February 14, 2018
Mr. John Sheehan
Subsistence Customer Operations
Defense Logistics Agency
700 Robbins Avenue
Philadelphia, Pennsylvania 19777-5096
Submitted via IngredientsRFI@dla.mil
RE: Request for Information to Industry to assess the impact of reducing or eliminating certain ingredients from food products (Posted November 14, 2017)
Dear Mr. Sheehan:
On behalf of the National Council of Farmer Cooperatives (NCFC), please accept the following comments in response to the Defense Logistics Agency’s (DLA) request for industry input on the impact of reducing or eliminating certain ingredients from food products posted on November 14, 2017.
Since 1929, NCFC has been the voice of America’s farmer-owned cooperatives. NCFC members include regional and national farmer cooperatives, which are in turn composed of over 2,500 local farmer cooperatives across the country. Farmer cooperatives – businesses owned, governed and controlled by farmers and ranchers – are an important part of the success of American agriculture. Many of our members have had long and direct experience collaborating with the Defense Logistics Agency to ensure our military service men and women are provided with high quality, nutritious food that enhances their performance.
Our farmer-owned cooperatives have made a commitment to fostering consumers’ and food service partners’ access to information about the food they eat; providing consumers with continued access to an abundant, safe, affordable and sustainable food supply; and respecting the strong scientific consensus on the safety of the ingredients we use in our food products.
Additionally, NCFC emphasizes the importance for DLA to consider the following points when considering prohibition of certain ingredients:
- Transparency – Our farmers and ranchers play a critical role in feeding not only America’s families, but also families around the world. Our service men and women play another critical role, and that is keeping those families safe. It is through transparency and collaboration that we can work together to ensure that DLA reaches its nutrition goals. Our farmer-owned cooperatives take great pride in their products, and would be more than happy to engage in a dialogue with any of our customers if certain nutrition objectives are outlined or concerns on particular ingredients are relayed. We also request that stakeholders have the opportunity to formally comment on a Defense Acquisition policy change that will certainly have an economic impact on our nation’s food manufacturing sector.
- Utilizing the Best Available Science – We recognize the important role the food industry plays in ensuring our military men and women have the nutrition they need to perform at the highest level. However, many of the ingredients covered by the DLA announcement are widely used and have long been accepted by the Food & Drug Administration (FDA). Consequently, the imprecise listing descriptions in the Notice had the unintended consequence of sweeping a vast number of products into the prohibition, including potentially all meat and dairy products. The lack of specificity in the proposal has the potential to impact stakeholders up and down the S. food supply chain as well as troop health and readiness. The food industry supports consistent nutrition and food standards across the federal government given a patchwork of standards leads to confusion and unnecessary cost and inefficiencies across the entire supply chain.
- Supply Chain Realities – While the decision to reformulate is not uncommon within the food industry, it is however a complex process that takes place over the course of months or years, not weeks. The initial notice specified a timeline of six weeks to provide the Department of Defense with information on Should the DLA decide to prohibit any ingredients, this must be adequately communicated to suppliers in a manner that would prevent potential disruptions to stakeholders and troop support activities.
NCFC appreciates the opportunity to provide input and remains available to confer with the agency as appropriate if additional input is needed.
Charles F. Conner
President & CEO