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 #262 January 16, 2015

TO: FGIS POLICY BULLETIN BOARD

FROM: Robert Lijewski, Director 

 Field Management Division 

SUBJECT: Container Stowage Exams

ORIGINATING OFFICE: Policies, Procedures, and Market Analysis Branch

1. PURPOSE

This memorandum establishes guidelines for determining whether 

a container meets/does not meet FGIS standards for fitness due to 

penetrating light. This memo also clarifies the difference between 

“direct” and “diffuse” light and addresses acceptable forms of floor 

repair. 

2. BACKGROUND

Section 800.75(f)(2) of the regulations under the USGSA and FGIS 

instructions require stowage examinations of carriers when export 

and domestic grain shipments are officially sampled and inspected, or 

weighed, at the time of loading. In accordance with Directive 9180.48, 

Stowage Examination Services, a container stowage area must be 

considered clean, dry, free of infestation, rodents, toxic, substances, 

and foreign odor, and otherwise be suitable to store or carry bulk or 

sacked grain, rice, beans, peas, lentils, or processed commodities. 

The directive also provides instruction for examining the inside of the 

container for penetrating light to ensure that the container is free from 

small holes, cracks, separated floorboards, loose or missing fasteners, 

or other defects that could expose the product to damaging conditions.

Official personnel may encounter “aged” containers with penetrating 

light (similar to the light shining in around the vent) visible around a 

section of the doors, when the container is completely closed (possibly 

caused by a sprung or uneven door) even though the seals/gaskets 

appear to be intact.

Also, cracks or holes may be found in or around the perimeter of the 

wood floor resulting in questionable forms of floor repair being used.

This policy is established to alleviate uncertainty on what is acceptable 

when conducting container stowage exams.
Page 2

3. DEFINITIONS

Diffuse Light – light that is spread over an area and not concentrated. 

It will appear scattered and dispersed or as a glow. The inspector will 

be unable to see through the door to the outside.

Direct Light – a greater part of the light goes directly from the source 

to the area lit. It will appear bright and focused. The inspector will be 

able to see outside of the container.
Page 3

4. POLICY

a. Light

(1) “Diffuse” light glowing in around a portion of the door of the

container is acceptable as long as the door gaskets, panels, 

and hinges are intact.

(2) “Direct” light shining in around a portion of the door is not

acceptable.

Note: The inspector must view the light from every angle to

determine what type of light it is. If the inspector can see 

outside the container at any point it is considered “Direct” 

light and the container will not pass the stowage exam 

requirements.

Note: Regardless if there is light penetrating, the container 

must have acceptable door gaskets, panels, and hinges. 

If not, the container will not pass the stowage exam 

requirements.

Note: This policy pertains exclusively to light penetrating 

through the doors. Any type of light coming from the roof, 

side panels (except vent), or floor must be repaired.

b. Floor Repair

The wood floors must be repaired with like material, however it 

has been determined that caulking can be used where the floor 

meets the side panel.

5. FILING INSTRUCTIONS

File a copy of this memo with Directive 9180.48, Stowage Examination

Services, until the directive is revised to include this change. Field 

office managers must ensure that a copy of this memorandum is 

provided to official agencies operating within their circuit.

6. QUESTIONS 

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

to AMS - FGIS Policies Procedures Market Analysis Branch.