United States Department of Agriculture

Agricultural Marketing Service

Federal Grain Inspection Service

Directive 9180.63 March 14, 2022

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

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.

INSPECTION OF HULLESS OATS

Contents

INSPECTION OF HULLESS OATS �����������������������������������������������������������������������������������������1

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

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

3. GENERAL INFORMATION���������������������������������������������������������������������������������������������������

4. DEFINITION OF HULLESS OATS ���������������������������������������������������������������������������������������

5. BASIS OF DETERMINATION ����������������������������������������������������������������������������������������������

6. QUALITY FACTORS DETERMINATION������������������������������������������������������������������������������

7. QUESTIONS ����������������������������������������������������������������������������������������������������������������������1
FGIS Directive 9180.63 March 14, 2022

Page 2

1. PURPOSE

This directive establishes uniform procedures for the factor analysis of Hulless oats 

(Avena nuda L.) as “Not Standardized Grain” under the U.S. Grain Standards A

(USGSA)

2. REPLACEMENT HIGHLIGHTS

This directive is revised to specify that any moisture meter listed as approved in 

the Moisture Handbook can be used to determine moisture content. This directive

supersedes FGIS Program Directive 9180.63, dated 6/15/1

3. GENERAL INFORMATION

a. Inspection of Hulless oats is upon request and on a factor only basi

b. All quantities referenced in this directive are approximate unless otherwise specified

c. There are no classes, subclasses, or numerical grades for Hulless oat

d. In addition to the factor analysis described in this directive, an applicant may

request other quality information (e.g., an exact count on stones in addition to th

percentage by weight, a percentage for a specific type of damage, etc.).

e. Use an approved divider to obtain subportions of a sample for analysis unless

otherwise specified.

f. If an approved mechanical sizer is unavailable, inspectors may handsieve the

sample

g. Official inspection personnel shall document inspection information during 

sampling and inspection

h. Record as “Not Standardized Grain” for the kind of grain on the work record

and certificate. Place “Hulless Oats” in the remarks section of the work record and 

certificate.

i. Under USGSA regulations there are four inspection levels: original inspection,

re-inspection, appeal inspection, and board appeal inspection

4. DEFINITION OF HULLESS OATS

Hulless oats, as described in this directive, is grain that before the removal of foreign 

material and other grains consists of 95 percent or more of whole kernels of Hulless 

oats and not more than 5 percent of other grains
FGIS Directive 9180.63 March 14, 2022

Page 3

Hulless oats are recognized by a non-adhering hull that is normally removed in the 

threshing process or can be removed easily by hand. Visually examine the sample to

determine if it meets the definition of Hulless oats. If an analysis is necessary, make 

the determination on a 25-gram representative portion before the removal of foreign 

material and other grains

a. Whole kernels are kernels with three-fourths or more of the kernel presen

b. Other grains for which standards have been established are barley, canola, corn,

flaxseed, oats, rye, sorghum, soybeans, sunflower seed, triticale, and wheat.

5. BASIS OF DETERMINATION

a. The determination of distinctly low quality, heating, infestation, or odor is made on

the basis of the lot at the time of sampling when a condition exists that may or may 

not appear in the representative sample and/or the sample as a whole

b. The determination of rodent pellets, bird droppings, other animal filth, broken 

glass, castor beans, cockleburs, crotalaria seeds, foreign material and other grains, 

garlic, live insect infestation, large stones, moisture, temperature, and unknown 

foreign substance(s), and a commonly recognized harmful or toxic substance(s) is 

made on the basis of the sample as a whole. When a condition exists that may not

appear in the representative sample, the determination may be made on the basis 

of the lot as a whole at the time of sampling

c. All other determinations are made after the removal of foreign materia

6. QUALITY FACTORS DETERMINATION

a. Purit

Upon request, determine purity on a 25-gram representative portion of the original 

sample before the removal of foreign material and other grains. Determine the

percent of purity by the weight of kernels and parts of kernels that meet the 

definition of Hulless oats. Report the percentage of Hulless oats on the work record 

and the certificate to the nearest tenth percent.

