Standards for Triploid Grass Carp Inspectors
Revised vice Memorandum of Agreement 2010, Amended August 2010
- The USFWS Inspector, before confirmation of an inspection date, will ask the producer whether the conditions, as specified in the “Checklist for Scheduling an Inspection (38 KB)” (i.e., available diploid controls, working Coulter Counter, etc.) will be met.
- The USFWS Inspector will provide inspection services for a minimum of 1500 fish to be shipped, within six calendar days, from isolated lots of fish being maintained within a containment unit, or units (tank/vat/etc.). Inspection requests for groups of fish of less than 1500 will only be performed when agreed upon, in advance, by the USFWS Inspector.
- The USFWS Inspector will observe the quantity and condition of the group of alleged 100% individually producer tested triploid fish that is to be certified before every ploidy verification inspection. Inspectors will verify that producer tested triploid grass carp and certified grass carp are maintained in labeled isolated containment tanks at least 100 feet away from grass carp production ponds and six feet from labeled diploid/ untested holding tanks thus reducing the chance of inadvertent mixing of triploids and diploids.
- The USFWS Inspector will visually estimate/confirm the numbers of fish reported to be in each tank. Containment units must be provisioned with water that is clear enough to allow the USFWS Inspector to visually estimating fish numbers. In addition, the USFWS Inspector will confirm the absence of other vertebrate species whose presence would indicate potential adulteration of screened fish. In the event the water in the holding tanks is not clear enough due to a unique weather event or temporary equipment malfunction, the inspector will offer to work with the producer to find an acceptable alternative method of determining the number and quality of fish in the containment unit.
- The USFWS Inspector will establish that the producer’s particle sizer is operational and can differentiate between diploid control samples and triploid samples prior to conducting every ploidy verification inspection. A fully operational particle sizer shall be defined as one where the modal peak for triploid screened fish is at least one channel to the right of a 2.8 micron bead modal peak.
- The inspector will supervise the collection and analysis of blood samples from diploid controls to ensure that the particle sizer is working properly. In the event diploid controls are not available, 2.8 micron polystyrene beads can be used to verify the testing equipment. The inspector may run additional controls until he/she is satisfied that the particle sizer is in good working order.
- The inspector will request the completed “Verification Checklist for Triploid Grass Carp Inspections (97 KB)“, with locations of fish to be sampled for the inspection. The inspector will supervise and observe the random collection of the 120 fish from the identified lots of alleged 100% individually producer tested triploid grass carp. The inspector will check a representative sub sample of fish for visible evidence of screening (poke mark on isthmus).
- If fish to be certified are sufficiently different in size, care must be exercised to ensure that diploid controls represent the fish to be certified. The inspector will not inspect samples of 120 fish preselected by the producer prior to arrival of the inspector.
- The inspector will supervise the collection and analysis of blood samples from all 120 randomly selected fish to be tested on the producer’s particle sizer. The Inspector will channelize every sample and record (at a minimum) every tenth fish during the testing of the 120-fish sample of alleged 100% tested triploid grass carp reported on the “Verification Checklist for Triploid Grass Carp Inspections.”
- If the Inspector finds a blood sample with a questionable reading when it is channelized the producer will follow the facility protocol for screening a suspect sample under the direction of the inspector. At the minimum, the protocol will contain the following elements:
- Pour original sample into a new, clean cuvette and retest up to two times. If okay continue with inspection.
- When suspect sample is present, the producer will stop testing without communicating the location of suspect fish to the blood collection personnel.
- Inspector will note the location of suspect fish and retrieve all suspect fish in a containment unit (i.e. two fish in a net) and return to the sample stand.
- Collect a new blood sample in a new, clean, cuvette(s) from all fish in the suspect group up to two times.
- Test samples and make determination of ploidy of new blood samples.
- If the inspector observes any non-triploid fish during testing the inspection will fail. This is a type (A failure) (a diploid is found during testing of the 120 fish sample). The inspection process is stopped and the lot cannot be certified. All fish in this lot must be individually retested, by the producer, before another date and time can be scheduled for inspection. A letter of warning/concern will be issued by the inspector or supervisor via US Postal Service within 3 business days. The producer will address the letter and identify the course of action that will be taken to correct the problem via return letter to the USFWS.
