Pet Food Regulations
On October 26, 2007

AAFCO news, part 2

Committees discussed key proposals such as a possible shift in the oversight of animal feeds

Dual avoirdupois-metric declarations have become the standard.

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 and industry.

Carb considerations

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 the consumer.

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 officials.

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 records.

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.

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