United States Department of Agriculture

Agricultural Marketing Service

Federal Grain Inspection Service

Directive 9180.58 September 30, 1998

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

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MODIFIED OBSERVATION OF LOADING EXPORT 

FARM SERVICE AGENCY PRODUCTS

Contents

MODIFIED OBSERVATION OF LOADING EXPORT FARM SERVICE AGENCY PRODUCTS 1

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

2. PRODUCTS AND CARRIERS TO BE INSPECTED ........................................................2

3. APPLICANT RESPONSIBILITIES ........................................................................................2

4. INSPECTION PROCEDURES .............................................................................................2

5. CERTIFICATION ..................................................................................................................4

6. SUPPLEMENTAL INFORMATION .......................................................................................5

7. BILLING................................................................................................................................5

Attachment ..............................................................................................................................6
FGIS Directive 9180.58 September 30, 1998

Page 2

1. PURPOSE

This directive establishes the procedures for performing a modified observation of 

loading inspection service of specific export products for the Farm Service Agency 

(FSA). The purpose of the service is to minimize the amount of damaged bags/

commodities loaded on vessels, and enhance the perception of U.S. agricultural 

commodities overseas and the integrity of the foreign food assistance programs.

2. PRODUCTS AND CARRIERS TO BE INSPECTED

FSA requires that the Agricultural Marketing Service (AMS), Federal Grain Inspection 

Service (FGIS) personnel observe the loading of all noncontainerized (i.e., ships and 

barges) export shipments packaged in multiwall paper bags. These commodities 

include:

Corn Meal Instant Corn-Soya Masa Flour

Soy-Fortified Corn Meal Soy-Fortified Sorghum Grits

Corn-Soy Blend Wheat-Soy Blend

Corn-Soya Milk Wheat-Soy Milk

Instant Corn-Soya Milk Powdered Milk

3. APPLICANT RESPONSIBILITIES

The steamship lines, or their representative responsible for transporting the 

commodities to the overseas destination, must request the modified observation of 

loading from the local FGIS field office. The steamship line must also inform the field 

office of the time and place of service and designate (and make readily available to the 

FGIS inspector) a local contact, i.e., an individual(s) at the loading location, to address 

any deficiencies found during loading.

4. INSPECTION PROCEDURES

a. After receiving a request for inspection. Determine the number of inspectors

needed to perform the service based on the number of holds to load. Limit the 

number of inspection personnel to the minimum number necessary to perform the 

inspection.

b. Upon arrival at the loading berth. Notify the vessel and stevedoring representatives 

that FGIS will observe the loading at the request of FSA and locate the individual 

designated by the steamship line to address deficiencies. If the steamship line 

does not provide a representative to address deficiencies, contact FSA=s Kansas 

City Commodity Office (KCCO) at (816) 926-6198 and record this information on 

the work records.

c. Prior to loading. Before boarding, determine if it is safe to board the vessel. From

a safe position on deck, observe the condition of the hold(s). Record observations 

on the form FGIS-992, Services Performed, or other locally generated worksheet. 

Note any deficiencies. Also record deficiencies of all other FSA cargo not being 

inspected (such as leaking vegetable oil cans or torn poly-weave bags, etc.). 

Repeat the prior to loading inspection each day before loading starts.
FGIS Directive 9180.58 September 30, 1998

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d. Observation of loading. From a safe vantage point outside the hold(s), observe the

loading of the commodity.

(1) Record the loading start time(s), the type of product(s) loaded, the contract 

numbers on the bags, and the hold(s) loaded.

(2) Inspectors are not required to count the number of bags loaded and are not 

responsible for performing a condition examination of the product in the 

warehouse prior to loading. Product condition examinations are requested 

separately by FSA, if needed.

(3) Report any deficiencies found to the steamship line representative as soon as 

possible. If a steamship representative is not responsive in correcting 

deficiencies or is not readily available, report this to KCCO as soon as 

possible at (816) 926-6198 and document the situation on the work records. 

FSA defines deficiencies as follows:

(a) Damaged bags loaded and not removed from the vessel. Damaged bags 

removed from the vessel and damaged bags not loaded. 

