oversight

Review of Practices, Procedures, and Controls To Prevent Spoilage or Theft of Federal Commodities Donated to the Commonwealth of Puerto Rico for Food Relief Programs

Published by the Government Accountability Office on 1977-08-18.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

ASSESSMENT OF PROGRAM                                                 CED-77-120
CONTROLS,OVER FEDERAL /                                               ___e      _
COMMODITIES DONATED TO                                                8-18-77
THE COMMONWEALTH OF /
PUERTO RICO 2:
FOOD AND NUTRITION SERVICE/
DEPARTMENT OF AGRICULTURE /


         Report to Senator James B. Allen, pursuant to his request.          The report

discussep Food and Nutrition Service and Commonwealth of Puerto Rico practices,

procedures, and controls to prevent the spoilage or theft of Federal commodities

 donated-to the Commonwealth for use in such Federal food assistance programs

as the school lunch program and the title VII feeding program for the elderly.

 Our review was primarily conducted in Puerto Rico where we visited 11 of the

 14 Commonwealth warehouses used to store federally donated commodities and

 6 local agencies--2 schools, 2 hospitals, and 2 elderly feeding projects--which

 received donated commodities from the warehouses.       Vefe-e:i   * : ox
                                                                         -l

-     ~ected   at.Serv±i-e h   quarters in- Wash4gton, D.C'-sant-4o   regional      office



         Although our review did not reveal current instances of theft or excessive

    spoilage, we concluded that controls over donated commodity transactions and

    inventories needed to be improved.    Without adequate controls--particularly

 over warehouses performing key operational and accountability functions--there

was no procedural assurance that any future program deterioration would be

 promptly detected and corrected.        In other words, the situation seemed all

 right at the time of our review, but this could change.        Improved control

 also was warranted in view of the large donated commodity losses the

 Commonwealth suffered in fiscal year 1975.

              ~
         4e-T~-epme ttherefore recommend$ that the Secretary of Agriculture direct

 the Food and Nutrition Service--the agency responsible for the administration
of the commodity distribution program nationwide--to take a number of actions

to improve the program in Puerto Rico.     The recommendations include having

the Service (1) make periodic evaluations and onsite inspections of Commonwealth

practices, procedures, and controls for receiving, storing, distributing, and

accounting for donated commodities and (2) require more frequent, regularly

scheduled warehouse inspections by the Commonwealth involving physical

inventory checks and independent verification of warehouse receipts and

shipments.



FOOD PROGRAMS



             Need for intensified program monitoring over the receipt, storage,

             and distribution of Federal commodities donated to the Commonwealth

             of Puerto Rico




                       CD~~
             COMPTROLLER GENERAL OF THE UNITED STATES                   -   -
                        WASHINGITON. DC   2048




A-51604
                                                 AUG 18 1977
The Honorable James B. Allen
United States Senate

Dear Senator Allen:

     As a result of your June 28, 1976, request and
subsequent discussions with your office, we have reviewed
Department of Agriculture and Commonwealth of Puerto Rico
practices, procedures, and controls to prevent spoilage or
theft of Federal commodities donated to the Commonwealth for
use in such Federal food assistance programs as the school
lunch program and the title VII feeding program for the
elderly. This report discusses the results of that work.

     At your request, we previously reviewed the Department
of Agriculture's $2.5 million claim against the Commonwealth
for losses of federally- donated commodities during fiscal
year 1975. A report on that claim was sent to you on
February 24, 1977 (CED-77-40). A third and final report
resulting from your June 1976 request is being developed
on certain aspects of food stamp program accountability and
controls in the Commonwealth and will be sent to you at a
later date.

      Our work on the Federal commodity distribution program
in Puerto Rico is summarized below and described in detail
in subsequent sections of this report.   In general, we found
that:

     -- The Department of Agriculture's Food and Nutrition
        Service, the agency responsible for administering the
        commodity distribution program nationwide, was not
        adequately monitoring program operations in the
        Commonwealti and, consequently, could not insure that
        the Commonwealth (1) received all commodities shipped
        or (2) employed sufficient program controls to prevent
        spoilage or theft.

     -- Commonwealth controls to insure a proper accounting
        for the receipt and use of donated commodities and to
        prevent their spoilage or theft needed improvement in


                                                               CED-77-120
                                                               (02389)
A-51604



          one important respect. Inspections of warehouses that
          receive, store, distribute, and account for the
          commodities were infrequent and sporadic, and did not
          include adequate verification that commodity receipts
          were properly recorded or that recorded commodity ship-
          ments were actually made.

