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 #218 November 5, 2008

TO: FGIS POLICY BULLETIN BOARD

FROM: John Giler, Director

 Field Management Division 

SUBJECT: “Average Quality” Unit Trains

ORIGINATING OFFICE: Policies and Procedures Branch

1. PURPOSE

This memorandum provides procedures for combining multiple railcar 

inspection results (individual grades or composite grades) for the 

purpose of issuing a single inspection certificate for the lot. 

2. BACKGROUND

We have seen an increasing number of requests from railcar shippers 

for “average quality” certification of unit trains. The purpose of the 

request is to obtain a single certificate representing the entire unit train 

that may contain varying quality within the train. In the absence of any 

specific guidelines in our instructions or handbooks that are pertinent 

to “average quality” of unit trains, we are offering 2 separate options 

for shippers to obtain a single certificate representing an entire unit 

train.

3. INSPECTION PROCEDURES

For the purposes of this memo FGIS will consider that a single lot may 

represent an individual railcar or a composite sample up to 5 railcars.

Option (1) – Request “Combined Lot” inspection procedures. Under 

the provisions of section 800.85 “Inspection of grain in combined lots,” 

of the United States Grain Standards Act (USGSA) regulations, grain 

that has been officially inspected and certified as two or more single 

lots may be recertified as a combined lot if (i) the grain in each lot

was sampled in a reasonably continuous operation; (ii) the original 

inspection certificates for the single lots have been surrendered (if 

issued); (iii) representative file samples of the single lots are available; 

(iv) the grain in the single lots is of one grade and quality; 
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(v) official personnel who performed the inspection service for 

the individual determine that the samples used as a basis for the 

inspection of the grain in the single lots were representative at the 

time of sampling and have not changed condition; and (vi) the quality 

or condition of the grain meets uniformity requirements established by 

FGIS for official inspection of grain in combined lots.

In reference to unit trains, only railcars (single or composite grades) 

that are uniform in quality (same grade) and condition may be 

combined to form a combined lot.

Option (2) – Request inspection of the unit train under the CuSum 

loading plan with “average quality” factor criteria. When the load order 

grade specifies the lot inspection and certification is to be based on 

an “average” quality, inspection of the unit train will be on the basis of 

sublot inspections. When “average quality” is specified for a particular

factor(s) it is the responsibility of the shipper to maintain the overall 

quality of the lot. If the overall average of the lot exceeds the specified 

average the applicant has the option of requesting a review inspection 

of the entire lot, or accepting Option 1 certification of the unit train.

Official personnel must set up the inspection log for “average quality” 

on the specified factors. Include information on the log that provides 

information which factor(s) are determined on the basis of “average 

quality.” Do not enter any starting values or breakpoints for the 

factor(s) that are “average quality.”

Material portions cannot occur on individual sublot factors that are 

declared “average” in quality. However, material portions may still 

occur for odor or condition, factors that have minimum/maximum, or 

absolute limits, or aflatoxin that exceeds FDAaction limits.

Note: Section 13(a)(10) of the USGSA and section 800.86(b)

(3) of the regulations require that the application for inspection 

and/or load order grade document reflect all the contract grade 

specifications.

4. QUESTIONS 

Direct any questions regarding this policy to 

AMS - FGIS Policies Procedures Market Analysis Branch.