Form

Grain standard operating protocol (GSOP)

Updated 21 September 2022

This grain standard operating protocol (GSOP) explains the arrangements for the issue of phytosanitary (plant health) certificates for export of bulk grain from England and Wales to non-EU countries (outside Great Britain) requiring certification, including the procedures for sampling and inspection of grain by authorised trade inspectors (ATI).

Please read this protocol and the notes on the application for certification of consignments of grain for export form (HH93) very carefully.

If you are unclear on any points please do not hesitate to seek advice from the Animal and Plant Health Agency (APHA):

Animal and Plant Health Agency
Foss House – CIT
1st Floor, Kings Pool
1-2 Peasholme Green
York
YO1 7PX
Telephone: 0300 1000 313
Email: PHASTPlantProducts@apha.gov.uk

Read annex 5 for specific guidance about exports from Scotland.

General information

This document sets out the arrangements for the sampling, inspection, and phytosanitary certification of grain for export to non-EU countries requiring such certification. It does not cover any matters other than those relating to plant health (for example human or animal health matters).

The plant health requirements of third countries are laid down by the relevant authorities in each country and vary from country to country. Phytosanitary certificates provide an assurance that consignments of plants and plant products (including grain) meet the required plant health standards of the importing country, in addition to conforming to the International Standards for Phytosanitary Measures (ISPM 12). Phytosanitary certificates are issued by APHA for England and Wales.

Under EU regulations phytosanitary certificates are not required for movements of grain grown in the UK into EU member states.

A list of the countries that require phytosanitary certificates for grain exports is given at annex 1, although this is not exhaustive. Annex 2 and 3 contain further details of additional requirements. Exporters should contact APHA for further information or details on the requirements of countries other than those listed, giving as much notice as possible (at least 5 working days) prior to the date of export.

Details of the relevant import regulations may not be available immediately as APHA may have to contact the plant health authorities in the countries concerned to obtain the required information. If exporters have up-to-date information this should be provided in advance of the export to APHA.

APHA may, on plant health grounds, refuse any application for a phytosanitary certificate. A certificate will not be issued if APHA has reason to believe that any information supplied by the applicant or an authorised trade inspector is incorrect or inaccurate, or that any conditions prescribed relating to the treatment or movement of material intended for export have not been met. APHA may also require an exporter to produce any relevant information in connection with any grain for export.

A trade inspector must attend and pass the GSOP training course to become an authorised trade inspector in respect to the official delegation of the phytosanitary inspection of grain. APHA is the sole and only recognised provider of GSOP training, for which there is no charge. Further details of GSOP training courses can be obtained from APHA. Authorised trade inspectors are required to re-attend and pass the GSOP training course every 5 years in order to retain their authorisation and must keep APHA informed of any changes to their employer or personal contact details.

It is the responsibility of the exporter to ensure that storage facilities and the holds of ships are free from infestation before loading and that, following inspection, they will remain free from infestation. If infestation is subsequently discovered or considered likely to be present, the matter must be reported to APHA. No phytosanitary certificate will be issued for this grain until disinfestation arrangements have been carried out in accordance with the procedures agreed between Grain and Feed Trade Association (Gafta) and APHA as detailed at annex 4.

Authorised trade inspectors will undertake the delegated inspection duties for official phytosanitary certification of grain on behalf of APHA. All matters relating to the employment of these trade inspectors (including those concerning health and safety) shall remain the responsibility of those organisations within the grain trade by whom they are employed. APHA shall not be liable in respect of any loss, damage, injury, or death arising as a result of any act or omission, whether negligent or otherwise, of a trade inspector. It is the responsibility of the trade to ensure that sufficient resources and appropriate facilities and equipment are provided, and that the application of any chemical treatment is carried out in accordance with current pesticide legislation and importers’ requirements.

No liability shall attach to APHA in respect of any loss or damage arising as a result of the issue or contents of any certificate, any delay in granting or failure to grant a certificate, or delay or non-delivery of any documents, whether negligent or otherwise. No guarantee is given by APHA that any certificate granted will comply with the requirements of any other country or importer.

Grain exports from Scotland

The sampling, inspection and disinfestation procedures detailed in this protocol also apply for grain exports from Scotland. But applications should be made to the Scottish Government Rural Payments and Inspections Directorate, not APHA.

Read annex 5 for specific guidance for grain exports from Scotland.

Data protection

Your privacy is important to us and protected in law through the General Data Protection Regulation (GDPR), and the Data Protection Act 2018 (DPA 2018).

For information on how we handle personal data please read the APHA personal information charter.

Complaints

If you have concerns or specific complaints about the way APHA operates, or the services we provide, please refer to the APHA complaints procedure.