     -- The Commonwealth's other practices, procedures, and
        controls to account for donated commodities and prevent
        spoilage or theft seemed generally adequate at the time
        of our review, except that temperatures in the ware-
        houses we checked were higher than the maximum levels
        suggested by the Food and Nutrition Service.

     -- We found no significant spoilage of donated commodities
        at the facilities we checked and only minor inventory
        discrepancies based on our tests of selected commod-
        ities.

     Although our review did not reveal current instances of
theft or excessive spoilage, we believe that controls over
donated commodity transactions and inventories need to be
improved. Without adequate controls--particularly over ware-
houses performing key operational and accountability func-
tions--there is no procedural assurance that any future
program deterioration would be promptly detected and cor-
rected.  In other words, the situation seemed all right at
the time of our review, but this could change.  Improved con-
trol also is warranted in view of the large donated commodity
losses the Commonwealth suffered in fiscal year 1975 (as
discussed in our February 1977 report).

     Therefore, we recommend that the Secretary of Agriculture
have the Food and Nutrition Service take a number of actions
to improve the Federal commodity distribution program in
Puerto Rico. Our recommendations, which are listed in a
later section of this report, include having the Service (1)
make periodic evaluations and onsite inspections of
Commonwealth practices, procedures, and controls for re-
ceiving, storing, distributing, and accounting for donated
commodities and (2) require more frequent, regularly scheduled
warehouse inspections by the Commonwealth involving physical
inventory checks and independent verification of warehouse
receipts and shipments.

SCOPE OF REVIEW

     Our review was conducted primarily in the Commonwealth
of Puerto Rico. We interviewed officials of the Commonwealth's
Department of Education; examined pertinent practices,

                                 2
A-51604



procedures, and controls relating to the receipt, storage, and
distribution of donated commodities; made detailed checks of
11 of the Department of Education's 14 warehouses, including
54 physical inventories of food items; visited 2 schools, 2
hospitals, and 2 elderly feeding projects receiving donated
commodities; and performed detailed tests of records for
selected commodities from the time these commodities arrived
in the Commonwealth, through warehouse storage, to their
distribution to eligible outlets. To evaluate the Food and
Nutrition Service's monitoring of the commodity distribution
program in the Commonwealth, we interviewed officials, re-
viewed practices and procedures, and examined records and
documents at the Service's Mid-Atlantic Regional Office in
Robbinsville, New Jersey.

GENERAL PROGRAM INFORMATION

     Section 32 of Public Law 74-320 (7 U.S.C. 612c) estab-
lished the Federal commodity distribution program in 1935.
The Commonwealth of Puerto Rico has been authorized to
participate in this program since 1958 (see 7 U.S.C.
1431b). Under the present program, agricultural commodities
acquired by the Department of Agriculture are donated for use
principally in school feeding programs, charitable institu-
tions, and feeding projects for the elderly authorized by
title VII of the Older Americans Act of 1965 (42 U.S.C.
3045 et seq.). Until 1975, when the Federal food stamp pro-
gram began operating throughout the Commonwealth, commodities
were also distributed to needy families in Puerto Rico.

     The Commonwealth's Department of Education currently
administers the commodity distribution program in Puerto Rico
under an agreement with the Food and Nutrition Service. Both
the Department of Agriculture's Agricultural Stabilization and
Conservation Service and its Agricultural Marketing Service
acquire commodities for donation and distribution to the
various food program outlets. The Agricultural Stabilization
and Conservation Service ships donated commodities to the
Commonwealth as well as to other participating States and
agencies.

     Federal commodities shipped to Puerto Rico come under
the Department of Education's control when they are delivered
from the port of entry to a "store-door" warehouse. Of the
Department of Education's 14 warehouses handling donated
commodities, 5 are designated store-door delivery points
because they initially receive the commodities donated to the
Commonwealth and then distribute some of them to the other
warehouses. All 14 warehouses distribute commodities to
eligible local outlets. These outlets include schools,


                              3
'A-51604



charitable institutions, and elderly feeding projects.
Commodity distribution to local outlets is based on program
participation reported by each user.

