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AuditProgram

USDA BioPreferred Program Audit Plan Summary

What is the USDA BioPreferred Program Audit?

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.

Definitions

Qualified product - meets the requirements for one or more product categories identified by USDA as part of the federal government procurement preference program.

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

How was 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 results?

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 serious violations.

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 conducted?

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 conducted?

Stage 3 will involve the retesting of all certified products falling outside of a pre-determined initial certification date.



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 information?

For more information, you can contact Kate Lewis, Deputy Program Manager at (202) 720-0811, email: kate.lewis@dm.usda.gov.

 
 
 
 
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