Application procedures

Exporters requiring phytosanitary certificates for consignments of grain for export should in the first instance, either themselves or through a representative, notify APHA of the intended export by submitting a copy of the application form (HH93) with sections I, II and III completed and signed as soon as possible. Exporters or their agents are requested to give as much notice as possible of intended loading.

Under normal circumstances a period of at least 5 working days’ notice is required. Where exporters are unable to give at least 5 working days’ notice due to freight constraints (for example where the means of transport becomes available for chartering less than 5 days before the intended date of loading), exporters or their agents are requested to contact APHA at the earliest opportunity.

Exporters must also ensure that the cargo superintendents and silo operators employed to handle their grain at the ports are notified as soon as possible of the need for sampling and inspection of their grain by authorised trade inspectors.

APHA must be informed of any special conditions of entry, for example any import permit requirements, relating to the examination and certification of the consignment. Where an import permit has been issued by the relevant authorities in the country to which grain is being exported a copy should be forwarded to APHA with the application form.

In some circumstances, depending on the requirements of the importing country, it may be necessary for samples to be examined by an official laboratory. Details are provided in the sampling and inspection section and annex 1.

Annex 1 contains details of the countries that require phytosanitary certificates for grain exports, although this is not exhaustive, and specifies additional examinations that may be required. As noted, import permits may specify additional requirements.

When a sample is submitted to an official laboratory it must be accompanied by a copy of the HH93 application form with Section IVA completed and a completed sample submission form for the relevant laboratory.

Download a sample submission form for:

• The Food and Environment Research Agency (FERA)
• Official Seed Testing Station (OSTS)

Following sampling and examination of consignments for grain insect pests by authorised trade inspectors and, where relevant, the dispatch of samples to the appropriate laboratory, an application should be made to APHA for the issue of an official phytosanitary certificate by sending a further copy of the HH93 submitted earlier with Section IVA and IVB also completed.

A phytosanitary certificate can only be issued following submission of a fully completed application form (HH93) by an authorised trade inspector, including the following where appropriate:

• if the importing country requires additional testing, the report from the official laboratory detailing relevant pest, disease, or weed freedom must also be supplied
• if chemical treatment has been applied, a certificate of disinfestation must also be supplied

Some countries may also require a certificate of free sale - a declaration that the grain is free from harmful levels of radioactive material and is fit for human consumption. These are available from the Rural Payments Agency:

Rural Payments Agency
Telephone: 03300 416500
Email: trader@rpa.gov.uk

Charges

Fees will be charged for the certification of consignments.

Read about fees in England and Wales.

Where it is necessary for a sample to be examined by Fera or the OSTS, a separate charge will be made by the laboratories for this service. Contact the relevant laboratory for details:

Fera
Telephone: 01904 462324
Email: plantclinic@fera.co.uk

OSTS
Telephone: 01223 342243
Email: labtest@niab.com

Sampling and inspection procedures

Sampling and examination of grain for export will be undertaken by authorised trade inspectors.

Reliance will be placed on judgement exercised by ATI who must take into account all relevant factors relating to the quality and condition of grain on a case-by-case basis. Their reports will be largely responsible for determining whether a phytosanitary certificate can be issued by APHA.

It is essential that authorised trade inspectors keep a record of grain inspected. These records must be maintained for at least 12 months and made available to APHA upon request.

There are 3 options for sampling consignments of bulk grain for export:

• consignments loaded directly from lorry to ship
• consignments loaded from lorry to silo or store
• consignments loaded from silo or store to ship

Sampling consignments loaded directly from lorry to ship

Samples of grain must be drawn from all lorries before grain is loaded direct to ship. At least 3kg of grain must be collected from each lorry. Manual samples must be collected from at least 3 separate points at different depths within the load. Where an automatic core sampler is being used the sample can be drawn from a single point.

Sampling consignments loaded from lorry to silo or store

Samples of grain must be drawn from all lorries before grain is loaded to silo or store. At least 3kg of grain must be collected from each lorry. Manual samples must be collected from at least 3 separate points at different depths within the load. Where an automatic core sampler is being used the sample can be drawn from a single point.

This grain is eligible for export without further sampling provided that the silo or store into which it is loaded is free from infestation and the inspected grain will not thereby become infested. If infestation is discovered in the silo or store, phytosanitary certificates will not be issued until the store is treated following the steps in annex 4.

Sampling consignments loaded from silo or store to ship

In cases where grain has not been sampled by an authorised trade inspector before loading to silo or store a phytosanitary certificate will only be issued following subsequent sampling before or during loading from silo to ship.