     In fiscal year 1976 the Commonwealth received about $10
million in federally donated commodities. These commodities
benefited approximately 520,000 school children, 16,000
persons served by charitable institutions, and 4,000 elderly
persons participating in title VII projects.
MONITORING BY THE FOOD AND NUTRITION
SERVICE HAS NOT BEEN ADEQUATE

     The Service's monitoring of commodity distribution pro-
gram operations in the Commonwealth was generally limited to
(1) reviews of Commonwealth commodity need estimates, (2)
comparisons of beginning and ending commodity inventory
balances shown on monthly and yearly Commonwealth reports,
and (3) occasional visits to the Commonwealth. The results
of these visits were not documented. We were told that the
visits generally consisted of discussions of whatever problems
Commonwealth officials were having at the time. The Service's
last comprehensive, systematic evaluation of the Commonwealth's
program was in 1973. Although Service regional personnel be-
lieved they probably should perform such evaluations about
every year, they said they did not have sufficient staff to do
so.

      The Service is supposed to compare commodities received
 (as shown on the Commonwealth's monthly reports) with commod-
 ities shipped (as reported by the Agricultural Stabilization
 and Conservation Service), and resolve any differences. The
 Food and Nutrition Service advised us, however, that it was
 not making this comparison because it did not have enough
 staff. Since it was not making this comparison, the Service
 did not know whether the Commonwealth had received and
 accounted for all of the commodities that had been shipped.

      Our brief scanning of the Commonwealth's monthly reports
 for fiscal year 1976 revealed a further lack of depth in the
 Service's program monitoring. We noted that a loss of $64,000
 in butter was indicated but not explained, as the Service re-
 quires. Further inquiry showed that the butter had originally
 been designated for needy families but, when that program was
 phased out, it was redesignated for use in the school lunch
 program. The butter spoiled, however, before it could be
 used. When we informed the Service of the situation, it began
 followup to determine if a claim should be established.



                               4
'A-51604



     We believe the Service's monitoring of the Commonwealth's
administration of the commodity distribution program is not
adequate to insure that all commodities shipped are properly
received and accounted for or that Commonwealth controls are
adequate to detect and prevent spoilage or theft. -

COMMODITIES ADEQUATELY ACCOUNTED FOR
BUT COMMONWEALTH CONTROL NEEDS IMPROVEMENT

     The Department of Education's warehouse inspections did
not include verifications that commodity receipts were prop-
erly recorded and shipments shown on records were acutally
made. Also, these inspections were infrequent and sporadic.
Although our test of actual warehouse records and procedures
indicated that donated commodities were adequately accounted
for at the time of our review, we believe that Commonwealth
control over these commodities needs improvement to insure
efficient, verified commodity distribution operations in the
future.

Commonwealth procedures for
controlling commodities

     Upon delivery of federally donated commodities to the
five store-door warehouses, warehouse managers verify that
the types and amounts of commodities shown on the shipping
bills of lading have actually been received. When this ver-
ification is complete, the Department of Education's central
office sends the Agricultural Stabilization and Conservation
Service a signed receipt.

     Commodities are stored and recorded on a first-in, first-
out basis. The amount of commodities in a warehouse at any
given time is shown on perpetual inventory records. All
receipts, transfers to other warehouses, adjustments, dis-
tributions to users, and disposition of spoiled commodities
are recorded daily by warehouse personnel. Actual shipments
of commodities to schools, charitable institutions, and
elderly feeding projects are documented by receipts signed by
local outlet personnel. These receipts are kept on file at
the various warehouses.

     Each of the 14 warehouse managers submits a monthly
summary of warehouse operations to Education's central office
showing receipts, transfers, distributions, and ending in-
ventories for both the Federal commodities donated to the
Commonwealth as well as the non-Federal commodities the
Commonwealth acquires on its own. The central office uses
these monthly summaries as the basis for Commonwealth reports



                              5
A-51604



to the Food and Nutrition Service on the use and present
inventory level of federally donated commodities.

Our test of warehouse records and procedures

     Commonwealth officials told us that, although operating
procedures for warehouse personnel were not in writing, these
procedures had become firmly established over many years of
warehouse operations and warehouse personnel were thoroughly
familiar with them. To test the adequacy of the procedures
and the consistency with which they were implemented, we re-
viewed in detail transaction records involving three popular
commodities (canned green beans, canned beef, and powdered
milk) and four warehouses (two store-door warehouses and two
others) during the last 3 months of 1976.   (See enc. I.)1/
We tested transactions from the time the three selected
commodities arrived in the Commonwealth, through warehouse
storage, to their ultimate distribution to eligible outlets.
To check the accuracy of the warehouse receipt, inventory,
and shipment records we were testing, we also counted the
quantities of the three commodities on hand at the four ware-
houses during February 1977 and verified selected shipments
by reviewing records at the locations to which the shipments
were made.