b. Heati

Hulless oats developing a high temperature from excessive respiration are 

considered heating. Advanced stage of heating Hulless oats will usually have a

sour or musty odor. Care should be taken not to confuse Hulless oats that are

heating with Hulless oats that are warm and moist because of storage in bins, 
FGIS Directive 9180.63 March 14, 2022

Page 4

railcars, or other containers during hot weather

Determine heating on evidence obtained at the time of sampling or on the sample 

either before or after the removal of foreign material and other grains. When

applicable, record the word “Heating” on the work record and report “Heating” in 

the “Results” section of the certificate.

c. Moistur

Moisture is the water content of Hulless Oats as determined by approved moisture 

instruments listed in the Moisture Handbook using the approved calibration (see 

FGIS Directive 9180.61

Determine moisture on a representative portion of approximately 650 grams before 

the removal of dockage. Record the percentage of moisture on the work record to

the nearest tenth percent. Report the percentage of moisture on the certificate to 

the nearest tenth percent

d. Odo

Odor Classification Examples

Sour Musty Commercially Objectionable

Foreign Odors

Boot

Fermenting

Insect (acrid)

Pigpen

Ground

Insect

Moldy

Animal hides

Decaying animal and vegetable matter

Fertilizer

Fumigant

Insecticide

Oil products

Skunk

Smoke

Strong weed

(1) Commercially Objectionable Foreign Odors (COFO) are odors, except smut 

and garlic that are foreign to grain and render it unfit for normal commercial 

usage

(2) Determine odor on evidence obtained at the time of sampling or on the 

sample either before or after the removal of foreign material

Fumigant or insecticide odors are considered commercially objectionable 

foreign odors if they linger and do not dissipate. When a sample of Hulless

oats contains a fumigant or insecticide odor that prevents the determination 

as to whether any other odor(s) exists, apply the following guidelines:

(a) Original Inspections. Allow the work portion to aerate in an open
FGIS Directive 9180.63 March 14, 2022

Page 5

container for 4 hours, or less, if the odor dissipates in less time

(b) Reinspections, Appeal, and Board Appeal Inspections. Allow unworked

file samples and new samples to aerate in an open container for 4 

hours, or less, if the odor dissipates in less time. The 4-hour aeration

requirement does not apply when the original work portion was aerated 

and retained as the final file.

Consider the sample as having a commercially objectionable foreign odor if 

the fumigant or insecticide odor persists based on the above criteria

Final Determinations. The inspector(s) is responsible for making the final 

determination for all odors. A consensus of experienced inspectors is used,

whenever possible, on samples containing marginal odors. The consensus

approach is not required if no odor or a distinct odor is detected

Designate Hulless oats containing a “DISTINCT ODOR” as musty, sour, or COFO 

as applicable. Report the odor in the “Results” section of the certificate.

e. Infestatio

Infested Hulless oats are oats infested with live weevils or other live insects 

injurious to stored grain

The presence of any live weevil or other live insects injurious to stored grain 

indicates the probability of infestation and warns that the oats must be carefully 

examined to determine if they are infested. In such cases, examine the work

sample and the file sample before reaching a final conclusion. Do not examine the 

file sample if the work portion is insect free.

Live weevils shall include rice weevils, granary weevils, cowpea weevils, maize 

weevils, and lesser grain borers. Other live insects injurious to stored grain shall

include grain beetles, grain moths, and larvae. Determine infestation on the lot as a

whole and/or the sample as a whole. The following table shows insect tolerance
FGIS Directive 9180.63 March 14, 2022

Page 6

Samples meeting or exceeding any one of these tolerances are infested: 

2 lw, or 1 lw + 5 oli, or 10 oli

I. 1,000-Gram Representative Sample 

(+ file sample if needed)

- Submitted Samples

- Probed Lots

- D/T Sampled Landcarriers

II. Lot as a Whole (Stationary

- Probed Lots (at time of sampling)

III. Online Sample (In-Motion) 

- Railcars Under Cu-Sum

- Subsamples for Sacked Grain Lots

- Components for Bargelots 3

- Components for Shiplots 3

1/ Examine work portion and file sample if necessary.