Where consignments are sampled during loading, a 3kg sample should be collected from the stream every 10 minutes. Where consignments are sampled as static loads in store the following sampling rates should be applied:

• for silos or stores containing less than 100 tonnes a 3kg sample must be taken for each 30 tonnes of grain
• for silos or stores containing more than 100 tonnes a 1kg sample must be taken for every 30 tonnes of grain

In all cases the sample taken should be as representative of the whole of the grain as possible, for example they should be collected at different depths and separate points in the silos or stores.

Collection of grain from moving equipment can be hazardous. It is for the trade to ensure that suitable, safe arrangements are made for the collection of grain. It is for authorised trade inspectors and their employers to ensure compliance with all relevant health and safety legislation.

Examination of samples for grain insect pests

Samples of grain for phytosanitary purposes must be examined by an authorised trade inspector for the presence of grain insect pests detailed at annex 2.

Detection and identification of low levels of infestation in samples of grain can only be performed successfully under suitable working conditions and using the appropriate equipment. All samples should be examined in a well-lit, suitably warm area near to the sampling point.

Insects should be separated from grain using a sieve with a 2.0 to 2.5mm screen or mesh. Sieves should not be overloaded and should be well shaken to dislodge any grain insect pests. The results of sieving must be examined carefully in good light, either directly in the receiver, or tipped onto a white tray. In cold conditions the detection of live pests will be easier if the tray is warm. A x10 lens should be used for the identification of insects.

If, on inspection, no grain insect pests are found the grain can be considered free from infestation.

If live grain insect pests are found the grain consignment must either be rejected or chemically disinfested by a professional treatment company as set out in annex 4.

If only dead grain insect pests are found the sampling and inspection procedure outlined above should be repeated. Provided no live grain insect pests are found in this further examination the grain can be considered free from infestation.

In the case of mites, where appropriate, authorised trade inspectors will exercise judgement on whether the quality is acceptable.

Additional samples required for official laboratories

Where additional testing is specified in the table in annex 1, a 1kg representative sample should be sent to the relevant official laboratory. The representative sample should be drawn from the larger composite obtained throughout the sampling process as detailed above – guidance on this process is provided on the GSOP training course.

For examinations to detect the presence of prohibited pests and diseases:

Phytosanitary and Export Testing Lab
Fera Science Ltd
York Biotech Campus
Sand Hutton
York
YO41 1LZ
Telephone: 01904 462324
Email: plantclinic@fera.co.uk

For examinations to detect the presence of prohibited weed seeds and parasitic plants:

Official Seed Testing Station (OSTS)
NIAB Labtest
1 NIAB Park Farm
Impington
Cambridge
CB24 9NZ
Telephone: 01223 342243
Email: labtest@niab.com

Where a test for Orobanche is required, an additional 1kg sample should be sent in a paper or foil bag to OSTS.

Disinfestation by chemicals: residual insecticide treatment and fumigation

If chemical treatment has been applied to a consignment this should be recorded in Section IVA of the HH93 application form and a certificate of disinfestation issued by the professional treatment company attached. These details will be included on the phytosanitary certificate.

The certificate must include:

• tonnage treated
• location of treatment
• commodity
• shipper
• country of destination
• details of any pests present
• treatment
• chemical active ingredient
• concentration
• date of treatment
• duration and temperature
• signature

Guidelines on the treatment processes that would be expected to achieve effective disinfestation of grain are given at annex 4.

Annex 1: Countries requiring phytosanitary certificates for grain imports

The table below contains details of countries that have most commonly received exports of grain from the UK. All these countries require a phytosanitary certificate. Additionally, the table details whether an import permit or testing of a representative sample are required.

The details of phytosanitary requirements provided below apply to grain grown in the UK only. Grain originating outside the UK may require additional testing and certification or be prohibited by the importing country.

China

China does list prohibited pests and diseases, some of which do not occur in the UK, and some that are considered to be predominately soil-borne.  Therefore, a 1% soil tolerance is applied to the sample submitted to OSTS for prohibited weed and parasitic plant testing and no sample is submitted to Fera. If the soil content of the sample is 1% or below the consignment will be considered to have met the pest and disease requirements for export to China. If soil exceeding 1% is found in the sample the consignment will fail for export to China.

For exports to China there is a requirement that exporters are registered with Defra. The requirement for this is that exporters are approved under the Gafta Trade Assurance Scheme (GTAS) and/or the Trade Assurance Scheme for Combinable Crops (TASCC) quality assurance schemes. For more information, contact Gafta:

The Grain and Feed Trade Association
9 Lincoln’s Inn Fields
London
WC2A 3BP
Telephone: +44 20 7814 9666
Email: post@gafta.com

Countries not listed

For further information or details on the requirements of countries other than those listed, exporters should contact APHA.

