ARLINGTON, Va. -- The American Feed Industry Association has always set feed/food safety as its highest priority. Since the association's birth in 1909, AFIA and its predecessor, the American Feed Manufacturers Association, focused the majority of its efforts on programs designed to ensure feed safety.
In 2004, AFIA launched its hallmark Safe Feed/Safe Food Certification Program based on the common innovative practices AFIA members agreed the industry performs and should continue to perform to ensure feed safety. These practices are critical in the production of safe meat, milk, eggs and fish, as feed represents upwards of 70 percent of the cost of producing these food products.
Congress has focused on amending the country's food/feed safety laws for the last four years, and AFIA has been an active player in securing agreements that ensure legislation intended to increase protections of human food production is appropriate to achieving the same goals for feed and pet food, but is appropriate to the feed industry and its operations.
Adapting to FDAAA
In addition to activity on Capitol Hill, the feed industry continues to adapt to the Food and Drug Administration Amendments Act of 2007. This measure, commonly called the FDAAA, created the Reportable Food Registry. The RFR requires companies to report contaminated or adulterated feed or food products, pet food or related ingredients which they determine have a reasonable probability of causing serious adverse health consequences or death in humans or animals. Such reports are required within 24 hours of a company determining that its product has such a probability.
FDAAA also encourages FDA to publicize such reports when it deems it is in the interest of the public's health. Since the initiation of the RFR, few feed safety incidences have been reported.
Also required under FDAAA is a mandate the agency write rules for pet food processing and ingredient standards and update pet food labeling and nutrition. These requirements present FDA with some challenges. For example, pets are not defined in the law -- though many believe the term means only dogs and cats -- but this is not stated explicitly.
Also, "ingredient standards" are not defined in FDAAA. Nearly all commercial state feed laws require use of ingredient definitions on feed labels accepted by the Association of American Feed Control Officials in the organization's most recent Official Publication. AFIA believes FDA should adopt AAFCO's definitions of ingredient standards, but FDA's legal counsel does not believe this is possible under current federal law. For instance, integrated poultry feed is exempt from these state provisions, but ingredient sales to poultry feed mills must comply with state labeling provisions.
As FDAAA evolves and regulations implementing it are written, Congress has worked for more than four years on more comprehensive food/feed safety legislation that would dramatically change the way livestock feed, pet food and ingredients are regulated for decades to come.
This legislation would also shift the way FDA would approach feed/food safety. The focus would be more on risk management and prevention. Basically, the legislation requires companies to identify all reasonable hazards and develop a written risk-based management plan to eliminate, manage or reduce the hazards to acceptable levels. FDA would have access to and could review this plan. When enacted, this legislation will require many years of rule-making to get to the final product.
AFIA's program
The pending federal legislation is in line with the philosophy and process adopted by the AFIA Safe Feed/Safe Food Certification Program, a unique third-party-verified program under which nearly 400 facilities in the U.S. and Canada have been certified to date. In fact, FDA officials praise the Safe Feed/Safe Food program, and one official said the program goes beyond what even the human food industry is doing. Another FDA official said the agency could not have created a better program.
The Safe Feed/Safe Food program follows the same model Congress has developed: Hazard identification, risk-control programs and ranking of risks.
The European Union has taken food/feed safety one step further by requiring mandatory Hazard Analysis and Critical Control Points programs for food, feed and pet food. Although effective in 2007 for domestic plants and in 2008 for imported products, the EU does not have a method to inspect foreign facilities.
A number of EU-wide certification programs have arisen, as the EU rules allow operating and compliance codes to be drafted by industry groups and reviewed and recognized by the European Commission. AFIA has allied itself with one EU code for export purposes.
The European Union Association of Specialty Ingredients and their Premixtures, known as FEFANA, in 2006 developed an EU-recognized program called the European Feed Additives Premixtures and Quality System, or FAMI-QS, to comply with EU regulations on feed hygiene.
In 2009, AFIA signed an alliance agreement with FAMI-QS to develop a U.S.-branded version -- the International Safe Feed/Safe Food Certification Program -- providing a recognized program for exporters to the U.S. and from the U.S. to Europe within the Safe Feed/Safe Food program. Both of these programs may be viewed at the Safe Feed/Safe Food web site at http://www.safefeedsafefood.org. We believe this is the future of global feed safety.
AFIA will always play an active role in advising Congress, ensuring AFIA's priorities are known and understood, and will comment on and shape any future feed safety rule-making process by FDA.
Although there will be costs and resources required by each feed mill, ingredient facility or pet food plant, it is clear this is what the public and government demand. AFIA believes the feed industry is well-equipped to deal with these new rules and procedures within the well-established, domestic Safe Feed/Safe Food Certification Program.
The feed and associated industries will have little problem in complying with the new requirements and provisions as they evolve. There have been very few contaminant events in feed in the past, and this legislation and future regulations will assure even fewer episodes in the future.
Richard Sellers is the American Feed Industry Association's vice president of feed regulation and nutrition. More information can be obtained at http://www.afia.org or http://www.safefeedsafefood.org.
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