- In the event of a type B, C or D failure, the standard for which the producer was out of compliance must be corrected prior to scheduling another inspection. The inspector must indicate in writing using the standardized letter addressing the standard(s) resulting in the failure so that the producer can correct the problem. The producer will identify the course of action that will be taken to correct the problem via return letter to the USFWS.
- A lot is defined as the number of fish recently individually screened by the producer to remove non triploid fish and held in isolation that may potentially be shipped within six calendar days. The inspector will determine the number of fish permitted to be certified and sold in this lot from the producer’s certificate request at the time of inspection. The inspector records the total number of fish on the “Verification Checklist for Triploid Grass Carp Inspections.” An arbitrary maximum number of 6,000 fish per lot is being assigned until empirical data on actual diploid incidence rates in failed lots can be reviewed and a more accurate statistical model applied to establish higher or lower lot sizes based on the 120 fish sampling protocol. Multiple inspections can be performed in a day to accommodate larger orders greater than 6,000 fish. Larger groups of fish will be segregated into multiple lots with a maximum of 6,000 fish per lot. The lots will be inspected and certified independently.
- The certified lot of fish derived from the inspection is held in isolation. Certificates may be issued by the inspector for up to 6 calendar days on fish sold from the certified lot. If any fish are added to the certified lot after the certification inspection the remaining fish from the inspected lot are null and void. All fish in the respective lot must pass re-inspection before they can be certified and sold. If the inspector receives a request for additional certificates he/she will maintain a copy of the “Verification Checklist for Triploid Grass Carp Inspections (97 KB)” to ensure certificates are not issued for more than the number of fish in the lot. Certificates issued will be documented on the “Verification Checklist for Triploid Grass Carp Inspections” and will be cross referenced with the Producer’s “Verification Checklist for Triploid Grass Carp Inspections“ at the next inspection.
- Any fish from the certified lot not sold within six calendar days of inspection must be re-certified before new certificates can be issued for sale and shipment. Unsold fish from the previous certified lot(s) may be submitted for re-certification with alleged 100% individually producer tested triploid fish to form a new lot for USFWS inspection.
- Additional certificates associated with a certified lot can be provided for subsequent sales at the discretion of the local inspector after the inspector leaves the producer’s site on the day of the inspection. Upon agreement of this request the inspector will inform the producer of their options for delivery of the certificates at a mutually acceptable time. This can be accomplished in three ways depending on the urgency of the request by (1) sent by regular mail, (2) sent via courier service using the producer’s account number, or (3) picked up by the producer at a location convenient for the inspector. Certificate(s) will be sent on the day requested provided the request is made during business hours and before the deadline for pickup of the courier. Certificates can be issued by another USFWS Inspector at the request of original Inspector.
- Officials, in States where fish are scheduled for delivery, will be notified by faxing/emailing certificates within 24 hours. Information to be communicated will be the number of fish involved in a shipment, the source of the fish, the destination, estimated date/time of arrival, and the name of the dealer or hauler of the fish.
- The inspector will not falsify any certificates or documents. USFWS Inspector will provide the original embossed Certificate(s) to the producer for shipment with the fish. Copies of the signed Inspection/Certification will be made and distributed as follows:
- USFWS Triploid Inspector (day of inspection)
- State Agencies requiring official written notification (copy by USFWS)
- USFWS Regional Accounting Office for grass carp work (optional)
- Each USFWS Triploid Grass Carp Inspection Office will reserve 1-day each week (generally Tuesday or Wednesday) for administrative duties, vehicle maintenance, and other required activities.
- The USFWS Inspector will collect the appropriate fee-for-service, via one check, from the Producer prior to departure from the Inspection site or by other agreed terms. Effective January 1, 2012, the fee structure requires the Inspector to collect thirty-six cents ($.36) per certified triploid grass carp shipped. The costs for Inspections occurring outside the local USFWS region will be the responsibility of the requesting USFWS region. Costs outside the region will include the regular inspection fee+ travel costs (Travel costs include mileage round trip to the site (28.5 cents/mile), airfare, lodging, per diem, and miscellaneous expenses incurred at the standard government rate. The National Program will cover travel costs associated with training to establishing a new program in the region until they are reimbursed by the newly established Regional Triploid Grass Carp Inspection and Certification Program.
- The USFWS will provide quality control assurances for the Grass Carp Inspection and Certification Program to include employee training, record archiving, maintenance of a Triploid Grass Carp Inspection and Certification Program database, and maintain a file on state grass carp regulations.