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AFIA reiterates FSMA costs trump benefits

The American Feed Industry Association (AFIA) has submitted comments to the US Food and Drug Administration (FDA) on the Food Safety Modernization Act (FSMA)'s supplemental proposed animal food rules, flagging the cost as the lead concern if the rules are implemented as-is. The comment submission echoed comments AFIA submitted in March 2014 on the originally proposed "Current Good Manufacturing Practices and Hazard Analysis Risk-Based Preventive Controls for Food for Animals." Nineteen regional and state feed associations also signed on to AFIA's letter as a statement of their support.

"We recognize the inclusion of many of the industry's suggested changes by FDA to the proposed rules as they continue to reduce the cost of the implementation of the final rule," said Richard Sellers, AFIA senior vice president of legislative and regulatory affairs. "However, it is not enough. Our comments urge the agency to take additional steps to lower the rule's cost while strengthening any overall benefits to the animal food industry."

Other comments submitted by AFIA revolved around the language of the rule. The organization believes there is still language within the rule that could be confusing to industry despite its attempt in its March comments to offer alternative wording and definitions. AFIA urged FDA to more closely align with the agency's medicated feed CGMPs that have been in place for more than 40 years, as there is already an understanding and excellent compliance, according to FDA's own data.

"Compliance with the rules and the implementation period is still a large and looming issue with AFIA," said the comments. "We urge the agency to closely examine our request for changing FDA's one, two and three year implementation period for regular, small and very small businesses, respectively, and consider the two, three and four year approach AFIA has advocated in previous comments."

AFIA said it will continue to work with its membership and the industry as FDA moves forward in the comment review process. The final animal food rule is mandated by a court order to be published by Aug. 30, 2015.

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