades) and must mee

class requirements. Containers that contain grain that has an odor or is out of

condition may not be joined with samples of good quality to form a composite 

sample. Samples representing individual carriers that contain insects, but

are not “infested” by definition in the U.S. Standards for Grain, may be 

composited with other samples that are “OK” for odor and condition to form a 

composite sample of the lot. For individual carriers that meet the definition of 

“infested”, the shipper has the options listed in Directive 9180.59 “Composite

Analysis for Combined Land Carrier Inspections”

Composite analysis is restricted to carriers inspected within the official service 

provider’s area of responsibility. However, under combined-lot procedures, an 

applicant may combine single lots of the same grade and same quality across 

different official service providers’ areas of responsibility.

Once the composite is formed, the composite group may not be 

reassembled into different combinations to meet the desired quality.

(a) Review Inspection

The applicant may request review (reinspection, appeal, board appeal) 

inspections on the composite sample. The basis of the inspection is the

file sample of the composite.

(b) Combined-Lot

When complete inspection of all composites has been finished, the 

applicant has the option of requesting combined-lot procedures for 

certifying multiple composites on a single certificate (see Code of 

Federal Regulations 800.85). For example if the first, third, and fifth 

composites are U.S. No. 2 Yellow Soybeans, these composites (of like 

quality) may be combined on a single certificate.

Note: Two composite single lots of different grades may be 

combined if load order indicates the lower of the grades or better. 

For example if the combined lot load order indicates a grade of 

‘U.S. No. 3 or better Yellow Corn’, lots graded as U.S. No. 3 Yellow 

Corn can be combined with lots graded as U.S. No. 2 Yellow Corn 

with a final grade of U.S. No. 3 or better Yellow Corn.
FGIS Directive 9180.78 September 30, 2013

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(3) Average Grade/Average Composite

To form an average grade/average composite sample from multiple 

containers, official personnel must sample each individual container from 

locations within the Official Service Provider’s area of responsibility in a 

reasonably continuous operation. Official personnel must then examine 

each container for odor, insects, and condition, and grade each container 

individually (with no certificates issued).

After grading individual containers, the applicant may select the containers to 

be combined for the average grade/average composite. All containers have to 

be similar in condition but do not have to be of the same grade. However, all

of the containers must be of the same class. Container samples which exceed

Food and Drug Administration (FDA) defect action levels or are identified as 

sample grade based on sample grade criteria may not be combined for the 

average grade/average composite grade.

Each average grade/average composite may contain a maximum of 20 

containers and each container represents a component of the single lot

Average Grade/Average Composite analysis is restricted to carriers inspected 

within the official service provider’s area of responsibility. However, under 

combined lot procedures, an applicant may combine single lots of the same 

grade and same quality across different official service providers’ areas of 

responsibility

Once an average grade/average composite is certified it may not be 

reassembled.

(a) Reinspection

After an average grade/average composite is formed, a review 

inspection can be performed but must be on the same basis as the 

original inspection. Since containers were graded individually then

averaged, the review inspection will be on the basis of a review of 

each carrier. For example, 20 containers were graded individually then

averaged to form a single grade, thus the review inspection would be on 

the basis of a review of each container, and then averaged. Appeal and

board appeal inspections follow the same logic

(b) Combined-Lot

When complete inspection of all composites has been finished, and 

the composites have been certified as single lots, the applicant has 

the option of requesting combined-lot procedures for certifying multiple 

composites on a single certificate (see Code of Federal Regulations 

800.85). For example if the first, third, and fifth composites are U.S. No. 

2 Yellow Soybeans, these composites (of like quality) may be combined 

on a single certificate.
FGIS Directive 9180.78 September 30, 2013

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Composite grade single lots may be combined with average grade/average 

composite single lots

Note: Two average grade/average composite single lots of different 

grades may be combined if load order indicates the lower of the grades 

or better. For example if the combined lot load order indicates a grade of 

‘U.S. No. 3 or better Yellow Corn’, lots graded as U.S. No. 3 Yellow Corn 

can be combined with lots graded as U.S. No. 2 Yellow Corn with a final 

grade of U.S. No. 3 or better Yellow Corn.

Note: Retain file samples for a minimum of 60 days.

c. Weighing. A Class X weighing certificate is required to fulfill the mandatory export

weighing requirements of the USGSA. The Weighing Handbook (https://www.ams.

usda.gov/sites/default/files/media/WeighingHB.pdf) transmits general procedures 

for weighing grain shipments

Container weights are certified either individually or as a combined weight 

(one weight certificate with several container identifications on the certificate). 

