Steve D Wirsching - Comment on FR Doc # 2010-17529

Please find the attached comments from US Wheat Associates. US Wheat would like to urge GISPA to extend the exemption on grain inspection for one more year, while FGIS agency reviews the quality assurance options for rail shipments to Mexico and the impact of this rule change on overseas container shipments. USW proposed the following revisions to the grain standards (in Blue) in February, 2010. Please consider our comments when making a final ruling on the proposed changes for the “High Quality Special Grain” waiver, which USW is unable to support at this time. Rail Shipments: Quality assurance on U.S. rail shipments to Mexico continues to be a significant concern to many Mexican millers. Notably, rail and truck exports to Canada and Mexico are exempt from official/FGIS export inspection requirements. While some rail shipments to Mexico are officially/FGIS sampled and graded, most are not. Many shipments are unofficially graded by FGIS based upon submitted samples from the shipper. In this case the words “submitted sample” are displayed on the face of the FGIS certificate. Some shipments provide only private/unofficial quality assurance documents. Mexican millers continue to suggest that a standardized approach needs to be developed to better and more consistently assure the quality of wheat being shipped to Mexico. USW recommends that FGIS undertake a review of all forms of quality assurance being provided on rail wheat shipments going to Mexico and report those findings to the wheat industry. USW further recommends that based on the findings of that review that FGIS recommend one or more options to the wheat industry for providing better and more consistent quality assurance on rail wheat shipments to Mexico. Container Shipments: Quality assurance on containerized wheat exports is a mixed bag. With the exception of rail or truck exports to Canada and Mexico, all U.S. wheat exports must be officially weighed and inspec