NGFA National Grain and Feed Association : Implementation of New Feed Rules Discussed at AAFCO Meeting

Posted by David Fairfield on January 23, 2015

How regulatory officials will implement the new feed rules required by the Food Safety Modernization Act (FSMA) was a key topic discussed at the meeting of the Association of American Feed Control Officials (AAFCO) Jan. 13-15 in San Antonio, Texas.

During a special session conducted at the meeting, NGFA Vice President of Feed Services Dave Fairfield was the sole industry representative to participate in a panel discussion with individuals from state and federal feed regulatory agencies. They provide perspectives on issues associated with implementing the new FSMA-related rule that will establish regulations for current good manufacturing practice (CGMP) and preventive controls for animal feed and pet food.

Fairfield's remarks during the discussion focused on the need for the Food and Drug Administration (FDA) to issue guidance to provide further direction on how the agency expects industry to demonstrate compliance with the new regulations once published. In addition, Fairfield stressed that adequate time is needed to allow the industry to implement programs and practices that comply with new requirements.

Meanwhile, comments provided during the session by Dan McChesney, director of the Office of Surveillance and Compliance at FDA's Center for Veterinary Medicine, reiterated the agency's desire to have the new feed safety regulations apply to fully integrated livestock and poultry operations.

However, McChesney said such operations likely will be exempt from the new requirements because they are classified as "farms" under the agency's current regulatory definitions. McChesney noted revising FDA's definition of "farm" would be a complex process because any changes would affect numerous FDA regulations. As such, he said any potential revisions to the definition likely would need to be addressed in a separate rulemaking.

State officials during the discussion highlighted the potential that various states may choose to adopt or reference within their individual feed laws only certain aspects of FDA's new regulations, thereby potentially creating disparity on how the new requirements would be applied. To help address this issue, it is anticipated that AAFCO will consider revising its Model Bill and Regulations to incorporate FDA's new CGMP and preventive control requirements. Most states base their feed laws in part or in whole on the AAFCO Model Bill and Regulations.

FDA is under court order to issue both its final CGMP and preventive controls regulations for animal feed and pet food by Aug. 30.

AAFCO is the professional organization of federal and state feed regulatory officials, with which the NGFA interacts extensively. Among other things, NGFA feed industry members and NGFA staff serve as non-voting advisers to key AAFCO committees, and participated actively in the meeting.

Other significant issues addressed during the AAFCO meeting included the following:

• Animal Food Safety Preventive Controls Alliance: The Animal Food Safety Preventive Controls Alliance met to further its work on developing training and guidance materials to assist firms in complying with the anticipated requirements of FDA's CGMP and preventive controls regulations for animal feed and pet food. The goal of the effort is to make the materials available shortly after FDA publishes its final rule. Fairfield is chairman of the Alliance's animal food-related activities.
• Feed Ingredient Definitions and Approvals: The AAFCO Ingredient Definitions Committee voted to establish new tentative definitions for: 1) de-oiled corn distillers, 2) L-methionine, 3) hydrolyzed wheat protein, and 4) molasses hydrolyzed yeast. The committee also considered, but did not proceed, establishing new tentative definitions for dehydrated alfalfa meal or pellets and direct dehydrated alfalfa meal or pellets. In addition, the committee considered, but took no action on, deleting the existing definition for fat product feed grade.
• Mineral Guidelines: The Feed and Feed Ingredient Manufacturing Committee continued its work to update the guidelines for contaminant levels permitted in mineral feed ingredients that are published in the AAFCO Official Publication. It is anticipated that final proposed guidelines will be considered during the committee's next meeting to be held in August.
• Feed Labeling: The Feed Labeling Committee voted to eliminate the current requirement to include minimum zinc guarantees on the labels of swine feeds. In addition, the committee intends to review required label nutrient guarantees for dairy and beef feeds after revised National Research Council nutrient requirements for dairy and beef cattle are announced later this year.
• Pet Food: The Model Bill and Regulations Committee approved revisions to the AAFCO dog and cat nutrient profiles. In addition, the Pet Food Committee voted to conduct a pet food-labeling workshop in conjunction with the 2017 AAFCO mid-year meeting.

David Fairfield

Vice President of Feed Services Dave Fairfield manages the NGFA's activities pertaining to feed and feed ingredient manufacturing, and livestock/poultry integrator operations. Among other things, he directs the NGFA's highly acclaimed Model Feed Quality Assurance Program and distance-learning courses, and other feed-related educational and training programs. He also assists in membership recruitment and retention programs for the feed sector, and provides assistance to Affiliated Associations in addressing feed-related issues at the state level. He is the principal staff liaison to the Feed Legislative and Regulatory Affairs Committee and Feed Manufacturing and Technology Committee, and is a staff liaison to the Biofuels and Co-Products Committee.