Distribution: FGIS, OSP Originating Office:QACD

Contents

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

2. BACKGROUND .................................................................................................................2

3. POLICY .........................................................................................................................2

4. PROCEDURES .................................................................................................................3

5. FILING INSTRUCTIONS .................................................................................................8

6. QUESTIONS .................................................................................................................8

In accordance with Federal civil rights law and U.S. Department of Agriculture (USDA) civil rights regulations and 

policies, the USDA, its Agencies, offices, and employees, and institutions participating in or administering USDA 

programs are prohibited from discriminating based on race, color, national origin, religion, sex, gender identity 

(including gender expression), sexual orientation, disability, age, marital status, family/parental status, income 

derived from a public assistance program, political beliefs, or reprisal or retaliation for prior civil rights activity, 

in any program or activity conducted or funded by USDA (not all bases apply to all programs). Remedies and 

complaint filing deadlines vary by program or incident.

Persons with disabilities who require alternative means of communication for program information (e.g., Braille, 

large print, audiotape, American Sign Language, etc.) should contact the responsible Agency or USDA’s TARGET 

Center at (202) 720-2600 (voice and TTY) or contact USDA through the Federal Relay Service at (800) 877-8339. 

Additionally, program information may be made available in languages other than English.

To file a program discrimination complaint, complete the USDA Program Discrimination Complaint Form, AD-3027, 

found online at How to File a Program Discrimination Complaint and at any USDA office or write a letter addressed 

to USDA and provide in the letter all of the information requested in the form. To request a copy of the complaint 

form, call (866) 632-9992. Submit your completed form or letter to USDA by: (1) mail: U.S. Department of Agriculture, 

Office of the Assistant Secretary for Civil Rights, 1400 Independence Avenue, SW, Washington, D.C. 20250-9410; (2) 

fax: (202) 690-7442; or (3) email: program.intake@usda.gov.

United States Department of Agriculture

Agricultural Marketing Service

Federal Grain Inspection Service

Program Notice FGIS-PN-23-04 July 19, 2023

UNIFORM REPORTING OF SAMPLE NOT AVAILABLE 

FOR SIMS AND STEP
FGIS Notice PN-23-04 July 19, 2023 

Page 2 

1. PURPOSE

This notice provides guidance and instructions for official service providers (OSP), 

supervising Federal Grain Inspection Service (FGIS) Field Offices (FO), and Board of 

Appeals and Review (BAR) for reporting the status of Sample Not Available (SNA) file 

samples and separations selected under the Sample Inspection and Monitoring System 

(SIMS) and Subjective Testing and Evaluation Process (STEP) to promote consistent 

and uniform data reporting across the official inspection system. 

2. BACKGROUND

SIMS is an automated information system which documents the results of monitoring 

(supervision) inspections and a tool designed to help managers promptly detect 

developing problems. SIMS collects information (comparative inspection results) that 

describe current inspection performance. The results are automatically processed and 

then subjected to standard statistical tests that can signal a real or potential grading 

problem. SIMS provides a representative historical database of inspection information 

for use in standards/CUSUM tolerance analysis, economic impact analysis, and other 

special studies.

STEP is a critical foundation process used to ensure that the FGIS Quality Assurance 

Specialist’s (QAS) or Agency Quality Assurance Specialist’s (AQAS) line on interpretive 

factors conforms with the BAR’s line. The objective of STEP is to control and minimize 

interpretive variability encountered with subjective factor determinations in all graded 

commodities (grain, rice, and pulses). STEP functions like onsite monitoring/over-theshoulder supervision and involves the BAR reviewing and adjusting the QAS’ or AQAS’ 

factor separations and when required, returning the adjusted separations to the OSP

or supervising FO for review. This allows inspectors to properly adjust their lines and 

improve inspection accuracy.

In 2007, the FGIS released and implemented the Quality Assurance and Control 

(QAC) module within its portfolio of online business applications (FGISonline). FGIS 

official service providers use this module to enter data, access results, and track 

inspector performance and ability, with immediate statistical information to measure 

the performance of the official grain inspection system. In QAC, users are required to 

identify any situation where system selected inspections and/or file samples are not 

available for SIMS and STEP monitoring purposes.

Currently, national SIMS and STEP SNA (supervision conducted by FGIS) are 

reported to the FGIS Quality Assurance and Compliance Division (QACD) via e-mail 

to FGISQACD@usda.gov and then a QACD team member identifies the selected 

record (QACD ID) as SNA and documents and saves the reason provided by the OSP 

or supervising FO in the SIMS or STEP Remarks section of QAC. Local SIMS SNA 

(supervision conducted by OSP) are identified by an authorized OSP representative 

within QAC using the same process. 

QACD uses the SIMS and STEP SNA data to evaluate an OSPs level of participation 

and compliance with these mandatory programs.

3. POLICY
FGIS Notice PN-23-04 July 19, 2023 

Page 3 

OSPs, supervising FOs, and BAR must report all SIMS and STEP SNA in accordance 

with the following procedures.

