USDA BioPreferred Program Audit Plan Summary
What is the USDA BioPreferred Program Audit?
The USDA BioPreferred Program Audit sets in place the audit procedures for both the Procurement side of the program as well as the Labeling side of the program. The purpose is to monitor the validity of the participants' designated and certified biobased content claims; and, for the Labeling initiative, monitor the proper usage of the label in the marketplace. The audit consists of three (3) stages: 1) Bi-annual contact and participant response (2012, 2014, 2016...); 2) Sample testing of participant's products (2014); and 3) Retesting of participants products (2016).
Why is this audit necessary?
The audit will ensure the integrity of the voluntary biobased product certification and labeling initiative and the preferred federal procurement initiative. The audits provide oversight and monitoring of the products affiliated with the program to ensure the products' biobased content information is accurate and that they products meet the requirements of both initiatives.
What is the timing of the USDA BioPreferred product audits?
Stage 1 of the audit will be conducted bi-annually and completed in the first half of the year for both programs. Stage 2 auditing is tentatively slated to be conducted in 2014, unless other issues impact alteration of dates. Stage 3 auditing is only for the Labeling Program and the audit for this stage is slated to begin in 2016.
How was Stage 1 Auditing conducted?
This stage (completed in 2012) involved contacting all participants via email and requesting that they complete a “Declaration of Conformance Form.” Program participants confirmed if they still manufactured the product, and whether or not the formulation/manufacturing processes had changed. They listed all active products and advised if any complaints have been received regarding the claim of the biobased content.
The participant had 30 days to respond, when no response was received, a second email was sent with a 15 day response time. When no response was received, a phone call was made to non-responders. When there was still no response, the participant received a notice of suspension with 30 days to comply and they had to discontinue using the label and their product was removed from the USDA website and catalog. The participant had to reapply, which included retesting at their own expense in order to have their product accepted back into the program.
What are Stage 1 Audit results?
Label Usage Audit - Of the companies audited, 76% were using the label on their websites and other media advertising correctly, with 13% having minor violations and 11% with more serious violations.
Certified Products - Only 2% of the total products certified were removed from the program. The reasons for being removed consisted of: 1) no response (7%); 2) product no longer manufactured (41%) and 3) change in biobase content (7%). All companies with certified products responded except 3% of total population.
Designated Products - 67% of the companies with designated products responded to audit. Thirty percent (30%); of these 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, less than 1%.
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How will Stage 2 Auditing be conducted?
This stage involves random sampling of approximately 100 desingated and certified products from selected companies to confirm the accuracy of biobased percentages claimed.
How will Stage 3 Auditing be conducted?
This stage will involve retesting of certified products only that have been certified for a specified period of time.
All appeals from participants/companies must be made in writing to USDA with supporting documentation for their appeal.
Who can I contact for more information?
For more information, you can contact Kate Lewis, Deputy Program Manager at (202) 720-0811, email: firstname.lastname@example.org.