NAMA COMMENTS ON PACKAGING REQUIREMENTS FOR BLENDED AND FORTIFIED MILLED COMMODITIES
Attached to the ICSB Sources Sought document was a separate set of proposed specifications for future packaging requirements for blended and fortified milled commodities. It’s not clear what products this proposal would apply to, but in conversations with FSA/DACO, it appears that these specifications would apply to all blended and fortified products currently in use in the US food aid program and prospectively, the ICSB product. These North American Millers’ Association comments are based on that assumption.
We are also basing these comments on the assumption that this proposal is being promulgated to comply with the same FAR dictated ‘performance based’ standards that the ICSB specifications were based on. In this case, it would seem to be directed to the prospect that the current paper bags with in inner polypropylene liner may not be the only type of bag capable of ‘performance’ in the international food aid programs. While NAMA has no inherent disagreement with the concept of ‘performance’ as a method of encouraging innovation and better effectiveness in programs, this specification appears to take into account far too few of the programs’ multiple goals to be sufficient in addressing this subject.
Our comments will address the goals we think are not addressed in the proposal and repeat our suggestion that FSA/DACO reissue a more comprehensive proposal and call a public meeting of stakeholders to discuss and gather expertise from industry sources on how the scope of the proposal can meet the perceived objectives. In that meeting, we’d expect more experts on packaging, ports, warehousing and cargo handling, who could provide valuable expertise in this area.
It appears from the testing included in the proposed requirements, the primary and perhaps sole objective of packaging is to maintain product intact (not torn or leaking) throughout the shipment and distribution of these products to their eventual recipient. The criteria to determine that ability appear to be the results of a ‘drop test’ and “ a history of successful use in commercial channels”. Our first comment is that we are not aware of any domestic circumstance that would approximate the wear and tear of international food aid distribution. In most cases, domestic uses of 50 lb. bags would normally be palletized, shrink wrapped and handled mechanically. In many cases, the first hands that touch those bags are the end consumers taking them off the pallet in a ‘big box’ store. Compare that to a bag of CSB that typically would be lifted by hand dozens of times in breakbulk shipments and probably at least 6-10 times in containerized shipments. There’s also the exposure to weather conditions at the time of loading/unloading rail cars, port terminals, rail or truck shipment on arrival and multiple warehouses in the destination country, which is entirely different than most domestic circumstances. Recommendation: History of successful use in US domestic commerce is not sufficient to warrant successful use in international food aid.
While durability and strength are necessary objectives, bags provide other services in the food aid supply chain. Ease and safety of handling, protection from insects and vermin, effectiveness of warehousing/stacking and lengthening of shelf life are just some examples
Shelf Life/Protection from insects and vermin-
World Food Program’s global procurement frequently uses a poly-lined, woven poly bag for blended food procurements and many African producers of these products use a similar bag. We agree that those bags are probably cheaper than paper bags and are very strong. The trade off is that they are not heat-sealed and the sewn seams of the bags provide the opportunity for insect infestation and moisture penetration. Locally produced CSB also uses inherent oil from the corn, so rancidity begins as soon as the products enter the bags. In most cases, WFP and local shipments are distributed in a short time, so the shortened shelf life inherent in those bags is not an issue. That’s not been our experience with US origin blended foods. In fact, we specifically attempt to make US origin, blended foods with a longer shelf life than their counterparts from other countries. Recommendation: Criteria be added to assure that packaging is resistant to insect migration and protection from infestation for an extended handling and storage period in hot/humid conditions.
Stacking/Warehousing-
Road salt used in the US during winters is packaged in a type of plastic sheeting bag that provides extremely effective shelter from moisture and can even be stored outside. However, these airtight bags are packaged like ‘pillows’ and neither stacking nor handling are simple or safe. If holes are used to release the pillowing, the offset is loss of protection from moisture and insects. These bags are frequently treated with a non-slick method to prevent sliding when stacked, but our experience is that this will only permit the minimum amount of stacking needed for safe palletization, not the numerous stacks in port and overseas warehousing of 20+ bags high. Recommendation: The ability to safely stack and warehouse bags and the methodology for pilot or test shipments is undertaken before any package is accepted for unlimited use in international food aid.
Consistency of size, shape and material-
Our PVO partners have frequently told us that one of the most challenging issues for warehousing bagged commodities is the need for warehouse space for numerous products. A single warehouse needs to provide the ability to separately stack and inventory the incoming/outgoing cargos of multiple bagged commodities (on any given day, bags of rice, beans, CSB, bulgur, dry peas, and corn meal) as well as boxes of vegoil for monetization, separate from vegoil for distribution and recently boxes of ready to eat therapeutic foods. Imagine the difficulties in now adding another dimension of another or even two more different types of packaging for each of those products. Any change in bag dimensions makes them necessary to be inventoried separately, so a difference in bag type and especially one that can’t be stacked over 4 or 5 high, will create major bottlenecks and extra costs to this program. Recommendation: Provisions be revised to address need for consistency of packaging materials and avoid additional storage, handling and inventory costs throughout the supply chain.
These constraints for the proposed packaging specifications are excellent examples of NAMA’s repeated assertion that the FAR regulations application to the international food aid program are likely to cause several unintended consequences that will increase costs and negatively effect the program’s goals of assisting the most needy human beings on the planet. We have little doubt that a procurement officer can find specifications for products in these programs that would save in procurement up-front. It is the fact that many of those procurement decisions would cost the program in down-stream inefficiencies, safety, or waste that causes us to once again urge caution and consultation with the industry and other stakeholders. The current specifications for products and packaging look like they do for valid reasons and were carefully worked out as the best answer to several complex procurement, logistics, handling and technology challenges. To now make the goals of durability and ease of procurement the priorities, based on some bureaucratic interpretation of consistent procurement rules is a colossal mistake.
NAMA supports and encourages product and packaging innovation and have many examples of consultation between industry, government and PVO stakeholders that have resulted in outstanding changes to this program’s effectiveness. We encourage such an approach to these issues going forward.
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