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NGFA seeks to change proposed rule on petfood, animal feed

The National Grain and Feed Association (NGFA) during a recent public meeting urged the US Food and Drug Administration (FDA) to make significant changes to its proposed rule that would establish for petfood and animal feed new requirements for current good manufacturing practices (CGMPs) and hazard analysis and risk-based preventive controls.

The FDA conducted the public meeting to receive stakeholder feedback on four major re-proposed rules associated with its implementation of the Food Safety Modernization Act (FSMA). The four re-proposed rules address produce safety, CGMPS and preventive controls for human food, CGMPs and preventive controls for petfood and animal feed, and foreign supplier verification programs.

The FDA issued the reproposed animal feed rule on Sept. 29, 2014 to provide the agency's current thinking on requirements after its review of comments received in response to its original proposal issued in 2013. The NGFA submitted extensive comments on the 2013 proposal, and recommended that FDA make major changes and re-propose the rule for additional stakeholder comment given the very significant nature of the regulations, and the extent of changes recommended by the NGFA and other stakeholders.

During the public meeting, Max Fisher, NGFA director of economics and government relations, said he commended FDA for re-proposing the rule and allowing additional comment. But Fisher said the NGFA remains concerned that "many of the proposed CGMP provisions continue to mirror those established for human food, and do not reflect the realities associated with feeding animals, nor are they necessary to assure the safety of feed products."

In prior statements to FDA, the NGFA has urged the agency to develop final requirements that are practical, achievable and serve to benefit the safety of petfood and animal feed. In doing so, the NGFA has cautioned that adding unnecessary regulatory burdens and costs would undermine the industry's ability to serve the animal agriculture industry and divert finite resources away from effective practices that already are assuring a safe and abundant supply of petfood and feed.

"The NGFA requests that FDA carefully consider the economic impact of its proposed requirements and weigh the extensive costs against anticipated benefits, which the agency has yet to quantify," said Fisher. The NGFA's economic analysis of FDA's original proposal indicated the requirements would cost petfood and animal feed facilities more than US$500 million annually—approximately four times more than estimated by FDA.

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