SUSTAIN
Focus on Quality in Food Aid  
Food Aid Quality Project

Early in 2007, the U.S. Department of Agriculture (USDA) and the U.S. Agency for International Development (USAID) jointly announced a three part initiative to evaluate the quality assurance requirements and nutritional formulation of food aid products. In October 2007, USDA contracted with SUSTAIN to review and recommend updates to key quality oversight components of its food aid product procurement system.

The one-year “Food Aid Quality” project was designed to comprehensively review Public Law 480, Title II product specifications and develop recommendations for improvements in these critical quality assurance tools. The agency asked for a comprehensive and uniform set of food aid specification templates, with relevant product composition, quality assurance and performance requirements consistent with contemporary commercial practices. Additionally USDA requested scientifically valid sampling and testing plans for determining if products are in compliance with specification.

A team of experts in food manufacturing, food science, quality assurance, cereal chemistry, analytical testing, and statistics reviewed the Commodity Requirement documents and identified deficiencies and areas for improvements. Some product specifications contain insufficient criteria to adequately define the product and others include more requirements than necessary. The current Commodity Requirement documents, moreover, do not define quality control systems expected of manufacturers. Inconsistent formatting and structure in the existing specifications has made it difficult for vendors and manufacturers to find parallel information in different specification documents.

The project delivered recommended product specification templates for the major categories of P.L. 480 Title II commodities – blended and fortified foods, whole or partially processed grains, commercial products, and vegetable oils and fats. In addition to uniform performance language that would improve end product quality, SUSTAIN provided:

  • standardized vitamin and micronutrient terminology

  • recommendations to dissuade use of discount schedules for products that fail to meet specifications

  • defined lot sizes appropriate for each commodity

  • criteria for selecting contract analytical laboratory services

  • recommended analytical methods for measuring compliance with requirements, and

  • an outline of quality control systems components.

USDA was encouraged to require manufacturers to implement and maintain basic food safety systems consistent with Good Manufacturing Practices (21 CFR 110) as well as a validated Hazard Analysis and Critical Control Points (HACCP) plan and its prerequisite programs. It was recommended that a complete certificate of analysis accompany each lot of product submitted for acceptance by the Government.

Data on manufacturing process variability is critical to the development of scientifically valid sampling and testing protocols for use in verifying product compliance to specifications. However, these data were not available for current food aid products. SUSTAIN was able to develop sampling and testing plans based on, and sharing the same philosophical and theoretical bases with those presented in the Codex Alimentarius Commission’s document titled “CAC/GL 50-2004”.

While outside the scope of the current project SUSTAIN also identified opportunities to capture trends and innovation in the commercial sector. This included offering recommendations for new product lines and for applied research to help improve quality assurance/control programs.

SUSTAIN’s final report is recorded in the Federal Register (Vol. 74, No. 163 /Tuesday, August 25, 2009 /Notices 42845) and was posted on USDA’s website on July 17, 2009. Reference to the work is also made by the U.S. Government Accountability Office (GAO) in its September 2009 report on International Food Assistance: Key Issues for Congressional Oversight (GAO-09-977SP).