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Situation:
Narration: You are a veterinary medical officer working in the VS office in Virginia on October 31, 2011. Your name is Dr. John Doe.
An exporter has presented you a VS Form 16-4 on your screen along with an affidavit. The 16-4 is for dry dog food intended for export to Bobania. You advise the exporter that it is her responsibility to be sure that the certificate that is endorsed meets all the requirements of Bobania.
There is no information on the IREGS regarding the export of pet food to Bobania. APHIS has not inspected the facility, and no documentation other than a notarized affidavit is available. The exporter says she needs the certificate today, so you agree to review the certificate with the understanding that you will not be able to inspect the facility before endorsement. This means for the certificate to be endorsable today, it must be endorsable without any facility inspection.
Let's first focus on the VS Form 16-4 the exporter presented. You can examine the magnified 16-4 using the scroll bars to view its content more closely. Or, you can also select the PDF icon below the form to view it in PDF format.
The following Knowledge Review is a multiple choice question. Only one answer is correct; select the best answer and feedback will immediately appear.
You notice an issue with the "NAME AND ADDRESS OF THE EXPORTER" section of the exporter's 16-4. What is the problem?
The answer is D.
The location of the exporter is an issue. Your office is in Virginia, and because the material is being exported from Texas, you need to confirm that the shipment is related to your state in some way.
Narration: As you review the exporter's VS Form 16-4, you notice a problem with the information the exporter provided in the Name and Address section of the form. What is the problem?
The following Knowledge Review is a multiple choice question. Only one answer is correct; select the best answer and feedback will immediately appear.
You notice that the affidavit line that appears on the exporter's VS Form 16-4 is worded incorrectly: "This office has on file a notarized affidavit verifying the following information." What is the proper affidavit line the exporter should have used in this particular scenario?
The answer is A.
The affidavit line should say, "This office has on file a notarized affidavit from Jimmy Joe's Pet Delights verifying the accuracy of the statements below."
Narration: You know from discussion with the exporter that they are the manufacturer of the pet food to be exported. Looking again at the 16-4, you focus on the statement that says, "This office has on file a notarized affidavit verifying the following information." You notice that this particular affidavit line is worded incorrectly. What is the proper affidavit line in this situation?
Narration: Here is the exporter's 16-4 with the correct affidavit line. The statement has been corrected to include the name of the exporting company who is also the manufacturer of the pet food.
Notice, however, that the name and address of the exporter has not been altered. The exporter confirmed that, while the material is being shipped from their factory in Texas, their corporate headquarters are in Richmond, VA. Therefore, the information is acceptable.
There are several problems with the statement, "Certified materials are free of dioxins, and have radioactivity levels consistent with international standards."
Which of the following might be included in what you tell the exporter?
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The answers are A, B, C, and D.
The exporter should have their importer confirm what is really required by the government of the importing country. APHIS cannot endorse statements related to dioxins and radioactivity. Any exceptions would be noted on the IREGS, and we have established that there is no entry on the IREGS for the export to pet food to Bobania. If the statement is being required by the importing country, the FDA would be the competent authority to address the issue. APHIS cannot certify that products meet the requirements of other specific U.S. government authorities. APHIS could certify that the pet food is free for sale in the United States.
Narration: Now that the affidavit line has been addressed, let's focus on the statement that "certified materials are free of dioxins, and have radioactivity levels consistent with international standards." You notice that there are several problems with this section.
Which of the following might be included in what you tell the exporter?
Narration: Here is the modified VS Form 16-4 with the statement removed that says, "Certified materials are free of dioxins, and have radioactivity levels consistent with international standards." The statement has been replaced with the statement that says, "Certified materials are free for sale in the United States."
The following Knowledge Review is a True or False question. Select the best answer and feedback will immediately appear.
The statement, "Materials were heated to a minimum internal temperature of 90°C," may be endorsed as it currently appears on the exporter's VS Form 16-4.
The correct answer is True.
