 |
YELLOW SHEET Office of the State Auditor of Missouri |
October 1, 2002
Report No. 2002-106
The following problems were discovered as a result of an audit conducted by our office of the Department of Agriculture, Oversight of Manufacture and Distribution of Commercial Feed Products.
The Department of Agriculture, Plant Industries Division-Bureau of Feed and Seed (bureau) inspection and testing program helps ensure the majority of commercial feed products, such as cattle feed and pet food, manufactured and/or distributed in the state contain ingredients guaranteed on the product labels.� The bureau's testing program consistently showed at least 87 percent of the commercial feed providers complied with ingredient requirements.
Repeated violators not penalized
Despite high compliance, the bureau's policy did not penalize feed distributors who repeatedly violated state feed laws and regulations.� This policy has partly contributed to sales of over 6.5 million pounds in deficient feed products during calendar years 2000 and 2001.
These mislabeled products contained less protein and/or other necessary ingredients critical to the growth and health of livestock, poultry, and pets.� When commercial feed products contain less ingredients than advertised, it can result in reduced profits for commercial feed purchasers, and increased health maintenance costs for pet owners.� Additionally, the bureau did not collect all state inspection fees in a timely manner.
The bureau's analyses showed 87 percent of the feed sampled in 2000 and 88 percent sampled in 2001 complied with labeling laws.� For feed products that did not meet label guarantees, the bureau issued a "withdrawal from distribution order."
Audit analysis of withdrawal orders for 2000 and 2001 showed commercial feed manufacturers and distributors reported 6.5 million of the 9.5 million pounds of deficient feed (68 percent) already sold when they received the withdrawal order.� The total amount of deficient feed products actually sold to farmers and pet owners could be substantially higher than 6.5 million pounds.� The withdrawal orders only list the amount of feed on hand at the site of the original sample, which could have been substantially less than the total amount manufactured, especially if the sample came from a retail distributor.
The bureau lacked procedures to ensure deficient feed products are not sold.� Due to the time required to obtain samples and conduct feed tests, it is not possible to totally prevent the sale of deficient feed products.
The bureau's feed inspectors visited and obtained feed samples from numerous retail sites when they could obtain the same feed samples from single manufacturing feed mill sites within the state.� The bureau's inspection policy authorizes feed inspectors to independently develop feed inspection and sampling strategies rather than follow a statewide strategy.� Additionally, bureau staff may be over testing some products, such as 20 or more tests on a product in a calendar year.
Although a statewide inspection and sampling strategy would not eliminate the need to visit some retail distributors and obtain multiple samples of the same feed, bureau officials acknowledged some visits and multiple testing of the same product could be prevented.� Eliminating unnecessary visits would allow feed inspectors more time to ensure manufacturers and distributors comply with withdrawal orders.
Increased central oversight could reduce the number of feed samples obtained and annual tests conducted.� Audit analysis showed some feed products were sampled and tested 52 times in a calendar year.� Because several of these products did not fail or failed only a few tests for labeling guarantees, some tests could have been potentially eliminated.
According to the bureau officials, some feed ingredients, such as soybean meal, need more frequent testing because of the importance related to protein guarantees.� Bureau staff, however, have not monitored the samples obtained and tested for each product throughout the year to determine if current practices are adequate.
