USDA BioPreferred Program Audit Plan Summary
What is the USDA BioPreferred
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) Retesting a sampling
of participant's products (2014); and 3) Retesting all participant’s products
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
What is the timing of the USDA BioPreferred
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 biobased content (7%). All companies with certified products
responded except 3% of total population.
Designated Products - 67% of the companies with
designated products responded to the 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%.
Please refer here
for more details.
How will Stage 2 Auditing be conducted?
This stage involves a sampling of approximately 50 certified
products from selected companies to confirm the accuracy of biobased
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 sample and ship the sample along
with the "Documentation of Sample Selection, Shipping, and Disposal by
Manufacturer/Vendor 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 the 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?
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: email@example.com.