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Pet Food News / Pet Food Safety
On March 31, 2014

AFIA submits animal food rule comments to FDA

Nineteen regional, state feed associations lend signed support to 100-plus pages of notes

The American Feed Industry Association (AFIA) has submitted comments to the US Food and Drug Administration on what AFIA describes as the most massive overhaul of animal food industry regulations since 1958. The comments, which address the Food Safety Modernization Act "Current Good Manufacturing Practices and Hazard Analysis Risk-Based Preventive Controls for Food for Animals" rule, are 100-plus pages in length and cover five major areas.

Nineteen regional and state feed associations also signed on to AFIA's letter as a statement of their support.

"AFIA and its membership are extremely satisfied with the comments generated during the brief, yet productive, comment period," said Richard Sellers, AFIA senior vice president of legislative and regulatory affairs. "If more time had been allotted, we would have ideally provided FDA with more examples of the overall impact of the proposal. However, given our time constraints, AFIA focused primarily on how this rule would impact the many varied segments of the industry to strive for practical and easily understood requirements by the industry, FDA and state investigators that will inspect and audit these new requirements."

One major area of AFIA's comments is its focus on Current Good Manufacturing Practices, or CGMPs. The organization stated CGMPs should be "more practical and less prescriptive," which will allow its members and the industry as a whole to be more innovative and have a better understanding as it is the first time many companies will use CGMPs. AFIA is also requesting FDA to simplify terms and concepts used throughout the rule such as replacing "utensils" with "tools" or "sanitation" with "cleaning," and seeks assurance the rules are dedicated to the animal food industry, not the human food industry, which they originated from.

The organization's comments addressed FDA's lack of differentiation among various types of animal food facilities. AFIA stated without clarity in the rules, inspections/audits of the facility would be "related to the facility's animal food safety plan and not some predetermined idea about the expectations of a plant related to the highly subjective language of the proposed rules."

AFIA also focused largely on the overall language of the hazard analysis and preventive controls rule. "We are asking FDA remove all HACCP references and requirements throughout the rule, including references to 'hazards that are reasonably likely to occur' and return to the statutory language of 'known or reasonably foreseeable hazards'," said Sellers.

AFIA intends to work with its membership and the industry to submit ongoing comments to FDA as the agency moves forward in the comment review process. The intention of the "Current Good Manufacturing Practices and Hazard Analysis Risk-Based Preventive Controls for Food for Animals" rule is to continue to ensure safe animal food, and AFIA will continue to work comprehensively with FDA to achieve this overall goal. The final animal food rule is mandated by court order to be published by Aug. 30, 2015.

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