Posted April 1, 2014
 
The comment period for the FDA’s Food Safety and Modernization Act (FSMA) proposed rule on “Current Good Manufacturing Practice and Hazard Analysis and Risk-Based Preventative Controls for Food for Animals” closed on Monday, with several groups commenting, according to a Feedstuffs article available here
 
The proposed rule, available here, seeks to assure that food for animals is safe and will not cause illness or injure animals or humans.  The rule would require certain facilities to establish and implement hazard analysis and risk-based preventive controls.  In addition the rule would establish requirements for current good manufacturing practices in manufacturing, processing, packing, and holding of animal food. 
 
The American Feed Industry Association (AFIA) commented that it “strongly supported development and passage of the FSMA.”
 
The National Grain and Feed Industry Association (NGFA) commented that “the agency’s proposal would add unnecessary requirements that cause industry to direct scarce resources towards complying with regulatory obligations that will not serve to benefit the safety of animal feed and pet food.”
 
Both groups commented that FDA’s requirements for animal and pet food should differ “significantly from those established for human food.”
 
“AFIA is concerned that FDA has failed to clearly delineate the human food rules from the animal food rules as Congress intended.  Both the intent and sometimes the language used in the statute requires a separation of the rules,” the group commented.
 
The NFGA opposed the use of the term “contamination” in the proposed rule, commenting, “We strongly believe that FDA’s regulation cannot rightfully focus on avoiding and preventing ‘contamination,” when that term has no defined meaning in the regulatory context.  As such, we urge FDA to replace the term ‘contamination’ throughout the proposed regulation with the term ‘adulteration.’”
 
Breweries also expressed concern that the proposed rule would limit their ability to supply leftover grain to farmers, according to an article by the Chico ER available here.

 

For more information on food safety, please visit the National Agricultural Law Center’s website here.
 
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