While the Food Safety Modernization Act (FSMA) overall and, specifically, its recently proposed preventive control rule for animal feed represent a paradigm shift in how petfood will be regulated, the petfood industry has a rare -- if rushed -- opportunity to have a say in how the final rule will read. Yes, believe it or not, the US Food and Drug Administration (FDA) wants your input.
This week both the Pet Food Institute (PFI) and American Feed Industry Association (AFIA) held webinars on the proposed preventive control rule for their respective members. During both webinars, Daniel McChesney, PhD, director of the Office of Surveillance and Compliance for FDA's Center for Veterinary Medicine, presented key elements of the proposed regulation and, notably, stressed the facts on which FDA is seeking industry input and feedback. Actually, he did the same during PFI's and the National Grain and Feed Association's 2013 Feed and Pet Food Joint Conference in September. The third time's the charm for me; I believe McChesney (and his agency) truly want that feedback and isn't just playing lip service and telling the feed and petfood industries what he thinks they want to hear.
The catch is, there's not much time for understanding what's proposed in the rule, let alone for giving cogent feedback by the current deadline of February 26, 2014. “This is really the first major overhaul of animal food regulations,” said Leah Wilkinson, AFIA director of ingredients, petfood and state affairs. “It’s really the first overhaul that’s been there in decades. So it’s a monumental task to try to get through all of the different regulations that are proposed, especially because this is the first time that current good manufacturing practices (GMPs) are going to be established for non-medicated feed."
AFIA, PFI and other groups have filed requests to extend the deadline for comments to the proposed rule. All these organizations have also been meeting with FDA throughout the rule-making process and will no doubt file comments that represent a good portion of their respective industries' concerns and desires. But industry professionals can give their own responses. Where should you start?
First, learn as much about what's in the proposed regulation as you can. Resources include:
- FDA's web page about the rule;
- The proposed rule itself (this is also the page that leads to where you can post comments);
- An analysis of what the rule means for petfood by David Dzanis, DVM, PhD, DACVN, in his latest Petfood Insights column;
- Another free webinar this week, on Friday, December 13, this one hosted by TraceGains.
Further information is likely to keep coming, especially as the February 26 deadline draws nearer (if it doesn't change). Even past the deadline, Petfood Forum 2014 will feature a session on the new rule once finalized and what petfood manufacturers must do to comply. (The session will be presented by Jason Vickers, section head of product safety and regulatory affairs for Procter & Gamble Pet Care and also co-chair of PFI's FSMA working group.)
If you feel strongly about how the final rule will read -- or will be responsible for ensuring your company's compliance -- now's the time to learn about the regulation and provide your input to help shape it.