Do not examine file sample if work portion is insect free.

2/ Minimum sampling rate is 500 grams per 2,000 bushels.

3/ Minimum component size is 10,000 bushels.

Key: lw = live weevil

Oli = other live insects injurious to stored grain

When applicable, report the word “Infested” in the “Results” section of the 

certificate.

f. Test Weigh

The weight per Winchester bushel (2,150.42 cubic inches) as determined using an

approved device according to procedures prescribed in Federal Grain Inspection 

Service (FGIS) instructions

Determine test weight on a portion of sufficient quantity to overflow the kettle. 

Record test weight results on the work record as displayed on the electronic 

scale, or in whole and half pounds, disregarding fractions of a half-pound. Report

the test weight in the “Results” section of the certificate in whole and half pounds 

disregarding fractions of a half-pound

If requested, convert the pounds per bushel (lbs/Bu) result to kilograms per 

hectoliter (kg/hl) using the following formula: lbs/Bu x 1.287 = kg/hl and record in

the “Remarks” section in whole and tenths
FGIS Directive 9180.63 March 14, 2022

Page 7

g. Distinctly Low Qualit

Consider Hulless oats distinctly low quality when they are obviously of inferior 

quality and the existing quality factors or guidelines do not accurately reflect the 

inferior condition. Use all available information to determine whether the oats are

of distinctly low quality. This includes a general examination of the oats during

sampling and an analysis of the obtained sample(s)

(1) Large Debris. Oats containing two or more stones, pieces of glass, pieces of

concrete, or other pieces of wreckage or debris that are visible to the sampler 

but too large to enter the sampling device are considered distinctly low quality

(2) Other Unusual Conditions. Oats that are obviously affected by other unusual 

conditions which adversely affect the quality of the oats and cannot be 

properly graded by use of the grading factors specified or defined in the 

standards are considered distinctly low quality

Hulless oats suspected of containing diatomaceous earth are considered distinctly 

low quality unless the applicant specifically requests an examination to verify the 

presence of diatomaceous earth. If the laboratory examination verifies that the 

oats contain diatomaceous earth, then the oats are not considered distinctly low 

quality due to diatomaceous earth. Refer to FGIS Directive 9180.49, Grading an

Certification of Grain Containing Diatomaceous Earth and Silica Gel, for additional 

information regarding the testing of oats for diatomaceous earth

Designate the grain as distinctly low quality and report the reason(s) why the oats 

were distinctly low quality in the “Results” section of the certificate.

h. Smutt

Hulless oats that have kernels covered with smut spores so as to give a smutty 

appearance in mass or that contain more than 0.2 percent of smut balls. Determin

smutty on a portion of 500 grams of the original sample

Smut Spores. When smut spores are in a sufficient quantity to give the entire 

sample a smutty appearance, or the sample contains smut balls in excess of 0.2

percent, grade the oats smutty

When applicable, designate the oats “Smutty” and record the percentage to the 

nearest tenth percent on the work record. Report the percentage in the “Results”

section of the certificate.
FGIS Directive 9180.63 March 14, 2022

Page 8

i. Garlick

Hulless oats that contain four or more green garlic bulblets or an equivalent 

quantity of dry or partly dry bulblets in 500 grams of oats. Determine garlicky on a

portion of 500 grams of the original sample. Bulblets are divided into the following

types:

(1) Green garlic bulblets are bulblets that have retained all of their husks intact

(2) Dry or partly dry bulblets are bulblets that have lost all or part of their husks

