The Grain Inspection Advisory Committee provides advice to the Secretary of Agriculture on matters related to the implementation of the U.S. Grain Standards Act. A topic of recurring interest over the past decade has been how new technology can be incorporated into the official grading system to improve efficiency, timeliness, consistency and accuracy. (Refer to Exhibit A for relevant resolutions from prior years.) In preparation for the next meeting, a subgroup of the committee collected input from industry and designated / delegated agencies.
Pending AMS/FGIS Initiative
With full GIAC support, Technology and Science Division (TSD), issued a draft process for evaluating new technology for use in the official system. The Federal Register notice can be found in Exhibit B. Comments were received and are under review. As that process becomes finalized, this report is meant to generate discussion to identify priorities and bring attention to the new evaluation process.
Project Objectives and Discussion Topics
- Maintain integrity and transparency of the official grain grading system
- Review current grading process to identify areas for streamlining with new or existing technology
- Consider how the additional use of technology can make grading less subjective
- Review current grading factors for relevancy. If factor not important in the market, why keep it?
- Discuss possible new approaches to grain grading. Rather than tweaking the existing system, is a fully automated inspection process possible and/or desirable?
Comments / Input
- Committee member Nick Friant consulted two of the primary industry associations, the National Grain and Feed Association (NGFA) and North American Export Grain Association (NAEGA) on the project. Overall, both are very supportive and see a real need for improving the official system through technological adoption. General comments included:
- Research to identify and define new technology is needed and should look at multiple technologies.
- FGIS should identify eligible equipment manufacturers and parameters.
- Government and industry should partner on this effort.
- Sources for R&D funding needs to be identified.
- Involve land grant universities to provide existing research and to participate in future research as identified.
- Reference similar technology development efforts (e.g., the automated diverter sampler) for guidance on future efforts.
- Identify current technology and provide a recommended list to FGIS for evaluation and possible approval.
- Committee member Curt Engel reached out to industry contacts and engaged in discussions related to current grain standards. For background and context, see these points:
- The Grade Standards establish the value basis for each commodity. The amalgamation of the individual factors determines the general grade value (#1, #2, etc.). The basis for factor determination is at question from both accurate identification as well as consistency and replication. Factor value has changed over time, e.g., dark, hard, and vitreous (DHV) in wheat and Test Weight (TW) in soybeans. Reviewing the standards for relevancy may be needed but should not prevent progress on technology adoption.
- Closer examination of factor value may be a guide to technological improvement. For example, should protein become a significant value function in corn? Do flour millers care about kernel hardness? Obviously, TW is important, but not critical, to soybean utility. There are likely grading factors whose value has changed over time and may need to be requalified on the basis of user/consumer requirements/preferences.
- The who is involved in and how the Standards become more relevant and functional is a puzzle with many pieces.
Specific industry comments include:- Producing consistent results is paramount.
- Automating/combining objective functions (TW, moisture content, and protein) is welcomed.
- Employing selective technology to identify subject grading factors. Optical scanning to identify damage makes good sense where applicable. Possibly works for yellow corn but not for wheat.
- People issues (labor and training) are large drivers.
- May find out there are factors to add.
- FGIS has the best opportunity to ask the industry (either directly or through sponsored research):
- Which (key) factors drive decision making and profitability, starting with the end user, then backing through the supply chain.
- Engage the processors and exporters to identify the factors interfering with providing an acceptable product to the end user. Soybean color comes to mind.
- Engaging the operators (country, terminal, exporter) to identify the factors that have the greatest subjectivity and highest failure cost.
- Committee member Janice Cooper spoke with representatives from delegated states and designated agencies. She heard strong support for the current official system and concerns about the continued availability of labor to fill their requirements. The staffing problem related to the lack of communication from the railroads about train arrival times was also mentioned, but that topic will be discussed separately. The agencies are incorporating innovation and technology in improving training for their staff and response time for their customers. Other comments from one or more agencies included:
- Increasing “need for speed” to meet customer demands and grading is the bottleneck.
- Various equipment providers are offering new devices including optical sorters, but without FGIS certification the agencies have little incentive to invest in new equipment.