4. PROCEDURES

National SIMS and STEP SNA must be reported by the OSP, the supervising FO, or the 

BAR using the following requirements and an e-mail notification including the following 

information must be sent to FGISQACD@usda.gov. OSPs must report SNA as soon as 

possible but no later than five business days of the SIMS or STEP selection notification. 

Supervising FOs or BAR must notify QACD as soon as possible but no later than five 

business days of sample receipt or from when the issue was identified. Local SIMS SNA

must be reported by the OSP in QAC within five business days of the SIMS selection 

notification.

National SIMS SNA Notification E-mail

(1) The subject line of the e-mail must include:

(a) SNA (National SIMS) and OSP or supervising FO Name.

(2) The body of the e-mail must include:

(a) the QACD ID number;

(b) the approved SNA short code defining the specific reason why the sample is 

not available for SIMS; 

(c) the name and contact information of the person submitting the national SIMS

SNA to QACD. 

STEP SNA Notification E-mail

(1) The subject line of the e-mail must include:

(a) SNA (STEP) and OSP name, supervising FO name, or BAR as applicable.

(2) The body of the e-mail must include:

(a) the QACD ID number;

(b) the approved SNA short code defining the specific reason why the sample is 

not available for STEP. 

(c) The name and contact information of the person providing the STEP SNA to

QACD.
FGIS Notice PN-23-04 July 19, 2023 

Page 4 

APPROVED SNA SHORT CODES AND DEFINITIONS

OSPs, supervising FOs, and BAR must use the approved SNA short codes below when 

submitting national SIMS and STEP SNA information to QACD or when entering Local 

SIMS SNA information in QAC. The approved SNA short code must be entered into the 

SIMS or STEP Remarks section each respective QACD ID. 

OSPs must use the following approved short codes and their definitions when 

reporting SIMS SNA (1 through 15). 

OSP Approved SNA Short 

Code SIMS

DEFINITION

1 Mishandled OSP

The file sample was spilled, dumped prior 

to retention requirement, commingled, 

misplaced, etc., by the OSP performing 

the original inspection.

2 REX The file sample was called for reinspection 

or retest.

3 APPEAL The file sample was called for Federal 

Appeal or Board Appeal.

4 VOID The selection was made from a voided 

certificate.

5 Average Grade RAIL

The selection was made from a certificate 

which represents a mathematical average 

of more than one individually graded rail 

car.

6 Average Grade CONTAINER

The selection was made from a certificate 

which represents a mathematical average 

of more than one individually graded 

container.

7 Combined Lot

The selection was made from a combined 

lot certificate and represents multiple lots, 

previously certified as individual lots.

8 Divided Lot

The selection was made from a divided lot 

certificate and represents a portion of a lot, 

originally certified as a larger lot.

9 Mycotoxin/Other SUBMIT

The OSP was required to grind or use the 

entire file sample for Mycotoxin or other 

required laboratory testing. (Submitted 

Samples Only)

10 No File Sample OCIS

The selection was made from an official 

commercial inspection service (OCIS) 

certificate and the approved agreement 

does not require the retention of file 

samples.
FGIS Notice PN-23-04 July 19, 2023 

Page 5 

OSP Approved SNA Short 

Code SIMS

DEFINITION

11 QAS/AQAS Local

The inspector who officially graded the 

requested sample, selected as a LOCAL 

SIMS, was the FGIS Quality Assurance 

Specialist or Agency Quality Assurance 

Specialist (AQAS - supervision inspector). 

No other OSP personnel are available 

or authorized to perform the supervision. 

(Local SIMS only)

12 SIMS Request Missed/Overlooked

The SIMS request was missed or 

overlooked by the OSP performing the 

original inspection and the file sample is 

no longer available for submission.

13 SIMS Not Delivered

The SIMS sample was shipped by the 

OSP performing the original inspection 

but was not delivered to the supervising 

FO by the courier. The OSP must provide 

supporting evidence to substantiate any 

claims of undelivered SIMS (i.e., shipping/

delivery records)

14 Corrected Cert (Late SIMS Request)

The SIMS was selected on the basis of 

a corrected certificate which was issued 

after the file sample retention period had 

expired and the file sample is no longer 

available for submission.

15 Other OSP (See SIMS Remarks)

The reason for the SNA was not identified 

in reasons 1 through 14. I have clearly 

provided and described the reason for the 

SNA which must be documented in the 

SIMS REMARKS section of the QACD ID.

Supervising FOs must use the following approved short codes and their 

definitions when reporting SIMS SNA (16 through 24).

Supervising FO Approved SNA Short 

Code SIMS

DEFINITION

16 Mishandled FO

The file sample was spilled, dumped prior 

to retention requirement, commingled, 

misplaced, etc., by the supervising FO 

prior to performing the supervision.

17 Mishandled SHIPPING

The file sample was mishandled during the 

shipping process and was received by the 

Supervising Field Office in an unusable 

condition. 

