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First, the good news for petfood safety: The US Food and Drug Administration (FDA) seems to have carefully considered comments it received on the Current Good Manufacturing Practices and Hazard Analysis and Risk-Based Preventive Controls for Food for Animals rule it proposed as part of the Food and Safety Modernization Act (FSMA) and issued in October 2013. In fact, the agency is even proposing revisions to the rule—along with four others under FSMA—based on that feedback.
The bad news? According to the American Feed Industry Association (AFIA), complying with the rule will likely still be costly for many petfood and feed companies, especially in comparison with any benefits received. “FDA seriously underestimated the cost of the proposed rule and the additions within this re-proposal have the potential to drive that cost up even further,” said Richard Sellers, AFIA senior vice president of legislative and regulatory affairs. “AFIA is committed to advocate for a final rule that is appropriate for the low risk that animal food presents. The cost-benefit ratio is nearly 20-to-1, and federal laws require the costs to reasonably approximate the benefit.”
Still, I find it encouraging that FDA listened to input from industry, the public and others and, seemingly, took it to heart. AFIA and other organizations and stakeholders, such as the Pet Food Institute, invested a good deal of time, effort and resources in reviewing, discussing and responding to the original proposed rule. Even AFIA concedes that, at first review, FDA incorporated many of the changes the feed organization recommended in its comments on the originally proposed rule.
What are those changes? Some key revisions, according to FDA, are:
Other revisions involve further development of withdrawal of qualified exemptions process, proposed language for economically motivated adulteration and feed mills associated with farms.
FDA also issued compliance dates for the preventive control rule for animal food; it’s not clear if these are proposed dates or simply a notification of the mandated dates:
Finally, and perhaps most importantly, public comment on the re-proposed rule open September 29; FDA will accept comments for 75 days. You can comment at Regulations.gov.