- The MCI Autokicker was mentioned specifically as a system worth evaluating.
- Other technologies being used in unofficial grading may be applicable to official system.
- Streamlining grading by combining test functions may require a change to the grading standards, i.e. test weight.
- Focus of innovation has been on document handling and data entry to reduce errors and increase reporting efficiencies.
- Replacing pan tickets with electronic alternative is desirable.
- FGIS and industry should consider adopting distributed ledger technology to handle data management for the international grain system.
- Multiple vendors for moisture meters and mycotoxin test kits showed benefit of cost control and competition. Those examples should be replicated.
- While technology has helped streamline the process, some concern was expressed about “going too far” in eliminating human involvement in grading.
Next Steps
The Grain Inspection Advisory Committee will have the opportunity to discuss this topic at the December meeting and provide guidance on how to move forward. The input reported above contains both general and specific recommendations. The Committee may wish to consider several resolutions based on its discussion in Kansas City.
Respectfully submitted,
Janice Cooper
Nick Friant
Curt Engel
November 29, 2022
Exhibit A: Prior GIAC Resolutions Related to Technology
2013
- The Advisory Committee recommends the GIPSA initiate research to determine the feasibility of extending the theory of "equivalency" to multiple-constituent instruments in order to utilize standardized technology while maintaining accuracy and consistency in measurement of wheat protein.
- The Advisory Committee supports the use of water based mycotoxin test kits in the official inspection system. The committee recommends seeking official agency and industry stakeholder input regarding the implementation timeline.
2014
- The Advisory Committee recommends that GIPSA initiate the implementation of a Quantitative Rapid Test kit verification program for the detection of genetically engineered traits in grains.
- Whereas GIPSA is exploring the possibility of expanding the concentration ranges in performance criteria for mycotoxin test kits, the Advisory Committee recommends GIPSA consider setting the following ranges for performance to specific criteria.
- The Advisory Committee supports continued focus on water-based quantitative mycotoxin test kits. Industry efforts to be "green" by reducing use of hazardous chemicals and associated waste are becoming commonplace. Encouraging manufacturers of testing methodology to develop the water-based methods should be continued.
- The Advisory Committee recommends the GIPSA continue its work to utilize technology enhancements to advance efficiencies for grain inspections. For example, GIPSA should continue its work with the USDA Rice Studio (rice scanner project) by connecting with industry stakeholders for feasibility of using the technology for further evaluations: including rice brokens sizing, color, and potential uses with other grains.
- The Advisory Committee recommends the GIPSA review and update all quality assurance tolerances utilized in the official system. Specifically, the Advisory Committee recommends that the first to be reviewed reflect the Unified Grain Moisture Algorithm (UGMA) technology for moisture measurement. Whereas the Test Weight module/apparatus that is integrated in the current official moisture meters is capable of testing for the test weight of grain; the Advisory Committee recommends that GIPSA complete and report its research regarding the feasibility of changing the official method for determination of test weight from the kettle method to the test weight apparatus integrated in the official moisture meters.
- The Advisory Committee recommends that GIPSA continue its work with updating inspection lab lighting standards. Lab lighting is crucial for proper visual quality analysis. Advancements in LED technology and lower overall cost should prove this technology a suitable replacement for current approved lighting technology.
2015
- The Advisory Committee commends FGIS on the development of the USDA Rice Studio Rice Program; and recommends that imaging technology be studied for possible use in the determination of percent Dark Hard and Vitreous (DHV) for spring wheat sub classes. FGIS should also study the possible use of this technology to determine shrunken and broken kernel count in all wheat classes. • The Advisory Committee recommends that new equipment must be equal to or better than the old equipment in precision and repeatability in order to be approved as official. Performance of equivalent instruments should match or exceed that of the existing approved instrument in the same field environment. The Advisory Committee recommends GIPSA continue work with NIR Equivalence by continuing focus on improving performance in test instrument field studies. GIPSA should also consider including all NTEP approved instruments in the field studies to determine equivalency.
