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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 #211 November 1, 2006

TO: FGIS POLICY BULLETIN BOARD

FROM: John Giler, Acting Director

 Field Management Division 

SUBJECT: CuSum “Average” Grade Interpretation

ORIGINATING OFFICE: Policies and Procedures Branch

1. PURPOSE

This memorandum provides guidelines for the application of “average” 

grade requests in load order documents. 

2. BACKGROUND

The CuSum loading plan represents an online acceptance sampling 

plan that provides continuous quality information throughout the 

loading history. Applicants for inspection may request minimum, 

maximum, or absolute (no sublot to exceed) limits on grading

factors and official criteria factors. The loading plan also provides the 

applicant the option of specifying “average” quality on individual, or all 

grading factors encompassing the grade determination.

“Average” grade applies to grade factors, moisture, and official criteria 

factors, but does not apply to odor and condition. It also does not 

apply to aflatoxin test results that are above the FDA action limit of 20 

ppb. Aflatoxin results above 20 ppb may not be averaged with results 

at or below 20 ppb.

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 Option1 certification of the grain on board.

Material portions can not 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.
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3. PROCEDURES FOR SETTING UP THE LOG

When the load order grade specifies the lot inspection and certification 

is to be based on an “average” quality, 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.

4. INTERPRETING A LOAD ORDER

a. “Average”.

If a load order stipulates U.S. No. 2 YSB (average), we would 

interpret that as a request for an average of all grading factors.

b. “Average” Select Factors.

If the load order stated U.S. No. 2 YSB, maximum 1.5 Foreign 

Material (fm), all other factors “average”, we would interpret the 

request as CuSum applied to fm only, and “average” for Test 

Weight (tw), Moisture, Damaged Kernels Total, Heat Damage, 

and Splits.

c. Example.

EXAMPLE LOAD ORDER

U.S. No. Two (2) or Better Yellow Soybeans (Average):

Average 13.5% moisture max.

Average minimum tw 55.0 lbs.

All other factors U.S. No. 1 Yellow Soybeans, except tw

No sublot to exceed 1% heat damage & 5% damage

FGIS RESPONSIBILITY

• Set up a log with the applicable grade factor limits for U.S. No. 

2 Yellow Soybeans with a moisture content of 13.5%.

• Indicate on the log that the grading factors are based on 

“average” quality.

• Do not complete starting value or breakpoint blocks on log.
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SHIPPERS RESPONSIBILITY

• Maintain a final grade average of U.S. No. 2 or Better Yellow 

Soybeans with 13.5% or less moisture.

• Meet stipulation that all factors are U.S. No. 1, except for test 

weight; and

• Do not allow any sublots to be loaded that exceed 1% heat 

damage or 5% damage.

5. FILING INSTRUCTIONS 

File a copy of this memo with the Grain Inspection Handbook, Book 

III, Chapter 2, Certification of Shiplots, Unit Trains, and Lash Barges. 

Field office managers must ensure that a copy of this memo is 

provided to official agencies that use the CuSum loading plan for 

shiplots, unit trains, and Lash Barges.

6. QUESTIONS 

Direct any questions concerning the interpretation of “average” quality 

load orders and the application of the CuSum loading plan to

AMS - FGIS Policies Procedures Market Analysis Branch.