This statement may be endorsed as it currently appears on the exporter's 16-4. APHIS officials may endorse statements referring to how a product was processed if the statements are supported by an affidavit and/or inspection. In this situation, the statement appears under the affidavit line, and therefore may be endorsed (if the statement also appears on the affidavit itself).
Narration: Now let's review the statement on the exporter's VS Form 16-4 that says, "Materials were heated to a minimum internal temperature of 90°C." Would it be true or false to say that this statement can be endorsed as it currently appears on the 16-4?
The following Knowledge Review is a multiple choice question. Only one answer is correct; select the best answer and feedback will immediately appear.
There are problems with the statement, "The undersigned guarantees that certified materials are not mislabeled." Which of the following statements best describe an issue with this statement as it appears on the VS Form 16-4?
The answer is C.
The portion of the statement that says, "the undersigned guarantees," does not belong on an APHIS certificate. As this wording appears on the exporter's 16-4, it implies that the signatory of the certificate is endorsing the statement beyond the fact that the office has an affidavit on file supporting the information. Additionally, APHIS does not certify general labeling statements.
Narration: There are problems with the statement, "The undersigned guarantees that certified materials are not mislabeled." Which of the following statements best describe an issue with this statement as it appears on the VS Form 16-4?"
The following Knowledge Review is a multiple choice question. Only one answer is correct; select the best answer and feedback will immediately appear.
Which of the following would be an acceptable replacement for the statement, "The undersigned guarantees that certified materials are not mislabeled"?
The answer is C.
Although APHIS does not certify labeling in general terms, APHIS may certify that a product is labeled with a certain statement either under affidavit or based upon inspection.
Narration: We know that there are problems with the statement, "The undersigned guarantees that certified materials are not mislabeled." What would be an acceptable replacement for this statement?
Narration: Here is the modified VS Form 16-4. The statement, "The undersigned guarantees that certified materials are not mislabeled," has been removed and replaced with the statement, "Certified materials are labeled 'dog food'". The statement, "Materials were heated to a minimum internal temperature of 90° C," still appears on the page."
The following Knowledge Review is a True or False question. Select the best answer and feedback will immediately appear.
The statement, "All grain components of the pet food are free of all plant pests," may be endorsed as it currently appears on the exporter's VS Form 16-4.
The correct answer is False.
VS does not certify to plant diseases. This statement should be removed.
Narration: Now let's focus on the statement, "All grain components of the pet food are free of all plant pests." Would it be true or false to say that this statement could be endorsed as it currently appears on the exporter's VS Form 16-4?
The following Knowledge Review allows for multiple correct answers. Select all of the answers that are correct, then select the Check Answers button and feedback will appear.
There are several problems with the statement, "The production facility is located in Texas, which is free of rabies." What is wrong with this statement?
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The answers are B and D.
Animal disease status statements should not be placed under the affidavit line. Also, statements about the disease status of a region of the United States should not be made without first confirming it. In this scenario, you have not confirmed that Texas is free of rabies.
Narration: Let's look at the next statement that appears on the VS Form 16-4. The statement says, "The production facility is located in Texas, which is free of rabies."
Notice that there are several problems with this statement.
What is wrong with this statement?
The following Knowledge Review is a multiple choice question. Only one answer is correct; select the best answer and feedback will immediately appear.
The exporter states that he actually wanted to include a statement that the state where the production facility is located is free of Lumpy Skin disease, not rabies. If you confirm that the state is free of Lumpy Skin disease, which of the following would be acceptable?
The answer is B.
The animal health status statement should appear above the affidavit line.
Narration: We know that animal disease status statements should not be placed under the affidavit line and that statements should not be made about the disease status of a region of the United States without confirmation. The exporter explains that he actually wanted to include a statement that says the state where the production facility is located is free of Lumpy Skin disease, not rabies. If you confirm that the state of Texas is free of Lumpy Skin disease, how can we properly change the statement to reflect the fact that the production facility is in Texas, and that Texas is free of Lumpy Skin disease?