     In additional, abbreviated tests, we verified the amounts
of other commodities that inventory records indicated should
have been in storage at these and other warehouses by counting
the quantities of commodities actually on hand. Overall, we
made 54 counts of commodities to verify inventory records.
Both our detailed and our abbreviated tests disclosed only a
few transactional errors and discrepancies, the most signifi-
cant of which are described below.

     At the Bayamon warehouse (a store-door warehouse), the
4,224 cases of powdered milk in the warehouse were 32 cases
more than the records showed should have been on hand. Most
of the overage appeared to be accounted for when we noted
that, 2 months earlier, 2 shipments totaling 34 cases were
shown on the records but, according to supporting documents,
were not delivered. Apparently, the shipments were returned



l/In addition to making these detailed reviews of commodity
  transaction records at four warehouses, we asked warehouse
  personnel at seven other locations to describe the proce-
  dures they followed. These descriptions were generally
  consistent with the practices we observed at the four
  warehouses.


                              6
A-51604



to the warehouse.   The net shortage of two cases could not be
accounted for.

     At the San Juan warehouse, there were three errors in
recording shipments of canned green beans to users. One ship-
ment of six cases was recorded but not actually made, accord-
ing to supporting documents. Two other shipments totaling six
cases and three cans were made but not recorded.  There were
295 cases of green beans on hand in the San Juan warehouse at
the time of our count.

Warehouse inspections were not adequate

     The Department of Education's warehouse inspections were
(1) inadequate to insure that donated commodities were proper-
ly accounted for and (2) too infrequently and irregularly
scheduled to detect warehouse conditions and practices that
might contribute to commodity spoilage or theft.

     Education's central office conducted warehouse inspec-
tions, including comparisons of the quantities of commodities
shown on inventory records with quantities shown by physical
counts.  However, these inspections did not include verifi-
cation that receipts of commodities were properly recorded or
that shipments shown on records were actually made. Such
verification is crucial to the Commonwealth's procedures for
controlling commodity usage and inventories because warehouse
records are the basis for the summaries of commodity opera-
tions submitted by warehouse managers to the central office
each month. These summaries, in turn, become the basis for
the Commonwealth reports to the Food and Nutrition Service
on commodity operations in Puerto Rico.

     We believe it would have been relatively easy for errors
and improprieties in warehouse records to go undetected be-
cause only the balance of commodities on hand was verified
during central office inspections. Shipments to local users
could have been erroneously or improperly entered on records,
or warehouse commodity receipts could have been omitted to
make the book.balances correspond to quantities actually on
hand. These types of errors and improprieties, if undetected,
could undermine the Commonwealth's control over donated
commodities.

     Between July 1975 and November 1976, central office
personnel made only 20 inspections of Education's 14 ware-
houses. One warehouse was not inspected at all during this
period, and there were intervals of 10 months or more between
inspections at 12 other warehouses. During the first 11
months of 1976, 13 inspections were made--all during June,


                               7
k-51604



July, or August. The inspections showed only minor
discrepancies. However, without frequent inspections at
regular intervals, poor storage conditions or poor storage
practices could develop at the 14 warehouses and go unnoticed
over extended periods with no corrective action being required
or taken, increasing the possibility of commodity spoilage or
theft.

     Periodic warehouse inspections by personnel not directly
responsible for day-to-day warehouse operations are essential
elements of control over the approximately $10 million in
Federal commodities donated to the Commonwealth each year.
The many locations and users to which these commodities are
shipped also dictate frequent inspections at regular inter-
vals. Although our tests of actual transactions did not in-
dicate substantial errors or irregularities at the time of
our review, the Commonwealth should establish better control
for the future by using frequent, periodic, and independent
warehouse inspections (including verification of receipts and
shipments) to insure that donated commodities are properly
accounted for and to prevent spoilage or theft.

COMMONWEALTH STORAGE FACILITIES AND
PROCEDURES SEEMED ADEQUATE

     Warehouse facilities and commodity storage practices at
the time of our review seemed adequate to minimize the spoil-
age or theft of donated commodities under normal conditions.
Although the 11 warehouses we visited were warmer than the
Service recommends, there was no evidence of significant
spoilage. Storage facilities and practices at the schools,
hospitals, and elderly feeding projects we visited also seemed
adequate.