Containers must be weighed within an Official Service Provider’s area of 

responsibility in a reasonably continuous operation with breaks not to exceed 88 

hours. If the 88-hour rule is satisfied, there is no limit to the number of containers 

that may be certified on a weight certificate. However, an applicant may elect to 

certify containers in smaller groups and combine using combined lot procedures

In lieu of weighing loaded containers, official personnel may transfer weights from 

another carrier (e.g. truck lot to container) or source to the container when the 

grain is officially Class X weighed. Official personnel must assure the weight of 

the grain source has not changed by checking carrier seals and other available 

information. Official personnel must observe the grain transfer then deduct any 

weight losses for grain not reaching the container

6. CERTIFICATION AND ADDITIONAL DOCUMENTATION

a. Certificates. Certify grain inspection results on an Official Export Grain Inspection

Certificate. Certify grain weight results on an Official Grain Weight Certificate. The 

Official Export Grain Inspection Certificate has a “Quantity” block on the certificate. 

Indicate the total number of containers represented by the certificate.

b. Combined-Lot Certification. Upon applicant request, a certified lot of grain (e.g., a

certificate for 20 containers containing U.S. No. 2 Yellow Corn) may be combined 

with another certified lot of grain of like quality (e.g., another lot with 20 containers 

of U.S. No. 2 Yellow Corn) to get one certificate. To issue a combined-lot certificate, 

the original certificates must be voided. A new certificate will be issued with all 

carriers listed, and the factor results must be calculated using a weighted average 

based on the number of containers on each certificate. Combined-lot certificates 

may be formed from single lot certificates that originated in different official service 

providers’ territories.

Note: All Container ID numbers must be placed in the remarks section of the 

combined-lot certificate.
FGIS Directive 9180.78 September 30, 2013

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c. Special Certificate Statements.

(1) Container identification. Record the container(s) identification(s) on the scale 

tape or ticket and list the identification(s) in the remarks section of the 

certificate, on the next page of the certificate, or on separate AMS letterhead if 

the carrier identifications do not fit in the identification block of the certificates. 

The certificate must reference in the identification block where to find the 

carrier identifications (see remarks or see next page).

(2) Grain sampled prior to loading the container. Include the statement “This grain

was sampled and graded prior to loading the container(s).” if the information

used for container certification was based on grain inspection results from 

other carriers or bins

(3) Fumigation statement. Place the following information in the “Remarks” 

section of the certificate.

If fumigated according to official procedures:

“The (grain) in carrier(s) (Carrier Identification) was/were fumigated according 

to official procedures.”

If only witness fumigation (official personnel present to observe but fumigation 

not done according to FGIS procedures):

“This (grain) was witnessed being fumigated with (dosage) of (product) after it 

was loaded into (Carrier Identification).”

(4) Combined-Lot Certification Statement: The official service provider should 

supersede ALL inspection certificates to be combined in the combined-lot 

certificate. In the remarks section state:

“This combined-lot certificate supersedes certificate Nos.______, dated 

_____; _____, dated ____; and _____, dated ____. The superseded 

certificates have not been surrendered.”

d. Letterhead Statement

(1) AMS letterhead stationary is used for all export grain

(2) Split lot shipments. Containers represented by one inspection or weight

certificate may ship overseas on more than one vessel. The applicant 

may need additional information and documentation to facilitate the 

import of containerized grain into a foreign country when this happens. An

applicant may request an optional letterhead statement to identify container 

identifications involved in a split shipment. The letterhead statement must 

reference the certificate number and certificate date. The letterhead statement 

may also include a reference to the grade of the shipment (if it is a reference 

to the inspection certificate) or to the total weight of the lot (if it is a reference 

to the weight certificate). The applicant may also state the name of the vessel 

that carried the containers
FGIS Directive 9180.78 September 30, 2013

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Statement example: “The following containers were graded as U.S. No.

Yellow Soybeans as identified by certificate number [show certificate number], 

dated [show date]. The applicant states that these containers were loaded 

onto the M/V [show vessel name].”

Following this statement, include the container identifications provided by the 

applicant. These container identifications must match the identifications, in 

part, on the referenced certificate.

The applicant may attach a copy of the referenced certificate to the letterhead 

statement. If another original certificate is needed by the applicant [one for 

each vessel], the applicant may request and receive a duplicate certificate.

7. SUPPLEMENTAL INFORMATION

All containers inspected by FGIS and its official service providers will be considered as 

export inspections and will be assessed at the applicable rate(s), including the export 

metric tonnage fee

8. QUESTIONS

Direct any questions regarding this procedure to the local field office or to the Policies, 

Procedures, and Market Analysis Branch (PPMAB). Also, please visit the “Inspection 

and Weighing of Containers” Q & A page on the AMS website