Whilst every effort is made to ensure that information on importing countries’ plant health regulations is accurate at the time of publication, they are not a definitive statement of law and may have been subject to change.

Details of countries requiring import permits, phytosanitary certificates and/or additional testing

Country of destination	Import permit required?	Phytosanitary certificate required?	Testing required for prohibited plant pests and diseases?	Testing required for prohibited weeds and parasitic plants?	Orobanche testing required?
Algeria	Yes	Yes	Yes	Yes	Yes
Bangladesh	Yes	Yes	Yes	Yes	Yes
Cameroon	Yes	Yes	No	No	No
China (barley)	Yes	Yes	No Find out more about prohibited pests and diseases in China	Yes	No
China (excl. barley)	Yes	Yes	Yes	Yes	Yes
Ghana	Yes	Yes	No	Yes	No
Israel	Yes	Yes	Yes	No	Yes
Japan	No	Yes	No	Yes	Yes
Mauritania	Yes	Yes	Yes	Yes	No
Mexico	Yes	Yes	No	Yes	Yes
Morocco	No	Yes	No	No	No
Nigeria	Yes	Yes	Yes	No	No
Russia	No	Yes	No	Yes	No
Saudi Arabia	Yes	Yes	No	No	No
Suriname	Yes	Yes	No	No	No
Syria	Yes	Yes	Yes	Yes	Yes
Taiwan	Yes	Yes	No	Yes	Yes
Thailand	No	Yes	No	Yes	Yes
Tunisia	No	Yes	No	Yes	Yes
Turkey	No	Yes	Yes	Yes	Yes
United Arab Emirates (UAE)	Yes	Yes	No	No	No
United States of America (USA)	Yes	Yes	No	Yes	Yes

Annex 2: Grain insect pests for which inspections must be undertaken for all countries requiring phytosanitary certificates

If you’re an authorised trade inspector, you can certify the consignment of grain as free from the following:

Beetles

• Ahasverus advena - foreign grain beetle
• Cryptolestes spp - flat grain beetle
• Oryzaephilus spp - saw toothed/merchant grain beetles
• Rhyzopertha dominica - lesser grain beetle
• Sitophilus granarius - grain weevil
• Sitophilus oryzae/zeamais - rice/maize weevil
• Tribolium spp - flour beetles
• Trogoderma spp – for example khapra beetles

Moths

Stored product moths are difficult to identify as adult moths are unlikely to be found alive in grain. On the very rare occasions when moth larvae are found, they need to be considered further only if the cargo is destined for countries that list moth species in annex 3.

Annex 3: countries requiring examination of representative samples for freedom from prohibited weed seeds and/or parasitic plants (including Orobanche species) and fungal diseases

Identification of the relevant weed seeds, parasitic plants or fungal diseases listed in annex 3 in a consignment would probably mean that a phytosanitary certificate could not be issued.

Check annex 3 for the country you are exporting grain to.

Annex 4: Disinfestation by chemical - residual insecticide treatment and fumigation

This annex describes the processes, which if applied rigorously by professional treatment companies, would be expected to achieve effective disinfestation of grain for export.

For the purposes of this protocol, a professional treatment company is a company that is in the business of disinfecting grain by application of residual insecticide and/or by fumigation, and who are certified under a recognised Trade Assurance Scheme (for example the Gafta Approved Fumigator or equivalent) and/or hold current membership of the British Pest Control Association or equivalent association specifically relevant for these activities.

Subject to the continued approval of the substances in question for the purposes described, APHA will accept certificates of treatment completed by professional treatment companies as evidence that such treatments have been undertaken and are expected to be effective under the particular circumstances.

It remains the responsibility of treatment companies to ensure that the substances they use continue to be permitted for the purposes under the Control of Pesticides legislation and that all other relevant legislation, including health and safety measures, are observed. The pesticide product label must be consulted and all applications must be made in accordance with the statutory conditions of approval of the pesticide. It remains the responsibility of the exporter to ensure that any treatments meet any specific requirements of importing countries.

Residual insecticide treatment

The temperature of the grain during loading and length of time between loading and discharge will have an effect on the efficacy of the treatment applied. Correct application of a UK approved pesticide undertaken by professional treatment companies within the conditions of approval and taking into account the following temperature and time provisions will normally be accepted for the purposes of phytosanitary certification of the grain.

Grain temperature	Length of time between treatment of infested grain and discharge
10°C and above	5 days or more
7.5°C to less than 10°C	8 days or more
5°C to less than 7.5°C	10 days or more

At less than 5°C treatment will be effective in certain specific situations.