(3) Consider bulblets with cracked husks as dry

(4) Three dry or partly dry bulblets are equal to one green garlic bulblet

Record the word “Garlicky” on the certificate. Upon request of the applicant for 

service, report the number of garlic bulblets in whole and decimals to the nearest 

hundredth percent in the “Results” section of the certificate. (i.e. 1/3=0.33, 

2/3=0.67

j. Ergot

Hulless oats that contain more than 0.10 percent ergot are considered ergot

Determine ergoty on a portion of 250 grams of the original sample

Ergot is a hard, reddish-brown or black grain-like mass of certain parasitic fungi 

that replaces oat kernels

Report the word “Ergoty” in the “Results” section of the certificate. When 

requested, the percentage of ergot may be recorded to the nearest hundredth 

percent on the certificate.

k. Soun

Kernels and pieces of Hulless oat kernels (except wild oats) that are not diseased, 

frost-damaged, germ-damaged, heat-damaged, insect-bored, mold-damaged, 

sprout-damaged, or otherwise materially damaged are considered sound

Determine sound as follows:

(1) Separate coarse foreign material and whole kernels of corn and soybeans 

from the work sample, and

(2) Separate foreign material, other grains, heat-damaged kernels, other 

damaged kernels, and wild oats from a work portion of 30 grams
FGIS Directive 9180.63 March 14, 2022

Page 9

The sum of the percentages of foreign material, other grains, heat-damaged 

kernels, other damaged kernels, and wild oats subtracted from 100 percent, equals 

the percentage of sound oats

Record the percentage of sound oats on the work record. Report the percentage of

sounds oats in the “Results” section of the certificate to the nearest tenth percent.

l. Fine Foreign Material and Other Grain

All matter other than Hulless oats, wild oats, and other grains are considered 

foreign material. Consider oat clippings and detached oat hulls and pieces of

detached hulls as foreign material

Barley, canola, corn, cultivated buckwheat, einkorn, emmer, flaxseed, guar, hulless 

barley, nongrain sorghum, oats, Polish wheat, popcorn, poulard wheat, rice, rye, 

safflower, sorghum, soybeans, spelt, sunflower seed, sweet corn, triticale, wild 

oats, and wheat are considered other grains

(1) Coarse Foreign Material and Other Grains:

Determine coarse foreign material and coarse other grains on 1-1/8 to 1-1/4 

quarts representative portion. Coarse foreign material and coarse other grains

are corn, soybeans, cockleburs, sticks, soybean pods, corn cobs, large feed 

pellets, pieces of dirt, sweet corn, and edible beans

(2) Foreign Material and Other Grains:

Determine fine foreign material and fine other grains after the removal of 

coarse foreign material and coarse other grains on a 30-gram representative 

portion

Fine foreign material are Star thistles, star burs, sandburs, morning glory, 

kinghead seeds, sticks not meeting the criteria for coarse foreign material, 

soybean pods less than one-half the total pod, and any other material too 

small to function as coarse foreign material and other grains

Fine other grains are broken kernels of corn or soybeans with more than onefourth of the kernel removed, and other grains
FGIS Directive 9180.63 March 14, 2022

Page 10

Computing Foreign Material. Compute foreign material by adding the

percentage of coarse foreign material to the percentage of fine foreign 

material in hundredths (disregard thousandths) and round the sum to the 

nearest tenth percent

Example:

Weight of representative sample = 700 grams

Weight of coarse foreign material = 5.00 gram

Percent of coarse foreign material

(5.00 / 700) X 100 = 0.71 perce

Weight of portion to be sieved = 30.00 gram

Weight of fine foreign material = 0.50 gram

Percent of fine foreign material

(0.50 / 30.00) X 10  = 1.66 perc

Percent of foreign material

(0.71 + 1.66  = 2.37 perc

Rounded to: = 2.4 percen

Computing Other Grains. Compute other grains by adding the percentage of

coarse other grains to the percentage of fine other grains (procedure similar 

to that given in the above example)