2016
- The Advisory Committee recommends that FGIS continue to research ways to reduce the variance of the Falling Number Test. The Advisory Committee encourages FGIS to continue its efforts to narrow the variance of the test; provide greater oversight and training for official service providers; and to actively support the development of new testing methods. Specific areas of research and possible procedural changes may include adjustments for altitude, the use of mechanical shakers and increased operator training on how the test tubes should be cleaned. The Advisory Committee also recommends that FGIS continue to monitor new testing methodologies to identify improved methods.
- The Advisory Committee recommends GIPSA continue evaluation of Test Weight Determinations using UGMA moisture instruments. The Advisory Committee supports the efforts of FGIS to automate data collection functions in the grain grading process.
2018
- The Advisory Committee commends FGIS for researching an improved method for HVAC classification in Durum wheat. The committee recommends FGIS continue to research and develop a bleaching method to quantify and separate HVAC kernels from soft kernels in durum wheat to facilitate subclass determinations. The committee encourages FGIS to further investigate whether the same or similar methods can be used to determine DHV kernels versus non-vitreous kernels in the Hard Red Spring Wheat class.
- "The Advisory Committee commends FGIS on its efforts to incorporate innovative technology by delivering services to its shareholders, while protecting the safety of personnel. The Committee strongly encourages the approval and implementation of the “pilot program” for Barge Stowage Examinations via camera system.
- The Committee also recommends FGIS continue studying its technological innovative programs for cost savings, efficiency, and operational safety concerns, as it relates to Vessel Stowage Examinations. (i.e. UAV with NIR technology and/or camera when applicable).
Exhibit B
AGENCY:
Agricultural Marketing Service, USDA.
ACTION:
Notice; request for comments.
SUMMARY:
The Agricultural Marketing Service (AMS) currently evaluates and approves technology for use in official grain inspection on a case-by-case basis. AMS proposes a new internal process that is meant to facilitate the introduction of new and improved inspection technology that promotes competition and transparency. AMS is seeking public comment on the proposed process.
DATES:
Comments must be received by September 9, 2022.
ADDRESSES:
Additional technical information on the evaluation process can be found in the “Procedure and Submission Guidelines for the Evaluation of Technology for Official Grain Inspection” at https://www.ams.usda.gov/sites/default/files/media/FGISUserGuideforManu… .
Interested persons are invited to submit written comments concerning this Notice using either of the following procedures:
- Federal eRulemaking Portal: https://www.regulations.gov . Follow the instructions for submitting comments. You can access this Notice and instructions for submitting public comments by searching for document number, AMS-FGIS-22-0019.
- Mail: Dr. Timothy D. Norden, National Grain Center, 10383 N. Ambassador Drive, Kansas City, Missouri 64153.
All submissions received must include the docket number AMS-FGIS-22-0019. All comments received will be included in the record and will be posted without change, including any personal information provided. Comments will be made available for public inspection at the above address during regular business hours or via the at https://www.regulations.gov .
FOR FURTHER INFORMATION CONTACT:
Timothy D. Norden, Chief Scientist, Technology and Science Division, Federal Grain Inspection Service, AMS, USDA; Telephone: (816) 702-3803, or Email: Timothy.D.Norden@usda.gov.
SUPPLEMENTARY INFORMATION:
AMS provides grain inspection services under the authority of the United States Grain Standards Act (7 U.S.C. 71-87k) (USGSA), as amended, and the Agricultural Marketing Act of 1946 (7 U.S.C. 1621-1627), as amended. USGSA at 7 U.S.C. 74 states that the primary objective of the United States standards for grain is to certify the quality of grain as accurately as practicable and to accommodate scientific advances in testing and new knowledge concerning factors related to, or highly correlated with, the end-use performance of grain. The primary focus of the proposed Inspection Technology Evaluation (ITE) Process is on the need and suitability of the technology for official grain inspection. Below is a description of the proposed ITE Process.
“Technology” refers to instrumentation, equipment, and the associated methods for measuring grain quality factors. “Factor” means a measurable grain quality attribute. This evaluation process does not apply to the research and development effort before the technology is deemed fit-for-purpose; that is, the instrument or method has already been developed so that it generates factor-specific results with sufficient accuracy for official grain inspection.