Narration: Here is a modified version of the VS Form 16-4. The statement, "All grain components of the pet food are free of all plant pests," has been removed. VS does not certify plant diseases so it does not have the authority to endorse the statement, even if it appears under affidavit.
This modified version of the exporter's VS Form 16-4 shows the statement, "Texas is free of Lumpy Skin disease," in the direct attestation area, above the affidavit line. The statement that the production facility is located in Texas remains under affidavit.
The following Knowledge Review is a matching question. Select a letter associated with the answers at the bottom of the screen and type that letter in the space next to the best corresponding phrase or statement. Then, select the Check Answers button and feedback will appear.
Notice there are several problems with the statement, "This product is produced at an establishment inspected and approved by APHIS." Review the following sentences that refer to these problems, and select words from the list below that correctly complete the sentences.
1. The _________ above the line should not be skipped. It allows items to be added after the certificate has been endorsed
2. Prior to endorsement a _________ must be added to blank areas of any VS Form 16-4.
3. Statements that facilities are "inspected and approved" by APHIS may only be made if ________ has inspected the facility.
4. If the statement was endorsable, it would have to appear in the ________ portion.
a. Direct Attestation
b. Affidavit
c. AMS
d. Blank space
e. APHIS
f. diagonal line
The answers are 1d, 2f, 3e, and 4a.
There should only be a single space between this statement and the statement listed above it on the certificate. Statements that facilities are "inspected and approved" by APHIS may only be made if APHIS has inspected the facility within the previous 365 days, which is not the case in this scenario. If the facility had been inspected by VS within the previous 365 days, the statement would still need to in the direct attestation section because it relates to APHIS actions and regulations.
Narration: Now let's look at the statement, "This product is produced at an establishment inspected and approved by APHIS." There are several issues with this statement, especially in the way it is located on the VS Form 16-4. Read the sentences regarding the statement, and then select the terms from below that complete the sentences.
The following Knowledge Review allows for multiple correct answers. Select all of the answers that are correct, then select the Check Answers button and feedback will appear.
Since the facility has not been inspected, and there is no time to inspect, the statement that the production facility has been inspected and approved by APHIS may not appear on the VS Form 16-4. Which of the following would be endorsable alternatives?
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The answers are A and C.
A statement that materials were produced under a system of rules and regulations in place in the U.S., or a statement that materials are free for sale in the U.S. would both be acceptable replacements.
Narration: Because the exporter wants his VS Form 16-4 endorsed as soon as possible, there is no time to inspect the production facility. Therefore, the statement that APHIS inspected and approved the facility cannot be included on the 16-4. Which of the following statements would be acceptable alternatives?
Narration: Looking at the latest version of the exporter's VS Form 16-4, notice that the exporter has replaced the statement that says, "The product is produced at an establishment inspected and approved by APHIS," with a different statement that says, "The product is produced at a facility operating under a system of rules and regulations in place in the United States governing the production of pet food." This second statement is acceptable because it can be made on the basis of APHIS's authority or on the basis of an affidavit. Also notice that the text has been moved higher so that there is not a large blank area in the middle of the statements.
The following Knowledge Review allows for multiple correct answers. Select all of the answers that are correct, then select the Check Answers button and feedback will appear.
Please review the corrected VS Form 16-4 as it now appears. Which of the following are among the issues that must be resolved before the certificate can be prepared for endorsement?
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The answers are B and C.
The blank space after the statements still allows for certifications to be added. The certificate is also missing information about the source animal species. In the box for product quantity and type, there should be enough information provided to determine the source animal species.
Narration: The exporter gives you another version of his VS Form 16-4. You notice that some problems remain. Which of the following are among the issues that must be resolved before the certificate can be prepared for endorsement?
