1. Purpose:

   Shelf life extensions on The Exchange food and food commodities are always the exception and never the rule. However, The Exchange owned subsistence is government-owned and protection of the financial interests of the government must also be considered when performing serviceability evaluations.
   1. OCONUS: Due to the uniqueness of short shelf life items, lead time for ordering and shipping, troop rotations, and other challenges of managing food OCONUS, requests for a serviceability evaluation by local public health authorities for consideration of extending the shelf life of food and food commodities may be fairly routine in the Distribution Centers. These requests, however, should be much rarer at the installation level.
   2. CONUS: In CONUS requests for serviceability evaluations by local public health authorities for the purpose of extending the shelf life of food and food commodities should be an extreme rarity. When the rare exception arises in CONUS, the appropriate Division Vice President and the Office of the Director, Food & Drug Safety / Staff Veterinarian, HQ The Exchange must be contacted and informed of the circumstances leading up to the requirement for a serviceability evaluation and shelf life extension request prior to requesting such evaluations.

2. Definitions:

   1. Food & Food Commodities: The FDA defines food and food commodities as “food & food additives for man & animals; dietary supplements & dietary ingredients; infant formula; pet foods; beverages (including alcoholic beverages & bottled water); fruits & vegetables; fish &seafood; dairy products & shell eggs; raw agricultural commodities for use as food or food components of food; canned foods; live food animals; bakery goods, snack food, & candy; and packaging materials that come in direct contact with the food”. For the purpose of this policy, The Exchange follows the same definition for food as it applies to the products we carry.
   2. Serviceability Evaluations: Inspections performed by local public health authorities to determine the wholesomeness, condition, and / or fitness for intended use of food and food commodities.
   3. Shelf Life Extensions: Inspection and approval of extension of the expiration date for products reaching best by / sell by / freshest by / expiration / or other similar date conducted by the responsible veterinary or public health offices.
   4. Public Health Authority: Members of the Army Veterinary Service, Army Preventive Medicine, and USAF Public Health.

3. Types of Products requiring extensions:

   1. Retail Food Items: These are those that are sold to consumers through The Exchange Retail outlets such as Shoppettes, Main Exchanges, The Exchange Gas Stations, etc.
   2. The Exchange Food Service Operations: Products destined for operations such as fast food restaurants, school feeding programs, and The Exchange production facilities such as bakeries etc.
   3. Non-food Items: Public health / Vets do not inspect or extend non-food and beverage products such as health and beauty aids, tobacco products, or other non-food products.
      
      **Note: Under NO circumstance will OTC (over-the-counter) drugs, baby food, infant formula, or dietary supplements ever be extended. There may also be other food and food commodities (i.e. fluid milk products) that local public health authorities also ban from being extended.

4. Maximum allowable shelf life extensions:

   1. Retail Food Items: The length of an individual extension (i.e. one week, two weeks, 30 days, etc.) of retail foods and beverages will be worked out between The Exchange manager and the Public Health Authority or their designated representatives. A single extension or combined total of multiple extensions will not exceed a total of 60 days without The Exchange manager receiving prior approval from the Vice President, Specialty Stores-Consumables Division, HQ, The Exchange. Although The Exchange’ intent is not to offer retail food and beverage products for sale after they have exceeded manufacturer’s shelf life, it is understandable that this may be necessary from time to time.
   2. OIF / OEF Retail Food Items: Due to the unique challenges of transporting food and food commodities into a war zone in a timely manner, the 60 day retail food extension limit does not apply to retail foods and beverages in OIF / OEF or any other future war zone. In these locations, product may be extended as long as it is wholesome and fit for its intended use.
   3. The Exchange Food Service Operations: Product destined for The Exchange food service operations and The Exchange production facilities that is wholesome and in good or excellent condition should always be extended. The length of an approved individual extension and any subsequent extensions on the same product will be worked out between The Exchange manager and the Public Health Authority or their designated representative(s) and should be based on product wholesomeness, quality (fitness for its intended use), and safety.
   4. Shelf Life Extension Reference Document: DLAM 4145.12 may be used as a reference to assist in determining length of extension for The Exchange products being inspected at the end of labeled shelf life. The Exchange products may always be extended to reach the shelf life listed in DLAM 4145.12 for similar or like product provided that conditions of wholesomeness, condition, and quality are met and that packaging and storage conditions are capable of protecting the product during continued storage. ADDITIONAL extensions should also be made so long as product meets above criteria of condition / quality / wholesomeness / packaging / storage capability and the responsible officer determines that he / she has the capability to utilize product while it still meets the above criteria.

5. Manufacturer Shelf Life Extensions of Frozen Foods:

   Some items shipped overseas may be produced in a chill package and then frozen by the manufacturer or The Exchange in order to extend the shelf life. In this case, the expiration date on the original label will reflect shelf life of the product in the chill state. The manufacturer provides guidelines for determining the new shelf life and handling of these products. A secondary label must contain an expiration date to reflect the shelf life in the frozen state. In some cases, a production date may be used to calculate the expiration date by adding the number of months the manufacturer has expressed as the shelf life in the frozen state. This is the case for some institutional foods and retail luncheon meats and franks going to Europe and Pacific Regions. Most of these retail products are sold overseas in a frozen state, however, some (i.e. Lunchables) may be thawed and then sold in a chill state. Institutional foods are typically thawed prior to preparation / serving. When frozen product is thawed a new expiration date, in accordance with the manufacturer’s recommendations and / or local regulatory requirements, must be affixed to the package. In any case, The Exchange managers and inspectors must be aware that this is normal practice with some products overseas and they must follow the manufacturer’s guidelines and / or local regulatory requirements when determining the expiration date of these products. Managers should have applicable manufacturer’s guidelines on file and will provide copies to Public Health Authorities upon request. If managers do not have these available, copies should be requested through the appropriate buyer at HQ, The Exchange.

6. Requesting Shelf Life Extensions:

   Although there may be exceptions, as a general rule, The Exchange CONUS Distribution Centers, retail facilities, food service facilities, and food production facility managers who deal with food and beverage products should seldom have to request inspections for the purpose of obtaining an extension of shelf life. OCONUS Distribution Centers may have a higher frequency of requests due to the uniqueness of managing a food supply and distribution chain overseas. If / When requests for inspection / extension are necessary The Exchange managers will contact the responsible veterinary or public health staff on the servicing installation. Since veterinary and public health staff cannot always respond on short notice, The Exchange managers should provide as much lead time as possible when submitting these requests.

7. Documenting Shelf Life Extensions:

   The Exchange requires a statement from inspectors indicating cause of unwholesomeness and / or description of factors causing products to be in less than good condition (i.e. unfit for its intended use) when product is condemned. Wholesomeness and condition condemnations (fitness for intended use) will only be signed by authorized inspectors in accordance with current Service / installation regulations and / or policies.

8. Product Condemnations:

   Product determined to be unwholesome or unfit for its intended use will be discarded IAW local procedures. The Exchange managers and buyers will determine if disposal of older products that remain wholesome and in good or excellent condition is appropriate to manage inventory.

9. Inventory Management:

   Concerns about inventory management should be addressed to local managers and to this office DSN 967-3604 or COM (214) 312-3604, but should not be used as a reason for condemnation or to deny extension. The Exchange will manage excess inventory by redistribution, discounting, or disposal as appropriate.

Thanks,
DON A. CULVER, DMV, MPH
LTC, VC
HQ The Exchange Staff Veterinarian
Food and Drug Safety Officer
(214) 312-3604; DSN: 967-3604