ITE Process Description
The ITE process starts with the submission of a written proposal by a manufacturer of technology for a specific inspection factor. Manufacturers provide an overview of the technology for which they seek approval. This overview should describe the technology solution, indicate to which grains and inspection factor, or factors the technology applies, and the steps the technology uses to analyze a sample. The proposal should address six criteria, which will form the basis of the initial evaluation. These criteria are: (1) need; (2) accuracy; (3) quality control; (4) automation; (5) testing time; and (6) testing cost.
An AMS review team conducts an initial evaluation of the proposal to determine if it meets these criteria. When the review team completes the initial evaluation, AMS decides whether to accept the proposal. This decision is documented and communicated to the manufacturer. If a proposal is not accepted, the manufacturer is informed of the specific deficiencies and the requirements for resubmission. If accepted, the proposal enters a queue, and the manufacturer is notified and provided with an estimate for the start date along with various factors that may affect the length of the evaluation process.
The remaining steps of the evaluation process focus on validating the performance of the submitted technology using AMS' developed criteria or specifications for the specific inspection factor. This allows for refinement of the initial review criteria to account for specific inspection needs and for a statistically sound evaluation of accuracy of the technology. If not already established, AMS develops performance criteria and specifications and determines whether a Federal Register notice is needed to finalize the criteria.
With established performance criteria and specifications, AMS requests that the manufacturer provides information and data supporting the criteria and specifications. When all requested information has been submitted and accepted, AMS conducts an independent verification that focuses on accuracy. AMS will also determine if the submitted technology delivers results that are equivalent to currently approved technology. If this process shows that the technology is accurate and it passes the equivalence test, AMS notifies stakeholders and provides them with the implementation plan. If AMS is unable to verify the accuracy or the technology is not equivalent, the manufacturer is notified of the deficiencies and the requirements for resubmission.
If AMS approves the technology, an AMS certificate of conformance (COC) is issued that allows for use in official grain inspection. If any alterations to the technology are made that could affect measurement results, the manufacturer should inform AMS in writing to determine the significance. In addition, if the manufacturer finds that the technology is not meeting AMS performance criteria, they should immediately inform AMS. Failure to inform AMS, may result in cancellation of the COC.
Evaluation Criteria
Need. AMS assesses the need criterion through a review of the manufacturer-provided information, input from stakeholders including the Grain Inspection Advisory Committee, and from internal information. AMS evaluates the demand for the testing technology from AMS customers and stakeholders and compares the demand to the costs of providing the testing service, including standardization, calibration, and quality control efforts. AMS recommends that manufacturers provide information from a market assessment of the technology that supports this demand. For existing inspection factors, a successful technology should be compatible with existing official procedures such as subsample size requirements. For a test factor with an existing single approved instrument model, a successful new instrument should offer an added benefit to official inspection and provide results in terms of accuracy that are equivalent to, or better than the currently approved instrument model. If pertinent, manufacturers should provide national or international regulatory requirements the technology addresses. This may include, but is not limited to, maximum levels for toxic substances.
Accuracy and Quality Control. Manufacturers should provide relevant data that support both the accuracy and quality control criteria. Manufacturers and other interested parties are encouraged to review the specific requirements and additional technical information at [insert hyperlink to technical document].
Automation. If the technology generates an electronic result, the manufacturer should provide procedures for automatic data capture and the method to modify the output.
Testing Time. Manufacturers should provide the estimated testing time required from sample receipt to final result. The testing time will be assessed by comparison to existing or similar technologies. Longer testing times should be justified by providing a significant advantage over existing technology.
Testing Cost. The manufacturer should provide itemized cost estimates for the technology, maintenance, consumables, and all materials and equipment needed to perform the test. AMS evaluates the estimated costs of the recommended quality control, calibration, and standardization procedures. The testing cost is compared to existing or similar technologies. Higher testing costs should provide significant advantages over existing technologies.
Melissa R. Bailey,
Associate Administrator, Agricultural Marketing Service.
[FR Doc. 2022-14671 Filed 7-8-22; 8:45 am]
BILLING CODE 3410-02-P