All recipient agencies (RAs) sign a contract with the Commodity Distribution Unit (CDU), agreeing to safeguard USDA commodities once they are delivered. The contract terms reflect health department regulations and general industry standard practices.
In order to safeguard these commodities, recipient agencies (RAs) must develop and maintain a written system of accountability for the USDA products received. OKDHS refers to this as a “Perpetual Inventory.” The perpetual inventory is a complete and accurate record of the receipt, distribution, use, disposal and physical inventory reconciliation of commodities. The Code of Federal Regulations (CFR) allows either a single inventory system or the state may require inventories to be maintained in a manner other than described in 7 CFR, Part 250. The Commodity Distribution Unit (CDU) elects the use of a perpetual inventory in Oklahoma. This includes an inventory for end product items processed with commodity foods.
The OKDHS Commodity Distribution Unit (CDU) recommends each item be listed on a separate page for ease in updating and reconciliation. Count quantities in units, including parts of cases. For example, seven cases and three cans of peanut butter. The Commodity Distribution Unit (CDU) recommends completing physical inventory reconciliation at least monthly. Many recipient agencies (RAs) have a computerized inventory system. These systems must be accurate so they maintain accountability for the USDA products. Those who use processing for USDA bulk products or value pass through must notify the Commodity Distribution Unit (CDU) when products are received. A form provided on the OKDHS Web site for this requirement.
Do not store commodities in private homes at any time. Keep all records relating to the commodity program for the current year as well as the three prior years. The records are not to be stored off site or in private homes.
Storage of commodities involves two major components. storage conditions and storage practices. Storage conditions are proper temperature and adequate air circulation. Storage practices include first in, first out, proper stacking, protection of stored food, storage during summer months and a perpetual inventory system.
One of the major keys to proper storage is to request and accept no more food than can be used without waste by the product's "best if used by" date. Recipient agencies (RAs) may contact other agencies who have a current agreement with the Commodity Distribution Unit (CDU) for possible transfer of excess products. The Commodity Distribution Unit (CDU) must approve all transfers.
Document temperatures daily during operation. Record the temperature late each Friday afternoon and early Monday morning if the operation is closed weekends. Check the storage area immediately and record the temperature after a known or suspected power loss, or mechanical malfunction. During school breaks or the summer months, the temperatures should be checked and recorded at least every other day, with no more than a two-day gap. Keep thermometers in all storage areas where commodity foods are stored.
Checking temperatures daily increases the likelihood freezer failure will be noticed before a thaw occurs. If food is lost due to freezer failure, the lack of a properly completed temperature log may be considered negligence and the Commodity Distribution Unit or USDA could file a claim requiring repayment for the products.
The recommended temperatures are:
- 70 degrees or below in dry storage
- 32 to 40 degrees in refrigerators
- zero degrees or below in freezers
All storage areas need air circulation. Commodities are to be stored on pallets or shelves with adequate clearance from the floor and walls and two feet of clearance from the ceiling. Never store directly on the floor of any of your storage units.
Commodities with the oldest pack date on the case are placed in front and used first. This is referred to as a first in, first out system. Mark food removed from a case with the pack date and use the oldest first. In cases where the pack date is not available, use the receipt date.
Stack commodities low enough so bottom layers are not crushed, cross-stack to keep the stack solid and orderly and away from moisture, heat sources or steam.
Protect food in storage by checking regularly for deterioration, such as torn sacks and broken cartons. Keep all storage areas clean. Store food away from chemicals and paper goods. Exterminate the facility monthly or more often if there are infestation problems and at least quarterly if not. Keep storage areas locked and limit key access to authorized personnel. Areas where commodities are stored should not be accessible to anyone but the designated food service staff. Commodity foods are not to be used for any purpose other than the approved USDA programs and participants.
USDA donated foods going into summer storage need special handling to prevent losses. Try to use up most donated foods received earlier in the school year so less food has to be stored over the summer break.
Do the following when storing food over the summer:
- Clean and check storage areas for infestation before storing food
- Store flour and other grain products in refrigerators or freezers
- Stack freezers with meat items on the bottom. In case of a freezer failure, there is no cross contamination of foods
- Check and record temperatures daily, if possible, and at least every other day with no more than a two-day gap
In the fall, check commodities for signs of damage and take another physical inventory to make sure the beginning inventory is accurate. Report any losses immediately. (See Chapter 8 for more details on losses).