Bags with all layers punctured and the contents leaking or exposed are 

considered damaged beyond repair. Such damaged bags may not be 

recouped and should not be loaded.

Bags with torn outer layers, but with inner layers intact, may be repaired 

by taping and loaded.

(b) Spilled commodity not removed from stowage area.

(c) Bags loaded during rain or left exposed to rain before the hatch covers 

are closed.

(d) Debris, such as wood, paper drinking cups, and food wrappers, left in 

the stowage area(s).

(e) Any other detrimental or unsanitary conditions that are not corrected in a 

satisfactory manner. Examples of detrimental or unsanitary conditions 

include: bags soiled with hydraulic fluid, paint, grease, rodent excrement, 

and excessive dirt. If, during the course of the inspection, a serious 

detrimental condition is found, such as rodent or insect infestation that 

could be considered actionable by the Food and Drug Administration, 

report the finding as soon as possible to the steamship representative 

and KCCO at (816) 926-6198.
FGIS Directive 9180.58 September 30, 1998

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e. Record. Record the following information on the work record:

(1) Any uncorrected deficiencies and the number of bags involved.

(2) The number of damaged bags loaded and not removed, number of damaged 

bags removed, number of damaged bags not loaded, and their condition 

(e.g., torn, stained, wet, etc.).

(3) The finish loading time.

(4) The steamship representative’s signature after each day’s loading to indicate 

concurrence with the number of bags not loaded, this includes damaged 

bags removed. Also, print the representative(s) name on the work record for 

future reference. If a discrepancy exists, count the bags with the steamship 

representative to resolve the discrepancy. (5) The steamship representative’s 

signature verifying the total number of bags loaded after loading is completed.

If a vessel stops loading cargo requiring observation of loading to load other 

cargo and then returns to loading the original cargo, observe the condition of 

the hold prior to the resumption of loading. If it appears that the subsequent 

loading may have damaged the cargo previously inspected, place a 

statement on the certificate. If unsure as to the effect the loading may have 

had on the quality of the previously inspected cargo, include a statement on 

the certificate that cargo not requiring inspection (specify type of cargo) was 

loaded on top of the previously inspected cargo.

5. CERTIFICATION

a. Required information. Certify the inspection results on form FGIS-993, “Commodity 

Inspection Certificate.” The certificate must contain the:

(1) vessel name,

(2) holds loaded,

(3) steamship line,

(4) port of loading,

(5) commodity name(s),

(6) stevedoring company,

(7) dates and times of loading,

(8) contract numbers located on bags,

(9) number and type of damaged bags loaded,

(10) number and type of damaged bags removed,

(11) number and type of damaged bags not loaded,

(12) deficiencies of previously loaded FSA cargo observed during prior to loading 

inspection, and

(13) total costs and hours billed (including standby, travel, and inspection).

The attachment provides an example of a completed certificate.
FGIS Directive 9180.58 September 30, 1998

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b. Distribution. Distribute the certificate as follows:

(1) Original to: The steamship line or their agent.

(2) One copy to each of the following:

Michigan State University

School of Packaging

East Lansing, MI 48824-1223

U.S. Department of Agriculture

FSA/P.D./C.B.

P.O. Box 2415

Washington, D.C. 20013-2415

U.S. Department of Agriculture

FSA/KCMO/DMD/CPDB

P.O. Box 419205

Kansas City, MO 64141-6205

6. SUPPLEMENTAL INFORMATION

Place the amount of product said to be loaded by the applicant on a piece of paper

separate from the inspection certificate and attach this information to the certificates 

sent to Michigan State University and FSA in Washington, D.C. Include the certificate

number on the paper in case the documents are separated.

7. BILLING

Submit the bill for all services performed using the processed commodity hourly 

inspection fee to FSA at:

U.S. Department of Agriculture

FSA/KCMO/DMD/CPDB

P.O. Box 419205

Kansas City, MO 64141-6205

Attachment 
FGIS Directive 9180.58 September 30, 1998

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Attachment