Inspections, Compliance, Enforcement, and Criminal Investigations


Collect samples only of specific assignment.

A. Equipment

  1. Double tube compartmented trier, 60 in. long
  2. Sampling cloth at least 60 in. long
  3. 1000 ml plastic graduate
  4. Paper bags or other suitable containers capable of holding more than one quart of sample and do not use canvas bags.
  5. FDA Metal Car Seals for resealing railroad cars
  6. Aluminum ladder
  7. Block and tackle to open railcar door

B. Drawing Sample
Principal sources of grain samples are railcars, barges, and trucks. Draw 5 probes (in duplicate) for each sample taken as described below. However, if the sample is to be Field Examined, an initial sample of 5 probes drawn as indicated below will be sufficient.

Probe samples from railcars and trucks as follows:

Probe #1 - From Center of car

Probe #2 - From 3-5 feet back from door post toward end of the car and approximately 2 feet from the side of the car.

Probe #3 - From 3-5 feet from the same end of the car, but approximately 2 feet from the opposite side of car as Probe #2.

Probe #4 - Same as Probe #2, but opposite end of car.

Probe #5 - Same as Probe #3, but opposite end of car.

Sketches I and II below are alternatives showing the approximate sampling locations.

Sample Schedule 4 Sketches 1 and 2 - Alternatives showing the approximate sampling locations

Insert trier in the grain at an angle of about 10° from the vertical, with the slot up and closed. Open slots. Give trier 2 or 3 short up and down motions, so that the openings will fill. Close slots (SEE CAUTION AT BEGINNING OF SCHEDULE), withdraw trier and carefully empty over sampling cloth. The cloth should be long enough to catch product from each compartment separately when you open the trier compartment doors; e.g. about 6 feet long.

C. Field Examination

Examine each pocket of the probe separately, looking for evidence of pink wheat, rodent pellets, insect damage and uneven loading or plugging. Note any insect infestation and record types of insects and whether live or dead. Count and report for each probe the number of rodent pellets, or rodent pellet fragments. Follow procedure in I.C.2 below. Count as pellets any that are sufficiently large to be readily identified by size, shape, surface coating, and/or presence of rodent hairs. Report the number of rodent pellets per sub. Measure the volume of each sub (probe) in quarts and calculate the average number of pellets per quart per I.C.2.a below. Place pellets from each sub in separate vials and submit with each wheat sub. Place each of the wheat subs in clean, paper bags.

Do not use canvas bags or take glass jars into railcars.

Substantially larger loads will require additional probing or larger samples taken from falling grain during loading or unloading operations.

Submit all suspect samples to laboratory for confirmatory analysis.

  1. Non-Violative Samples. When field examination shows sample as non-violative, return grain to the car, unless collected for pesticide analysis. Report results in the Remarks Section of the C/R.
  2. Violative Samples
    1. Rodent Pellet Contamination. The guideline for determining whether wheat is violative due to rodent contamination is: "9 mg or more rodent excreta pellets and/or fragments of rodent excreta pellets per kg of wheat."

      NOTE: Since it is impractical to weigh rodent pellets and wheat in the field, the following estimations can be used. Mouse pellets average approximately 8.7 mg each and a kilogram of wheat about 2.35 pints. This translates roughly as 1 pellet per quart of wheat or 1/2 pellet per pint.
      Where your field examination reveals one or more rodent pellets (or you can estimate that sufficient fragments of rodent pellets exist to equal one pellet) in a quart of wheat, take duplicate probes to furnish the claimants portion. Take the duplicate probes from the same locations as the original probes. Place the duplicates in separate containers and identify these to correspond with the original probes.

    2. Pink Wheat. Where evidence of pink wheat or other fungicide treated wheat is found, collect 15 probe samples. Take 5 probes from each end of the car and 5 probes from the center of the car. Submit the three 5-probe portions separately, using new clean containers.
    3. Insect Damaged Kernels. The violative status of these samples should be established by laboratory analysis. When any evidence of insect damage is revealed by cursory examination, collect duplicate samples and submit for laboratory analysis.
  3. Resealing Cars See IOM 4.3.4.
  4. Procedures for Actionable Cars. If field examination reveals an average of one or more rodent pellets per quart or gross evidence of insect-damaged kernels, evidence of plugging, or "pink wheat" contamination, determine any movement of the car or other disposition of the grain and notify your supervisor immediately.
  5. Preparation of Sample for Laboratory Analysis. If a sample can be delivered to the laboratory promptly and confirmatory analysis handled expeditiously, freezing of the FDA subsamples is not necessary. The claimant's (702(b)) portion of the sample, however, must be frozen. It is preferable to freeze the subsamples in paper bags. If a freezer is not available, the subsamples (in paper bags) can be placed in a cooler box with dry ice. Do not use glass jars with dry ice. Officially seal all subsamples. If dry ice is used, you must label the shipping container as described in IOM See Exhibit 4-19. Indicate frozen storage on the FDA 525.

D. Special Reporting
Submit an Analyst Worksheet (FDA-431) for each sample analyzed and found in compliance. See IOM If field examination shows the sample is possibly actionable, report analytical results in Remarks Section of the C/R.

If uneven loading, layering or "plugging" is suspected, contact your supervisor as to whether to sample or not. A 'plugged" car is a railcar, truck, or barge load of grain where the contamination is suspected of being in only one portion or layer of grain. Plugging is usually the deliberate mixing of violative grain below the surface or in isolated pockets of grain.

A. Equipment
Equipment needed is the same as in 1.A. above except:

  1. Double tube grain probe must have individual compartments permanently separated.
  2. Small containers of sufficient size to hold the contents of each compartment of each grain probe.

B. Procedure

  1. In the Remarks Section of the C/R, draw a diagram showing actual "plugging" pattern suspected.
  2. Each sample consists of thirty probes of grain with each probe compartment maintained as a separate sub. Each sample thus consists of 300-330 subs depending on whether a 10 or 11 compartment probe is used and if grain depth is sufficient to insert the probe to fully cover all compartments of the probe.
  3. Probe each load and number the probes as follows:
    1 4 7 10 13 16 19 22 25 28
    2 5 8 11 14 17 20 23 26 29
    3 6 9 12 15 18 21 24 27 30
  4. Identify the subs by probe number plus compartment letter starting with small "a" as the compartment nearest the tip of the probe.


    Sample Schedule 4 Two Probes

  5. Submit sample to your district's servicing laboratory. See IOM


Page Last Updated: 07/28/2015
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