January 14, 2011
By Email to Food Aid Quality Review, Tufts University
The North American Millers’ Association (NAMA) is pleased to submit the comments below in response to the Request for Comments on the Food Aid Quality Review (FAQR) initial draft published by Tufts University on December 14, 2010. NAMA is the trade association representing the wheat, corn, oat and rye milling industry. NAMA¹s 45 member companies operate 170 mills in 38 states and Canada. Their aggregate production of more than 160 million pounds per day is approximately 95 percent of the total industry capacity. NAMA has represented the manufacturers and vendors of the most highly nutritious grain based food products used in the US food aid program, since the inception of those products in the 1960’s. As truly engaged stakeholders, we are appreciative of the amount of dialogue we have been able to have with the authors of the FAQR and believe our input into the process has and will continue to make the recommendations more practical in accomplishing our mutual goals.
NAMA is extraordinarily proud of the role we have played in the noble effort of the last 50+ years to provide life-sustaining nutrition to literally millions of needy persons around the world, using the globe’s most efficient food delivery system. All of the comments below are directed toward assuring that efficiency and effectiveness are enhanced, not compromised, directly or indirectly by the recommendations of the FAQR.
We begin with a couple of general comments:
The most critical observation we wish to make is that this process is recommending changes to products and a system that is currently working. Even those organizations with overt agendas objecting to the US food aid program must admit that the programs continue to provide nearly half of vitally needed food products to the world’s neediest souls and that without that resource their fate would be dim.
The concurrent comment with that is that many of the recommendations in the FAQR will require more research, field-testing and analysis before being partially or fully implemented. NAMA members and staff pledge their best efforts to assist in all aspects of these pilot-testing regimes and would strongly recommend that current systems for programming and implementing food assistance programs not be changed or abandoned until these new, improved systems have proven themselves in practice. It would be a tragedy if new products and systems were rolled out as replacements before they were capable of meeting the same needs and populations that the current products and systems are serving.
More specific comments are related to points from the Report Synopsis that we believe warrant more lab research, industry dialogue and/or field-testing before they can be effectively implemented:
Item 5- NAMA agrees that lipid-based foods, while apparently highly effective for certain uses in food assistance, are not equally suitable for all uses and may not be cost-effective when used outside specific targeted populations. The ability to meet high nutrition goals with more cost-effective foods is a high-priority objective.
Item 6- NAMA agrees with cost-effectiveness as a measurement tool for international food assistance. Neither the cheapest food in terms of $/ton nor the most expensive in $/serving may actually be the best at serving the recipient’s nutritional needs at least cost per measure of nutritional outcome.
Items 10/11/12- Targeting of the ‘right food’ to the right use has been the challenge, since the first food assistance began centuries ago and remains an issue for the US programs today. Assuming that the perfect food will always be on hand in the right quantities in the right location denies the fact that food aid is one of the longest, most complex supply chains in the world. It also can be one of the most expensive, so products should err on the side of being applicable to as many population targets as possible, even if they are not the “best” to all. This has been the basis for the Fortified and Blended Food formulations for 50 years and the reason FBF’s have been the mainstay of food interventions. NAMA supports increased nutritional profiles for FBF’s, but reducing the role FBFs play to only a small number of target recipients would warrant more analysis to determine what other products can serve that same need.
Item 13- NAMA has produced Corn Soy Milk for decades and is hopeful to find a cost-effective, safe and practical method of adding animal protein to the Corn Soy and Wheat Soy products of the future. Our cautionary messages are: a.) the microbiological issues of dairy are different than those of grains and whey has not been fully tested for shelf life and micro issues when paired with grain foods, b.) costs of dairy addition will inevitably lead to higher costs as manufacturers determine whether current facilities can be structured to make such a product and at what cost and c.) our companies are not knowledgeable regarding possible allergenicity issues related to the intensity of proteins in whey concentrate. While unit cost and investment levels to retrofit equipment is a consideration, it must be noted that current food aid production facilities are not dedicated to food aid and we cannot imagine a viable economic model based on such dedication, due to the variable monthly demand base. Therefore, AID should consider whether the formulations they ultimately choose will actually be available, by either the current manufacturers, or under what conditions any other manufacturer would choose to make the new products. The perfect food that never gets produced is not really perfect.
Items 16-19- NAMA does not have specific expertise in the nutritional makeup of vitamin and mineral premix, but will pass on any practical issues on either the formulation or application that are conveyed to us by the vitamin and premix suppliers who have that expertise in the US food industry.
Item 20- This recommends that suppliers of FBF’s be held to ‘rigorous performance criteria’ and violations be met with temporary exclusions from participation. NAMA supports this concept, as long as those criteria are clear, measurable, transparent and are accompanied with an independent appeal process. Open-ended obligations for products after they leave the care and custody of the supplier entail risks that are not insurable or reasonable.
Item 21- Open-ended advocacy of other grain products in ‘new’ formulations seems like a reasonable recommendation, but taken to its logical extreme, we could have literally hundreds of new products, package sizes and flavors that will likely overwhelm the implementing agencies and supply chains. While nothing should be done to stifle progressive innovation in products that serve a purpose, new products for the sake of creating demand for the commodity are probably a misallocation of resources.
Item 22- This advocates exploration of smaller package sizes with the intention of honing targeting. While this benefit may be substantial, such changes will raise processing, packaging and subsequent handling costs substantially. Such increase costs need to be weighed against the perceived benefits to assure program efficiencies. There are also environmental and solid waste disposal vs. reuse considerations in the packaging size and materials consideration.
Item 31- NAMA has long been an advocate that nutrition delivery was the essential objective of US food aid interventions and that higher nutrition products were better ‘bang for the buck’ than lower nutrition, lower cost per ton products. This recommendation reinforces that idea and further expands it to say that some overly complex high nutrition foods are, in turn, overkill. NAMA fully supports the ‘right food for the right use’, without paying more for the product that its targeted use warrants.
Items 32/33- The recommendation states ‘ we recommend against the endless proliferation of increasingly specialized products’, which is essentially the point we made regarding Item 20. The essence of innovation is to do something that’s already being done in a significantly better or cheaper way and all new suggestions for food products must be held to that criterion. Doing the same thing in a new or different way that’s not significantly better or cheaper should be rejected.
Item 37- While NAMA thinks there would be some significant value in coordinating product and other approvals by US, UN and other bureaucracies, it’s likely that this would take significant investment by all the agencies and may not be a realistic expectation.
In summary, NAMA believes this FAQR has been a very helpful endeavor and wishes to be fully engaged in the further work that needs to be done to assure the implementation of the recommendations result in the most effective and efficient food aid interventions possible. To avoid unintended consequences, we strongly urge that the current program procedures be maintained until these recommendations have been field-tested and proven.
International Trade Consultant