October 2, 2007 – AAGIWA member letter on stowage examinations

TO: AAGIWA Members

SUBJECT: Stowage Examinations

Safety issues related to performing prior-to-loading stowage examinations of rail cars is a continuing concern to many AAGIWA members. There are several FGIS directives or notices that apply to stowage examinations with which you should be familiar.

FGIS Program Notice 06-07, “Conditional Dismissal of Mandatory and Service-on-Request Stowage Examination of Land Carriers and Domestic Barges,” outlines the procedure to follow in dismissing stowage examinations when hazardous conditions are present. As part of an official agency’s management practices, you may wish to include in your safety handbook a definition of “hazardous conditions” that would be applicable when dismissing stowage examinations. Those hazardous conditions could include such factors as lack of adequate lighting (after dark) and inclement weather (wind, rain, snow, ice, etc.). In other words, if you feel there are unsafe conditions present, you may decline to provide stowage examinations. Be sure to appropriately document such steps and to include the following statement on the inspection certificate: “Stowage area not examined.”

In case it is helpful, attached are two examples of the format used by official agencies to document instances of dismissal or withheld services. These examples are provided courtesy of Sioux City Inspection Services and the Champaign-Danville Grain Inspection Service.

If you have further, general concerns about performing stowage examinations, you should visit with your inspection customers to inform them of the safety issues. FGIS Directive 9180.48 prescribes the conditions under which an official agency may waive the stowage examination requirements. That Directive essentially requires that the shipper and receiver of the grain shipment must both agree to waive the stowage examination, that these steps must be documented, and that the appropriate language is included on the inspection certificate.

In addition, customers may not always be aware that they can streamline the loading process for shuttle trains if stowage examinations are not performed. Thus, having a waiver in place can allow the shipper to begin loading more expeditiously.

In closing, one of AAGIWA’s goals is to be helpful and supportive of its members in addressing common issues and problems. We welcome your comments and suggestions.

Sincerely,

Larry Kitchen
President

(314) 540-6217
Larry_Kitchen@sbcglobal.net

20610 NE 157th Street
Kearney, MO 64060

AAGIWA is the national association representing official grain inspection agencies. Comments or questions on this report may be directed to Bob Petersen at bob.petersen@aagiwa.org or by calling (816) 628-1287.