Our check of Department
of Education warehouses

     We checked 11 of the Department of Education's 14 ware-
houses, as well as 2 schools, 2 hospitals, and 2 elderly
feeding projects receiving Federal commodities.  (See
enc. II.) Some warehouses included more than 1 unit and we
therefore checked a total of 16 Department of Education
facilities. We used the Commonwealth's current inspection
form, the Food and Nutrition Service's food storage guide for
schools and institutions, and reports by the Department of
Agriculture's Office of Audit as criteria for evaluating the
adequacy of storage space, warehouse equipment, ventilating
systems and temperature controls, refrigerated storage space,
warehouse receiving and storage practices, insect and rodent
control, and physical security.

                              8
A-51604



     Our check of the warehouses showed the following:

     -- Equipment and storage space (both dry and refrigerated)
        were generally adequate to accommodate inventory levels
        normally on hand.

     -- Temperatures at each of the 16 facilities exceeded
        levels recommended by the Food and Nutrition Service.
        Recommended temperatures were 50 degrees to 70 degrees F
        for dry food storage area; we found temperatures of
        75 degrees to 90 degrees F. Despite these temperatures,
        we found no significant commodity spoilage. This lack
        of spoilage may be due, in part, to safety margins
        built into the temperature levels suggested by the
        Service as well as to the adequacy of the space main-
        tained between stacks of commodities, the natural air-
        flow through the warehouses, and the normal turnover
        of stored commodities. As mentioned previously, each
        facility used the first-in, first-out inventory method
        for distributing commodities.

     -- Most facilities were neat, clean, and, except for one
        facility where we noted termite trails on the walls,
        seemed to have no significant rodent or insect in-
        festation. In addition, each facility had periodic
        extermination and fumigation programs.

     -- Upon receipt of commodities, the facilities (1) checked
        the number and, where applicable, the weight of all
        containers and (2) randomly inspected individual con-
        tainers to check the quality of the contents.

     -- Physical security measures--including heavy-duty,
        locked doors; limited access procedures; and, at some
        warehouses, watchmen--appeared adequate to prevent
        theft.

     Our observations of storage facilities and practices at
the schools, hospitals, and elderly feeding projects we
visited were similar to those obtained during our check of
warehouses.

     Although Commonwealth storage facilities and practices
seemed generally adequate, we believe a problem could result,
particularly at the warehouses, if the present normal turnover
of donated commodities is disrupted.  If a disruption occurs,
high temperatures in the warehouses and reduced space between
commodity stacks might cause spoilage of backlogged commod-
ities--as happened in 1974 and 1975 during the phaseout of the
needy family program. This possibility makes it incumbent

                               9
A-51604



upon both the Food and Nutrition Service and the Commonwealth's
Department of Education to (1) maintain adequate surveillance
over the Commowealth's commodity distribution operations in
order to identify distribution problems early before they
become serious and (2) check the-effects on.donated commodities
of storage at temperatures above the suggested levels--partic-
ularly those commodities usually stored in refrigerated
facilities which are placed in nonrefrigerated warehouse areas
before distribution to recipient agencies.

Commodity losses

     In fiscal years 1975 and 1976 the Department of Education
attributed most of its losses--$27,110 and $328,631 respec-
tively--to the receipt of spoiled or deteriorating commodities
redesignated from the needy family progam to the school lunch
and other programs. In 1975 the Department attributed 75
percent ($20,215) and in 1976 99 percent ($325,224) of its
commodity losses to spoiled needy family commodities. The
remaining losses in 1975 ($6,895) and 1976 ($3,407) were
primarily attributed to weevil infestation and excessive heat.
     According to a Department of Education official, most of
the needy family commodites have now been distributed or, if
spoiled, have been disposed of.

CONCLUSIONS

     While our review of the Commonwealth's practices, proce-
dures, and controls over federally donated commodities (1) did
not disclose current instances of theft or excessive spoilage
and (2) indicated that the commodities were adequately
accounted for at the time of our review, we believe that both
Commonwealth control over donated commodities and Food and
Nutrition Service monitoring of the commodity program in the
Commonwealth need improvement to insure that the program there
does not deteriorate in the future. The Service needs to take
a more active role in overseeing the program. The Commonwealth
needs to improve its control over commodities by establishing
periodic, independent, and comprehensive warehouse inspections.

