The Pet Food Institute has submitted comments to the US Food and Drug Administration on the proposed regulation for petfood and animal feed safety. Formally called "Current Good Manufacturing Practice and Hazard Analysis and Risk-Based Preventive Controls for Food for Animals," the proposed rule outlines requisite elements for food safety plans for implementation by manufacturers of food for animals.

The comments are the culmination of more than 3,000 hours of engagement in work sessions by representatives of PFI member companies and PFI staff in meetings and on conference calls over many months. "This was a tremendous, cooperative effort," said Duane Ekedahl, president of PFI. "Never before has the petfood industry come together in quite this way, and worked so closely to reach consensus on very complex and important issues."

Topline points made in the PFI comments include:

• The proposed regulation should reflect the Congressional intent specified in the statute requiring that the rules be based on science and risk analysis;
• There should be one animal food regulation applicable to all animal food categories;
• The rule should apply to all petfood and animal feed companies, and there should be no exemptions based on the number of employees or the volume of sales;
• FDA should develop and implement training for animal food producers and FDA officials to ensure smooth implementation of the rule when finalized.

The proposed rule is based upon a similar rule for human food that was proposed by FDA in January 2013. The PFI comments note the surprise of the industry on the similarities between the two proposed rules, particularly because two international standards exist that were specifically developed for animal food-Publicly Available Specification 222 (PAS 222) and the Model Current Good Manufacturing Practices (CGMPs) of the Association of American Feed Control Officials-and do not appear to have been incorporated into the proposed rule.

"PFI urges FDA to provide sufficient discretion in the regulation before it is finalized to account for the wide variety of animal food production methods and practices," said Ekedahl. "We believe the animal food sector should be granted ample time to become familiar with CGMPs before they are required, as was the case for the human food sector."

CGMPs have been recommended by FDA for human food production for several decades, but they were not set to be required until publication of the human food in 2013. For animal food, CGMPs are a relatively new concept and had not been defined by FDA until now. Ekedahl said that the human food sector had many years to become familiar with CGMPs before they were required, whereas petfood and other animal food companies are being required to comply with CGMPs at the same time they are being introduced.

The proposed rule was open for public comment for a far shorter period of time than its human food counterpart-five months versus nearly 11 months for the human food proposed rule. The deadline to submit comments was March 31, 2014. PFI says it will continue its constructive engagement with FDA to encourage finalization and implementation of a regulation that is science-based and facilitates the production of safe petfood.