The American Feed Industry Association (AFIA) has submitted comments to the US Food and Drug
Administration (FDA) applauding the agency's proposal to exempt animal food from the
Food Safety Modernization Act (FSMA)'s intentional adulteration rule. The
"Focused Mitigation Strategies to Protect Food Against Intentional Adulteration"
would require registered domestic and foreign food facilities to address
hazards that may be intentionally introduced by acts of terrorism.
AFIA said in its comments that there are significant
differences between risks in human food and animal food, particularly when
dealing with intentional adulteration, which is recognized by Congress in the
Food, Drug and Cosmetic Act. "What is nutritious for a ruminant cow may
not be nutritious for a pig," said AFIA. "Sheep, for example, have an increased sensitivity
to copper. Risk varies between humans and animals as well. For example, humans
can be allergic to a host of things from peanuts to shellfish, while animals
simply do not have this same risk."
The creation of Section 420 in the FD&C Act
states FSMA requires FDA to establish regulations for facilities to review the
potential risk of intentional adulteration of food—further noted in Part C,
this applies only to human food. "AFIA fully supports FDA's findings and
proposed exemption of animal food in the intentional adulteration rule as we
believe it is Congress' intent," said Richard Sellers, AFIA senior vice
president of legislative and regulatory affairs. "FDA has indicated the
proposed rule's purpose is 'to protect food from intentional adulteration when
the intent is to cause large-scale public harm' and AFIA firmly believes animal
food has a significantly lower risk of impacting human health."
The final rule on intentional adulteration will
be published by May 31, 2016.
Public meetings invited comments and provided updates
Committees discussed key proposals such as a possible shift in the oversight of animal feeds
The mid-year meeting addressed several regulatory matters affecting petfoods
What you need to keep your manufacturing line clean, safe and contaminant-free
Processors should carefully develop, validate and implement an effective kill step to support production of pathogen-free petfoods
Safe, nutritious, tasty petfood requires careful handling and processing of raw meat ingredients
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