The American Feed Industry Association (AFIA) has submitted comments to the US Food and Drug Administration (FDA) on the proposed Sanitary Transportation of Human and Animal Food rule.
The FSMA requires FDA to create regulations for shippers, carriers by auto transit or railway vehicles, and receivers to use sanitary transportation practices to ensure food—including animal food—being transported does not become contaminated. The goal of the sanitary transportation rule is to ensure that transportation practices do not create food safety risks.
Although AFIA openly agrees with FDA in certain areas, such as allowing "the industry to continue to use bulk transport equipment in accordance with best practices without limiting industry, by rule, to hauling non-food exclusive of or preceding any food items," the organization listed several points of difference in their nine pages of comments for FDA to review.
In the rule, FDA proposed exemptions for farms and shelf stable products. AFIA suggested those exemptions be broadened to include intra-company shipments (when the company maintains control of the product), short haul transports (as defined by the US Department of Transportation) and finished product or raw agricultural commodities transported from facilities to farms in dedicated vehicles. AFIA also commented that FDA should lower the recommendation on the definition of "non-covered business" to engage businesses with transportation operations with less than US$10,000 in total annual sales.
The organization also made note of the temperature control measures and hand washing facility requirements originally proposed are not appropriate across the animal food industry and would induce unnecessary cost on the industry without improving the safety of animal food products. AFIA would like these requirements to be removed for animal food.
The comments on the proposed sanitary transportation rule were drafted by AFIA members who volunteered as part of a work group to review the rule. FDA, under a court ordered deadline, must issue the final rule on this topic by March 31, 2016.