The American Feed Industry Association (AFIA) addressed the US Food and Drug Administration (FDA) during a Nov. 13, 2014 public meeting on the four re-proposed Food Safety Modernization Act (FSMA) rules. AFIA and the 575 members it represents submitted comments to FDA in March 2014 and are taking the additional time provided to prepare feedback on the supplemental proposed rules published Sept. 29, 2014.

AFIA said it remains concerned with items addressed in its original comments that are not fully addressed in the supplemental, particularly the differentiation between human food and animal food as well as the looming high costs of the rule for its members. "There are a few proposed CGMP provisions that still appear geared toward human food, not animal food," said Paul Keppy, AFIA government affairs specialist. "This is frustrating because the spirit of the law clearly allows for treating animal food and human food regulations differently. On the other hand, there are places where animal food is left out of important rules."

Keppy said the additions in the supplemental represent significant cost increases. He said FDA's own numbers in the original Preliminary Regulatory Impact Analysis (PRIA) concur, showing the cost of the rule to far exceed the benefit. "Feed is already 70% of the cost of raising an animal," said Keppy. "AFIA members want to make animal food safer, not more expensive. We continue to believe the costs can be reduced by a less prescriptive set of CGMPs and a strong approach to controlling significant hazards through CGMPs."

AFIA will submit comments on the proposed supplemental rules, which are due by Dec. 15.