Record the percentage of foreign material (includes coarse and fine) on the 

work record. Report the percentage of foreign material in the “Results” section

of the certificate to the nearest tenth percent. Record the percentage of other 

grains (includes coarse and fine) on the work record to the nearest tenth 

percent

m. Heat-damaged Kernel

Heat-damaged kernels are kernels and pieces of Hulless oat kernels, other grains, 

and wild oats that are materially discolored and damaged by heat

(1) Whole Corn and Soybeans: Determine heat-damaged whole corn and 

soybeans on a work portion of 700 - 800 grams

Whole corn and soybeans that show evidence of distinct discoloration and 

damage by heat are examined to determine if they are heat damaged
FGIS Directive 9180.63 March 14, 2022

Page 11

(2) Oats, Wild Oats, and Other Grains: Determine heat-damaged kernels after 

the removal of coarse foreign material and coarse other grains on a 30-gram 

representative portion

Kernels of oats and wild oats that show evidence of distinct discoloration and 

damage by heat are hulled to determine if they are heat damaged. When the

hulled kernels show a reddish discoloration extending out of the germ, the 

kernels are heat-damaged

Hulless oats showing moldy, mold-like substance, sprouted, or dead germs, 

but no reddish cast or discoloration, are not considered sound oats, but 

function against the percentage of sound oats. Also, these oats are not

considered heat-damaged kernels

Other grains that show evidence of distinct discoloration and damage by heat 

are examined to determine if they are heat-damaged

Computing Heat-Damaged Kernels: Compute the percentage of heat-damaged 

kernels by adding the percentage of heat-damaged whole corn and soybeans to 

the percentage of heat-damaged oats, wild oats, and other grains in hundredths 

(disregard thousandths) and round the sum to the nearest tenth percent

Example:

Weight of representative sample = 700 grams

Weight of heat-damaged whole

corn and soybeans = 3.00 gram

Percent of heat-damaged whole

corn and soybeans

(3.00 / 700) x 100 = 0.42 perce

Weight of representative sample = 30.00 gram

Weight of heat-damaged oats, wild oats,

and other grains = 0.30 gram

Percent of heat-damaged oats, wild oats,

and other grains

(0.30 / 30.00) x 10  = 1.00 perc

Percent of heat-damaged kernels

(0.42 + 1.00  = 1.42 perc

Rounded to: = 1.4 percen

Record the percent of heat-damaged kernels to the nearest tenth percent 

on the work record. Report the percentage of heat-damaged kernels in the

“Results” section of the certificate to the nearest tenth percent.
FGIS Directive 9180.63 March 14, 2022

Page 12

n. Other Damaged Kernel

Other damaged kernels are kernels and pieces of Hulless oat kernels, except 

heat-damaged kernels, that are badly ground-damaged, badly weather-damaged, 

diseased, frost-damaged, germ-damaged, insect-bored, mold-damaged, sproutdamaged, or otherwise materially damaged. Heat-damaged kernels are not

considered as part of other damaged kernels. Determine other damaged kernels

after the removal of coarse foreign material and coarse other grains on a work 

portion of 30 grams

In general, oat kernels are considered damaged for inspection purposes only when 

the damage is distinctly apparent and of such character as to be recognized as 

damaged for commercial purposes. Green, immature kernels of Hulless oats that

are not otherwise damaged are considered sound

(1) Badly Ground and/or Weather-Damaged Kernels. Kernels which are badly

discolored by ground and/or weather conditions

(2) Germ-Damaged Kernels (Sick and/or Mold). Kernels in which the germ is

discolored or moldy as a result of respiration

(3) Insect-Bored Kernels. Kernels which have been bored or tunneled by insects

are considered damaged and scored against sound

(4) Sprout-Damaged Kernels. Kernels which have sprouted or which generally

have a crack in the seed coat over the germ area are considered damaged 

and scored against sound

(5) Computing Other Damaged Kernels. Compute other damaged kernels in

Hulless oats as follows:

Example:

Weight of representative portion = 30.00 gram

Weight of other damaged kernels = 0.22 gram

Percentage of other damaged kernels:

(0.22 / 30.00) x 10  = 0.73 perc

rounded to: = 0.7 percen

Report the percentage of other damaged kernels on the work record and the 

certificate to the nearest tenth percent.
FGIS Directive 9180.63 March 14, 2022

Page 13

o. Wild Oat

Wild oats are seeds of Avena fatua L. and A. sterilis L. They are usually identified 

by their characteristic slender kernels with twisted awns (so-called “sucker 

mouths”) and basal hairs or bristles on the germ end of the kernels. Wild oats are

not considered sound oats, but function against the percentage of sound oats

Determine wild oats after the removal of coarse foreign material and coarse other 

grains on a work portion of 30 grams

Record the percent of wild oats on the work record. Report the percent of wild oats

to the nearest tenth percent in the “Results” section of the certificate.

p. Seed Sizin

Determine seed sizing on a portion of 250 grams of the original sample using the 

5/64 x 3/4 slotted-hole sieve to determine the percentage of Hulless oats and other 

materials, except for fine seeds, that pass through the sieve as follows:

(1) Mechanical Sieving Method:

(a) Mount a 5/64 x 3/4 (1.984 x 19.050 millimeters (mm)) slotted-hole siev

and a bottom pan on the mechanical sieve shaker

(b) Set the stroke counter for 30 strokes

(c) Place the sample in the center of the sieve and start the machine. After

the sieve shaker has stopped, remove and clean the sieve and empty 

the bottom pan. Return the material lodged in the perforations to the oats

on top of the sieve

(d) Sieve the material that passed through the 5/64 x 3/4 inch slotted-hole 

sieve over a 5/64 (1.984 mm) triangular-hole hand sieve (small

buckwheat) to remove the fine seeds which may be present.

(e) Place the material that passed through the 5/64 x 3/4 inch slotted-hole 

sieve on the upper edge of the small buckwheat sieve. Hold the sieve at

a 10- to 20-degree angle and work the material down over the sieve with 

a gentle side-to-side motion. The fine seeds and other material passing 

through the small buckwheat sieve are considered fine seeds.

(2) Hand Sieving Method:

(a) Mount a 5/64 x 3/4 inch slotted-hole sieve on a bottom pan

(b) Place the sample in the center of the sieve

(c) Hold the sieve level in both hands with elbows close to the sides and the 

sieve perforations parallel to the direction of movement
FGIS Directive 9180.63 March 14, 2022

Page 14

(d) In a steady motion, move the sieve from left to right approximately 

10 inches and then return from right to left

(e) Repeat this operation 30 times

(f) Clean the sieve and empty the bottom pan. Return the material lodged in

the perforations to the oats on top of the sieve

(g) Sieve the material which passed through the 5/64 x 3/4 inch slotted-hole 

sieve over a 5/64 (1.984 mm) triangular-hole hand sieve (small

buckwheat) to remove the fine seeds which may be present.

(h) Place the material that passed through the 5/64 x 3/4 inch slotted-hole 

sieve on the upper edge of the small buckwheat sieve. Hold the sieve at

a 10- to 20-degree angle and work the material down over the sieve with 

a gentle side-to-side motion. The fine seeds and other material passing 

through the small buckwheat sieve are considered fine seeds.

Record the results of the sizing test to the nearest tenth percent on the work 

record. Report the results of the sizing test in the “Result” section of the certificate 

to the nearest tenth percent

7. QUESTIONS

Direct any questions concerning this directive to the Policies, Procedures, and Market 

Analysis Branch (PPMAB), at (202) 720-0228