Program Audit Plan Summary
What is the USDA BioPreferred
The USDA BioPreferred Program Audit
establishes the audit procedures for both the federal procurement
preference and the voluntary product certification (e.g. labeling)
elements of the BioPreferred program. The purpose is to monitor the
validity of the participants' qualified and certified biobased
content claims; and, for the product certification initiative,
monitor the proper usage of the label in the marketplace. The audit
consists of three (3) stages: 1) Review of completed of "Declaration
of Conformance Form"; 2) Retesting a sampling of certified
products; and 3) Retesting all certified products falling outside of
a pre-determined initial certification date.
Qualified product - meets
the requirements for one or more product categories identified by
USDA as part of the federal government procurement preference
Certified product - has
achieved third-party verification of biobased content and has
earned USDA certification and approval to display the USDA certified
biobased product label.
Why is this audit necessary?
The audit will ensure the integrity
of the voluntary biobased product certification and labeling and the
preferred federal procurement initiative. The audit provides
oversight and monitoring of the products affiliated with the program
to ensure the products' biobased content information is accurate and
that the products meet the requirements of one or both initiatives.
What is the timing of the USDA
BioPreferred product audits?
The audit will be conducted
bi-annually in three separate stages. The timeline for the current
audit cycle is:
Stage 1: completed
Stage 2: completed by October
31th, 2014 for certified products
Stage 3: will begin in 2016 and
will apply only to certified products
Stage 1 Auditing conducted?
Stage 1 of the audit applies to both
qualified and certified products. Stage 1 of the current audit cycle
was completed in 2012 and involved contacting all participants via
email and requesting that they complete a "Declaration of
Conformance Form." Program participants confirmed that they
still manufactured the product and that the formulation/manufacturing
processes had remained the same. Companies were asked to list all
active products and advise the BioPreferred program of any complaints
regarding the claim of the biobased content.
The participant had 30 days to
respond, and if no response was received, a second email was sent
with a 15 day response time. When no response was received to the
second request , a phone call was made to non-responders. If there
was still no response, the participant received a notice of
suspension with 30 days to comply. The notice included direction to
discontinue using the label and indicated that the product would be
removed from the USDA website and catalog. Participants receiving the
suspension notice are required to reapply for certification in order
to display the USDA certified label on a product.
What are Stage 1 Audit
Label Usage Audit - Of the
companies audited, 76% were using the label on their websites and
other media advertising according to the BioPreferred Brand
Guidelines, with 13% having minor violations and 11% with more
Certified Products - Only 2%
of the total products certified were removed from the program. The
reasons for removal consisted of: 1) no response (7%); 2) product no
longer manufactured (41%); and 3) change in biobased content (7%).
Ninety-seven percent (97%) of companies with certified products
responded to Stage 1 of the audit.
Qualified Products - 67% of
the companies with qualified products responded to the audit. Thirty
percent (30%); of qualified products were removed from the catalog.
The following is a breakdown of the reasons for removal: 1) no
response (62%); 2) no longer manufactured (25%); 3) modification of
product listings (7%); 4) the company requested removal from the
program (4%); 5) product no longer meets minimum requirement (2%) and
other reasons, (<1%).
Complete Stage 1 Audit Report
How is Stage 2 Auditing being
Stage 2 involves only certified
products and involves a random sampling of approximately 50 certified
products to confirm the accuracy of biobased content percentages
claimed. The participants whose products have been selected will be
contacted via email and by phone and requested to complete a
"Documentation of Sample Selection, Shipping, and Disposal by
Manufacturer/Vendor Form." The participant will then select a
representative product sample and ship the sample along with the
completed Form to an accepted laboratory as defined in the email. The
sample will follow the normal testing procedure and the results will
be provided to USDA and the participant. The test results will be
compared to the current biobased percentage. If the biobased
percentage is within +/- 3 percent, the participant’s product
will remain as certified in the program. If the biobased percentage
is not within +/- 3 percent, the participant will be contacted to
determine the cause.
How will Stage 3 Auditing be
Stage 3 will involve the retesting
of all certified products falling outside of a pre-determined initial
How are appeals handled?
All appeals from
participants/companies must be made in writing to USDA with
supporting documentation for the appeal.
Who can I contact for more
For more information, you can
contact Kate Lewis, Deputy Program Manager at (202) 720-0811, email: