Background:
The Grain Inspection Advisory Committee works to advise AMS in part to better meet the needs of its customers who operate in a dynamic and changing marketplace. A recent change in the marketplace is the requirement from Japan for phytosanitary certificates on imported US grains. In order for exporters to receive a clean phytosanitary certificate, official fumigation methods and application must be followed under FGIS supervision. The methods specified in the Fumigation Handbook require the use of tubes in vessel holds for recirculation when certain criteria are met. Those tubes have created disposal issues for customers in Japan, which has become a barrier to trade.
This issue is most prevalent in vessels loading for Japan with voyage times greater than 18 days and having hold depths of >12-20 meters. Because Table 3 of the fumigation handbook does not allow surface application for holds of >12-20m and the safety hazards of entering slack holds below the vessel combings by fumigators, it requires the hold be tubed for recirculation.
Allowing subsurface fumigation (which places the fumigant 1’ below the surface of the grain) in holds up to 20 meters of grain with 18 days of exposure time, but yet not allowing surface fumigation of holds with even 12.1 meters of grain appears to be contradictory. This implies the rate of descent of the fumigant into the cargo will vary depending on the application method, even with the same 45g per 1,000 cuft of storage space. It also does not take into consideration the actual exposure time of 30 – 35 days that it takes US Gulf cargos to reach Japanese destinations.
Discussion Topics:
- Review the Fumigation Handbook Chapter 2, Attachment 5: Table 3 (pdf) to consider:
- Efficacy of surface versus subsurface application
- Fumigant Exposure Time of 30 days