United States Department of Agriculture

Agricultural Marketing Service

Federal Grain Inspection Service

Directive 9100.1 March 18, 2019

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

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.

FOREIGN QUALITY AND WEIGHT COMPLAINTS

Contents

FOREIGN QUALITY AND WEIGHT COMPLAINTS�����������������������������������������������������������������1

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

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

3. POLICY ��������������������������������������������������������������������������������������������������������������������������������

4. RESPONSIBILITIES�������������������������������������������������������������������������������������������������������������
FGIS Directive 9100.1 March 18, 2019

Page 2

1. PURPOSE

This directive establishes responsibilities and procedures for Federal Grain Inspection 

Service (FGIS) personnel to follow in addressing quality and weight discrepancies from 

overseas buyers on officially inspected and/or weighed grain, oilseeds, rice, pulses, and 

processed grain products

2. REPLACEMENT HIGHLIGHTS

This directive replaces FGIS Instruction 9100-1, Revision 2, dated October 8, 1998.

This directive addresses changes in division names, clarifies responsibilities, and sets 

timeframes for deliverables

3. POLICY

The International Affairs Division (IAD) works closely with the Foreign Agricultural 

Service (FAS) in investigating and responding to quality and weight discrepancies 

reported by importers of U.S. grain, oilseeds, rice, pulses, and processed grain 

products. Notification of a quality or weight complaint on any grain, rice, pulse or 

processed commodity that is or going to be exported, is considered as a foreign 

complaint. Complaint notifications are neither formal nor informal, regardless of the 

origin of the notification, the complaint must be reported to the FGIS, International 

Affairs Division. 

 

IAD gathers all information and data received from FGIS field offices or delegated 

states, the Technology and Science Division (TSD), the U.S. Agricultural Attaché, and 

the receiver. After evaluating all information and data, IAD prepares a report of findings 

(final report) and sends it to the buyer overseas through the FAS office at the U.S. 

Embassy

The purpose of the investigation is to verify whether the original quality inspection and 

certification were in fact correct and to determine, insofar as possible, what factors may 

have contributed to a discrepancy in results at destination

4. RESPONSIBILITIES

a. IAD is responsible for

(1) Receiving, recording, and processing all allegations or indications of

mishandling of export cargo inspection or weighing services from foreign 

sources, whether received orally, by telephone, electronically, or in writing.

(2) Recording all pertinent information about the discrepancy and maintaining a 

database of all the discrepancies received
FGIS Directive 9100.1 March 18, 2019

Page 3

(3) Notifying the field office immediately of any requests from any interested party

to the sale to retain the file sublots samples beyond the normal 90 days for 

export ships and 60 days for container shipments

(4) Notifying the field office as soon as possible after the discrepancy is reported

and requesting samples and documents, as appropriate. IAD will instruct the 

field office or official service provider to notify the export elevator that we have 

received a complaint

(5) Collecting all necessary information to evaluate the discrepancy and 

formulate a reply. Exporters, grain traders, importers, and FGIS field offices, 

are sources of relevant information. Information from the export service point

may include, but is not limited to:

(a) Original sublot file samples (when available)

(b) Load order

(c) Inspection logs and certificates

(d) Stowage exam documents

(e) Fumigation documents

(f) Scale tapes and logs, weights logs, event logs, automated weighing

program malfunction logs,WH-13 repair modification, forms, gate 

checks, seal logs, program changes, pertinent emails, time-lapsed video 

of the loading of the ship, and certificates

(g) Protein logs (if appropriate)

(h) Supervision results (if available)

(i) Work records (Grain Sample Ticket, Rice Sample Ticket, etc.)

(j) Field office manager’s memo transmitting all pertinent data highlighting 

any unusual circumstances or events

(6) Requesting that the Quality Assurance and Compliance Division (QACD) to

conduct a review of weighing for shipments involving weight discrepancies

(7) Maintaining contact with the appropriate FAS representatives in Washington, 

D.C. and the appropriate FAS overseas office(s) until the final report of 

findings has been issued. 

(8) Contacting the appropriate Animal and Plant Health Inspection Service 

(APHIS) representative in the United States and in overseas offices, for 

discrepancies involving phytosanitary issues

(9) Referring questionable or suspicious cases to QACD for review, when there is

evidence of a possible violation of the United States Grain Standards Act, 

(USGSA) as amended, or the Agricultural Marketing Act of 1946, or if it appears 

that litigation may result
FGIS Directive 9100.1 March 18, 2019

Page 4

(10) Issuing final report of findings to complainant within 30 days of receipt of 

all documentation and test results; with a courtesy copy to interested parties/ 

stakeholders including all FGIS directors. 

(11) Providing a status update to complainant if the final report is delayed beyond

30 days.

b. FGIS field offices and official service providers are responsible for:

(1) Take immediate action from any interested party to the sale to retain the

file sublots samples beyond the normal 90 days for export ships and 60 days 

for container shipments. After doing so, notify IAD of the request.

(2) Reviewing the sampling and inspection methods at the loading elevator used 

by the official inspection personnel performing the inspection.

(3) Submitting information requested to IAD within 5 days of notification. 

Requested information may include, but is not limited to:

(a) Original sublot file samples (when available) 

(b) Load order

(c) Inspection logs and certificates

(d) Stowage exam documents

(e) Fumigation documents

(f) Scale tapes and logs, weights logs, event logs, automated weighing

program malfunction logs,WH-13 repair modification, forms, gate 

checks, seal logs, program changes, pertinent emails, time-lapsed video 

of the loading of the ship, and certificates

(g) Protein logs (if appropriate) 

(h) Supervision results (if available)

(i) Work records (Grain Sample Ticket, Rice Sample Ticket, etc.) 

(j) Field Office manager’s memo transmitting all pertinent data highlighting

any unusual circumstances or events

(4) Ensuring file samples relating to the discrepancy are submitted to TSD in a 

timely manner

(5) Reporting to IAD immediately by telephone, all reports of overseas quality or

weight discrepancies received from any source other than IAD

(6) Reviewing IAD’s final report and, if necessary, taking appropriate corrective

action as indicated in the report or corresponding memo

(7) Sending a copy of IAD’s final report to the export elevator and, where 

applicable, to the official service provider that performed the inspection.
FGIS Directive 9100.1 March 18, 2019

Page 5

c. TSD is responsible for

(1) Analyzing samples from quality discrepancies sent from origin and 

destination, and reporting the results to IAD within 14 days of receipt. The 

samples will be analyzed for all factors necessary to respond to the complaint, 

except those factors for which the sample is of insufficient size or if the 

sample was not maintained in a manner to preserve its identity or condition

(2) Including any additional information concerning the results of the file sample

review and any specific information requested to IAD. Additional information 

such as the condition of the sample in the file container, type of sample bag, 

and any abnormal condition should be recorded

(3) Retaining all samples in appropriate file containers in cold storage for 6

months, unless otherwise directed by IAD.

d. The QACD is responsible for

(1) Initiating a review of weighing for shipments involving weight discrepancies

within 14 days of receipt

(2) Issuing a report of findings to the IAD with a copy to the Director of Field 

Management Division, within 30 days.

(3) Investigating discrepancies where possible violations may have occurred 

within 60 days of notification. If investigations take longer than 60 days to 

complete, QACD will apprise IAD of their statuses.

(4) Taking appropriate action, if warranted. QACD will provide IAD with a copy

of their findings.