RECOMMENDATIONS TO THE
SECRETARY OF AGRICULTURE

     We recommend that the Secretary of Agriculture have the
Food and Nutrition Service improve the Federal commoditiy dis-
tribution program in the Commonwealth of Puerto Rico by

     -- reviewing monthly and yearly Commonwealth receipt, dis-
        tribution, and inventory reports more closely to insure

                             10
A-51604



          accurate, timely reporting and identification of both
          commodity losses and potential problems;

     -- reconciling, as required, monthly Commonwealth receipts,
        distributions, and inventories with commodity shipments
        reported by the Agricultural Stabilization and
        Conservation Service;

     -- conducting periodic evaluations and documented site
        inspections of the Commonwealth's receipt, storage, and
        distribution practices, procedures, and controls to in-
        sure their adequacy to account for donated commodities
        and minimize spoilage or theft;

     -- requiring the Department of Education to conduct more
        frequent, regularly scheduled warehouse inspections,
        including physical inventories and independent verifi-
        cation of warehouse receipts and shipments, to insure
        that (1) receipts are properly recorded and recorded
        shipments are actually made and (2) conditions and
        practices contributing to the spoilage, deterioration,
        or theft of donated commodities are promptly detected
        and corrective actions taken; and

     -- requiring the Department of Education to closely
        monitor the condition of donated commodities stored at
        temperatures above suggested levels--particularly those
        commodities removed from refrigeration and stored in
        nonrefrigerated warehouse space before distribution to
        recipient agencies. The Department of Education's
        monitoring should be checked during the Service's
        periodic site inspections recommended above.

AGENCY COMMENTS

     Officials of the Commonwealth and the Food and Nutrition
Service reviewed this report. Certain factual material in the
report has been revised based on their comments. Both the
Commonwealth and the Service generally agreed with our con-
clusions and recommendations and said that a number of actions
were planned to carry them out. The Service, in particular,
stated that it intended to:

     -- Meet with Commonwealth Department of Education officials
        immediately after our report is formally issued to
        discuss the report's findings and the need for intensi-
        fied program monitoring by the Department of Education.

     -- Schedule a follow-up review by the Service's regional
        office personnel no later than October 1, 1977, to

                                11
A-51604



          review the corrective action taken regarding our recom-
          mendations and those from a recent regional office
          evaluation of the Commonwealth's commodity distribution
          program. This evaluation was completed after the time
          of our review. The Service said the findings and
          recommendations in its evaluation were similar to ours.

     -- Plan quarterly follow-up visits to the Commonwealth so
        that regional office personnel can provide assistance
        in implementing the recommended improvements, with
        particular emphasis on warehouse records and storage
        conditions. In addition, the regional office will
        schedule an annual comprehensive evaluation of
        Commonwealth donated commodity operations.

     -- Review carefully the Commonwealth's monthly and yearly
        receipt, distribution, and inventory reports and recon-
        cile these reports with Agricultural Stabilization and
        Conservation Service shipping documents.

     -- Study the need for requiring a program monitoring plan
        to be submitted by all State agencies administering the
        commodity distribution program in order to help insure
        nationwide compliance with Food and Nutrition Service
        regulations and procedural instructions.



     As arranged with your office, we are sending copies of
this report to the Secretary of Agriculture and the House
Committee on Government Operations, the Senate Committee on
Governmental Affairs, and the House and Senate Committees on
Appropriations. We are also sending copies to the House
Committee on Education and Labor; the House Committee on
Agriculture; the Senate Committee on Agriculture, Nutrition,
and Forestry; and interested Members of Congress. Copies will
also be available to other parties who request them.




                                 Comptroller General
                                 of the United States

Enclosures - 2



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ENCLOSURE II                                       ENCLOSURE II



                   COMMONWEALTH OF PUERTO RICO

                 COMMODITY FACILITIES WE VISITED


DEPARTMENT OF EDUCATION WAREHOUSES:

     Bayamon (note a)

     San Juan (Catano)

     Caguas (note a)

     Arecibo (note a)

     Ponce (note a)

     Vega Alta

     Yauco

     Comerio

     Canovanas

     Mayaguez (note a)

     Aguadilla

SCHOOLS:

     Colegio San Gabriel--Puerto Nuevo

     A. B. Quinones--Moca

HOSPITALS:

     Centro Medico--Rico Piedras

     Hospital de Distrito--Fajardo

TITLE VII FEEDING PROJECTS:

     Centro de Actividades Multiples Para Ancianos--Bayamon

     Centro de Actividades Multiples Para Ancianos--Arecibo


a/Store-door delivery points.


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