18 Wrong Sample Shipped

The file sample submitted to the 

Supervising Field Office was for a different 

lot and/or identification than requested by 

the QAC system.
FGIS Notice PN-23-04 July 19, 2023 

Page 6 

Supervising FO Approved SNA Short 

Code SIMS

DEFINITION

19 Another Analysis Requested

The OSP was required to use the file 

sample for other requested services 

which weren’t included in the original 

request. This is only permitted in instances 

where the Supervising Field Office has 

approved in writing use of the file sample 

for these purposes, and both the applicant 

and buyer have waived their rights to 

reinspection, appeal, and board appeal in 

writing, in order to complete the analysis.

20 Out of Condition

The condition of the received file sample 

has “materially” changed since the original 

inspection was performed due to high 

moisture or other circumstances.

21 SIMS Jurisdiction

This was a LOCAL SIMS selection 

and mistakenly sent to the supervising 

FO instead of the OSP performing the 

supervision as required.

22 Returned to Applicant

The file sample was returned to the 

applicant prior to completing the required 

retention period. This is only permitted in 

instances where the supervising FO has 

approved in writing use of the file sample 

for these purposes, and both the applicant 

and buyer have waived their rights to 

reinspection, appeal, and board appeal in 

writing.

23 Not Supervised

The file sample was submitted to and 

received by the supervising FO but 

was not supervised due to unforeseen 

circumstances (i.e., government 

shutdown) or other workload issues per 

the approval of the FOM.

24 Other FO (See SIMS Remarks)

The reason for the SNA was not identified 

in reasons 16 through 23. I have clearly 

provided and described the reason for the 

SNA which must be documented in the 

SIMS REMARKS section of the QACD ID.
FGIS Notice PN-23-04 July 19, 2023 

Page 7 

OSPs must use the following approved short codes and their definitions when reporting 

STEP SNA (25 through 28).

OSP Approved SNA Short Code STEP DEFINITION

25 Mishandled OSP

The separation was spilled, dumped prior 

to selection, commingled, misplaced, etc., 

by the OSP prior to shipping to the BAR 

for analysis.

26 STEP Request Missed/Overlooked

The STEP request in QAC was missed 

or overlooked by the OSP performing the 

original inspection and the separation is no 

longer available for submission.

27 STEP Not Delivered

The STEP separation was shipped by the 

OSP but was not delivered to the BAR 

by the courier. The OSP must provide 

supporting evidence to substantiate any 

claims of undelivered STEP (i.e., shipping/

delivery records).

28 Other OSP (See STEP Remarks)

The reason for the SNA was not identified 

in reasons 25 through 27. I have provided 

and clearly described the reason for the 

SNA which must be documented in the 

STEP REMARKS section of the QACD ID.

Supervising FOs must use the following approved short codes and their definitions 

when reporting STEP SNA (29 through 32).

Supervising FO Approved SNA Short 

Code STEP

DEFINITIONS

29 Mishandled FO

The separation was spilled, dumped prior 

to selection, commingled, misplaced, etc., 

by the supervising FO prior to shipping to 

the BAR for analysis.

30 STEP Request Missed/Overlooked The STEP request in QAC was missed 

or overlooked by the supervising FO and 

the separation is no longer available for 

submission.

31 STEP Not Delivered

The STEP separation was shipped by the 

supervising FO but was not delivered to 

the BAR by the courier. The supervising 

FO must provide supporting evidence to 

substantiate any claims of undelivered 

STEP (i.e., shipping/delivery records).

32 Other FO (See STEP Remarks)

The reason for the SNA was not identified 

in reasons 29 through 31. I have provided 

and clearly described the reason for the 

SNA which must be documented in the 

STEP REMARKS section of the QACD ID.
FGIS Notice PN-23-04 July 19, 2023 

Page 8 

The BAR must use the following approved short codes and their definitions when 

reporting STEP SNA (33 through 38).

BAR Approved SNA Short 

Codes STEP

DEFINITIONS

33 Mishandled BAR

The separation was spilled, dumped prior 

to completion, commingled, misplaced 

etc., by the BAR prior to completing the 

analysis.

34 Mishandled SHIPPING

The separation was spilled, dumped prior 

to completion, commingled, misplaced 

etc., by the BAR prior to completing the 

analysis.

35 Wrong Sample Shipped

The separation submitted to the BAR was 

for a different lot and/or identification than 

requested by the QAC system.

36 Out of Condition

The condition of the separation submitted 

to the BAR has “materially” changed since 

the SIMS supervision was performed due 

to high moisture or other circumstances.

37 Not Supervised

The separation was submitted to 

and received by the BAR but was 

not supervised due to unforeseen 

circumstances (i.e., government 

shutdown) or other workload issues per 

the instruction and approval of the BAR 

Chairman.

38 Other BAR (See STEP Remarks)

The reason for the SNA was not identified 

in reasons 33 through 37. I have clearly 

provided and described the reason for the 

SNA which must be documented in the 

STEP REMARKS section of the QACD ID.

5. FILING INSTRUCTIONS

File a copy of this program notice with the FGIS Quality Handbook. The handbook will 

be revised at a later date.

6. QUESTIONS

Direct any questions regarding this program notice to the AMS - FGIS Quality 

Assurance and Compliance Division by e-mail to: FGISQACD@usda.gov