Last month, I reported on some of the Dual declarations and
pertinent happenings from the annual meeting of the Association
of American Feed Control Officials (AAFCO), held in August.
This month includes news from other AAFCO committees that may
affect the petfood industry.
The Model Bill & Regulations Committee (MBRC) rectified
a matter regarding policy statement #29. If passed, this policy
would allow for certain claims relating to nutritive value of
ingredients on petfood labels without prompting the need for
supportive guarantees for those nutrients. Unfortunately, the
proposal to accept the policy came to AAFCO's board of
directors through the Pet Food Committee, not MBRC, so it was
turned down for procedural reasons. MBRC has now sent the
proposal to the board.
After discussion, MBRC accepted draft language to amend the
Model Bill, model animal feed and petfood regulations to
require net quantity declarations in both avoirdupois (e.g.,
pound, quart) and metric units. The Food and Drug
Administration had proposed amendments to federal regulations
to implement these requirements under the Fair Packaging and
Labeling Act in the mid-1990s.
For some reason, the proposed rule was never finalized, even
though dual avoirdupois-metric declarations have become the
standard. Assuming these amendments are eventually enacted by
AAFCO, they should help clarify the issue for both regulators
The Carbohydrate Working Group under the Feed Labeling
Committee (FLC) recommended that policy statement #1 stay as
is, effectively considering "carbohydrate" guarantees as
misleading in that the term is too broad to be meaningful to
However, the group also recommended that the AAFCO Feed Term
Definition for "starch" be amended to better describe its
nutrient content and that new feed term definitions be
established for "sugars" and "fructans." These steps would
allow for guarantees for these componentse.g., "sugars and
starch (max). 11%"thus providing a means to include
carbohydrate-related information on the label. While FLC
accepted the recommendations, this item has to go to the AAFCO
board for further action.
Also important to note, there's been no discussion to date
as to applying descriptive terms to these nutrient components,
e.g., what constitutes "low sugars and starch." So, without a
consensus on that aspect, the prudent approach initially would
be for any associated claims to be comparative in nature (e.g.,
"___% less sugars and starch than ___").
Raw milk requirements
FLC also accepted proposed amendments to impose labeling and
other requirements on raw milk products sold as animal feed.
New labeling requirements would include a very prominent "not
for human consumption" statement with additional warning
regarding the potential for presence of harmful microorganisms
in the product.
The new regulations would also require the products be
decharacterized via addition of food coloring, be sold only in
containers so they do not resemble human milk products and not
be sold at retail in the vicinity of human milk products. This
all appears to have been done to address some states' concerns
regarding sale of raw milk under the guise of animal feed but
in fact intended for human consumption.
While the feasibility of the minimum size of the required
warning statement was discussed, there was little other
objection. However, I do not believe any manufacturers that
would be directly affected by the new regulations were present
at the meeting.
Shift in oversight?
The Feed Manufacturing Committee put final touches on the
draft Model Good Manufacturing Practices (GMPs) for Feed and
Feed Ingredients document before sending it to the board and
MBRC. If eventually enacted, this new set of regulations would
represent a major shift in how animal feeds, including
petfoods, may be subject to oversight by feed control
Presently, only medicated feeds and low acid canned foods
are subject to GMPs. These new regulations would require that
all feed facilities meet specified manufacturing standards,
including how they process feeds, store and transport
ingredients and final products, maintain sanitation and keep
The Model Bill has always identified adulteration as a
prohibited act, but enforcement has largely consisted of
inspection and testing of the end product, with little
regulatory emphasis on the process by which the product got
there. The new regulations would now include process control
requirements as well as product requirements, and as I
interpret it, not following them could be considered evidence
of adulteration by itself.
For example, if an inspector found that a facility failed to
follow adequate sanitary procedures to minimize the risk of
adulteration with pathogenic microorganisms, that finding could
be interpreted as a de facto sign of adulteration, even without
testing the end products. Even if my interpretation is
overreaching the regulations' intent, it's clear that firms
will be subject to a host of manufacturing stipulations that
weren't looked at with much importance before.
Not related to recalls
Development of these GMP regulations was initiated years
before the petfood contamination incident this year. Because of
that incident's unique circumstances, it's likely that even if
the regulations had been in place, they would not have
prevented the problem.
Regardless, these measures appear prudent and, in my
estimation, for the most part reflect the commonsense
procedures manufacturers should be following anyway for their
own protection, whether or not dictated by regulation.
The mid-year meeting addressed several regulatory matters affecting petfoods
Public meetings invited comments and provided updates
It gives more direct control to CVM in establishing and maintaining ingredient definitions
The intent was to educate regulators and industry about the Model Pet Food Regulations
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