1. Container Handbook
The need for a comprehensive yet streamlined resource regarding containers was established leading up to and including recent GIAC meetings. As a result, Jacob Thein (FGIS - PPMAB) reported relevant work is already in progress, with current plans to:
- Move instructions from critical directives such as FGIS Directive 9180.78 (Procedures for Bulk Commodities Exported in Containers) into a handbook; and
- Within that handbook, incorporate other relevant resources (directives, bulletins, memos) by reference (including hyperlinks).
As this work is already progressing, the GIAC recommends FGIS to continue their work in this area, with the following emphases:
- Transparency, including a publicly published timeline for comment & review .
- Enlisting stakeholder input throughout the development process, including providing clear instructions for submitting comments & inviting industry associations to participate.
- Streamlining, including collecting or referencing all relevant information in one resource.
- Inclusion of instructions for USGSA and AMA commodities.
2. Equipment Equivalency
Prioritize policies for measuring equivalence that can be applied to potential alternative, new technologies under consideration for Official use. The general criterion would be that the use of additional technologies for a given test would not create unacceptable systemic variability beyond what is present with the existing technology.
3. Updating FGIS-APHIS/PPQ MOU
The Grain Inspection Advisory Committee (GIAC) recommends that FGIS facilitate a conversation with APHIS to update the existing FGIS/APHIS PPQ MOU. In cases where FGIS has granted a waiver of official inspection and weighing requirements, the MOU will allow for third party insect inspection and witness of fumigation reporting to APHIS for phytosanitary certificate issuance. By implementing this change to the MOU agreement, export facilities can be assured of receiving a phytosanitary certificate in emergency situations when an FGIS waiver is issued.
Currently, when FGIS inspection services are waived or otherwise unavailable, the MOU agreement between FGIS and APHIS/PPQ does not allow for phytosanitary certification without a 921-2 form issued by FGIS. In case of natural disasters or other interruption of services, there is not a protocol in place that provides for phytosanitary issuance required by importing countries, but rather APHIS assesses each situation on a case-by-case basis. We feel this change to the MOU will help facilitate grain flow throughout the industry by allowing for continued grain shipments at export facilities when waivers are issued.
4. Laboratory Scales
The Grain Inspection Advisory Committee recommends that the Federal Grain Inspection Service adopt the ASTM Class 4 or better weights as the lab scale standard. This change will:
- Provide a procedure for testing laboratory scales for precision across the FGIS range of use.
- Justify the use of expanded resolution.
- Provide flexibility for future changes in laboratory scale procedures.
5. Periodic Updates for FGIS Inspection Instructions
To enhance the transparency and accessibility of the review process for the FGIS inspection instructions, we recommend the following actions:<
- Provide Clear Contact Information: Ensure that detailed contact information, including names, roles, and contact methods (email, phone, etc.), for relevant FGIS personnel is readily available.
- Outline Submission Guidelines: Develop and provide clear and concise guidelines for submitting recommendations, specifying any required formats or documentation.
- Schedule Regular Updates: Continue with a published schedule for regular updates and reviews of the instructions, with opportunities for stakeholders to provide input at each stage.
These steps will help make the review process more inclusive and transparent, ensuring that all stakeholders have a voice in the development and improvement of the FGIS inspection instructions.