Fumigation

Fumigation with phosphine in ships’ holds undertaken rigorously by professional treatment companies within the conditions of approval and taking into account, as appropriate, the following data, will normally be accepted for the purposes of phytosanitary certification of the grain.

Fumigant

Aluminium phosphide (AlP) or Magnesium phosphide (MgP), based on products currently approved for use in the UK.

Probe system

Aluminium phosphide probed into the cargo to a minimum depth of 1.5 metres. Either by means of tablet or pellet directly into the cargo, or with the aluminium phosphide contained within retrievable sleeves, packages or sachets.

It is not acceptable to bury the aluminium phosphide on or near the surface of the cargo, it must be probed in as set out above.

Temperature	Time (days)	Fumigant	Rate
10°C and above	12 or more (16 days or more if Sitophilus species present)	AIP	1.75g
15°C and above	10 or more	AIP	1.75g
20°C and above	7 or more	AIP	1.75g
20°C and above	5 or 6	AIP	2.5g
Less than 10°C	Ineffective	Ineffective	Ineffective

Time is the length of time between treatment of infested grain and discharge.

Rate is the amount of phosphine required per m3 of hold volume.

Phosphine generating formulations release 1g of PH3 per 3g of formulated product.

Re-circulation system

Powered fan linked to fumigation ducts at the bottom of each hold. Re-circulation of the fumigant, which may be placed on or near the surface or probed into the cargo, is then carried out continuously.

Temperature	Time (days)	Fumigant	Rate
5°C and above	12 or more (21 days or more if Sitophilus species present)	MgP	1.5g
10°C and above	10 or more	MgP/AIP	1.25g
15°C and above	8 or more	MgP/AIP	1.25g
20°C and above	5 or more	MgP/AIP	1.25g
Less than 5°C	Refer to Fera	Refer to Fera	Refer to Fera

Time is the length of time between treatment of infested grain and discharge.

Rate is the amount of phosphine required per m3 of hold volume.

Phosphine generating formulations release 1g of PH3 per 3g of formulated product.

Review of procedures and substances

The guidelines above will be reviewed periodically. It is important to emphasise, however, the information contained in this annex must not be taken as a definitive statement of pesticides legislation.

It is for those companies which undertake chemical treatments or fumigation to ensure that they comply fully with all relevant pesticide legislation, including the Food and Environment Protection Act 1985, the Control of Pesticides Regulations 1986 as amended by the Control of Pesticides (Amendment) Regulations 1997, the Plant Protection Products Regulations 1995 as amended and the Plant Protection Products (Basic Conditions) Regulations 1997. There may also be health and safety requirements including, where appropriate, the requirements of the UK Merchant Shipping (Carriage and Cargoes) Regulations 1997 as they relate to the use of pesticides in ships.

Companies should also note that pesticide approvals, once granted, are themselves subject to review and change.

If in doubt companies should seek guidance from:

Health and Safety Executive – Chemicals Regulation Directorate – Pesticides
Mallard House
Kings Pool
3 Peasholme Green
York
YO1 7PX
Telephone: 0300 003 1747
Email: CRD.Information.Management@hse.gov.uk

or

The Health and Safety Executive
Biocides and Pesticides Assessment Unit
Magdelene House
Stanley Precinct
Bootle
Merseyside
L20 2QZ
Telephone: (01519) 513219
Email: biocidesenquiries@hse.gov.uk for biocidal products (generally non-agricultural pesticides)

Annex 5: Grain exports from Scotland

For grain exports from Scotland contact your local Rural Payments and Inspections Directorate (RPID) Agricultural Officer.

Find the addresses of RPID offices on the Scottish Government website.

General information

The procedures detailed in this protocol also apply for grain exports from Scotland.

Application procedures

The application procedures detailed in this protocol also apply for grain exports from Scotland. However, applications should be made to your local Scottish Government Rural Payments and Inspections Directorate and not APHA.

Charging

Fees will be charged for the certification of consignments (for fees in Scotland please contact the Scottish government) and a separate fee may be charged for any sampling or testing carried out by OSTS.

Sampling and inspection procedures

The sampling and inspection procedures detailed in this protocol also apply for grain exports from Scotland. However, in Scotland all samples should be submitted to:

Official Seed Testing Station (OSTS)
Science and Advice for Scottish Agriculture (SASA)
1 Roddinglaw Road
Edinburgh
EH12 9FJ
Telephone: (0131) 2448900
Fax: (0131) 2448971
Email: osts@sasa.gsi.gov.uk

Contact SASA for disinfestation advice for grain consignments being loaded in Scotland.