Narration: The exporter creates a new VS Form 16-4 with the statements spaced closer together to prevent the insertion of additional statements after endorsement. A single diagonal line has been added in the blank space remaining in the additional declaration area. This prevents any certifications from being added after the certificate is endorsed. The exporter also modified what was included in the PRODUCT box so that the source animal species may be determined from the description. The product is now listed as "dry dog food, 500 50-pound bags, porcine and avian origin."
You can examine the magnified 16-4 using the scroll bars to view its content more closely. Or, you can also select the PDF icon below the form to view it in PDF format.
We're now ready to review the affidavit that the exporter gave you.
Narration: The exporter provides you with this affidavit. The changes he has agreed to make on the 16-4 are incorporated into the affidavit.
The statement regarding dioxins and radioactivity levels has been reworded correctly to "Certified materials are free for sale in the United States."
The statement, "The undersigned guarantees that certified materials are not mislabeled," has been changed to, "Certified materials are labeled "dog food."
The statement about plant pests remains on the affidavit, but this is not an issue as long as it is not also on the VS Form 16-4.
The statement about Texas being free of rabies has been altered to simply state that the production facility is located in Texas.
The statement, "This product is produced at an establishment inspected and approved by APHIS," has been replaced with the following statement: "The product is produced at a facility operating under a system of rules and regulations in place in the United States governing the production of pet food." Because this statement appears on the VS Form 16-4 under the affidavit line, it must be on the affidavit.
Select the PDF icon to open a version of the affidavit in PDF format to review for any further issues.
The following Knowledge Review allows for multiple correct answers. Select all of the answers that are correct, then select the Check Answers button and feedback will appear.
Now evaluate the affidavit the exporter provided (as shown on the right).
Which of the following are missing from this affidavit?
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The answers are A, C, and E.
The affidavit is missing Jimmy Joe's title. It also does not state that he is authorized to represent Jimmy Joe's Pet Delights in this manner. The affidavit is not notarized or dated.
Narration: Looking at the affidavit, you notice that there are several things missing. Which of the following are missing from the affidavit?
The following Knowledge Review is a multiple choice question. Only one answer is correct; select the best answer and feedback will immediately appear.
Which one of the following statements on the exporter's affidavit must be removed?
The answer is C.
The exporter needs to remove the statement, "This office has on file a notarized affidavit verifying the following information."
Narration: You will see that Jimmy Joe Edward's title of "President" has been added to the affidavit below his signature.
Looking again at the affidavit, you notice a statement that should be removed. Which of the following statements must be removed?
The following Knowledge Review is a multiple choice question. Only one answer is correct; select the best answer and feedback will immediately appear.
As you review the exporter's affidavit, you notice another statement is worded incorrectly. Which one of the following statements is worded incorrectly?
The answer is C.
The statement, "The above statements are true," is worded incorrectly and needs to be rephrased.
The closing statement should instead say, "I certify the statements listed above are true to the best of my knowledge and belief."
Narration: Here is a revised affidavit. The statement, "This office has on file a notarized affidavit verifying the following information," has been removed.
You now notice there are some statements that are worded incorrectly. Which of the following statements is worded incorrectly?
Narration: The exporter modified the affidavit following your suggestions, and after a trip to the bank to get it notarized, gave you another draft. Let's review this modified affidavit.
The statement, "The above statements are true," has been replaced by, "I certify that the statements listed above are true to the best of my knowledge and belief. I am the president of Jimmy Joe's Pet Delights, Inc., and am authorized to represent the company in this manner."
The affidavit is signed, dated, and notarized. You determine the affidavit is complete and does not need to be further modified.
Now that the affidavit is complete, you will need to return to add the certificate number, the certifying official's name and title, and the date to the VS Form 16-4 prior to printing it on VS Security Paper. Once printed on VS Security Paper, the VS Form 16-4 can be signed and embossed. Then after you make an office copy, you can provide the original to the exporter. Remember to remind the exporter that it is her responsibility to have her importer confirm prior to shipment that the changes to the certificate are acceptable to the government of Bobania.
This screen concludes this scenario. Please close this window to return to the lesson menu.