AFIA makes headway in regulatory compliance

The American Feed Industry Association (AFIA) hosted its Regulatory Training Seminar – a biennial event – in Arlington, Virginia, USA, on December 9-10, 2015. The training pinpointed regulatory hot topics affecting the U.S. feed industry including genetically modified labeling challenges, biosecurity and trade, as well as numerous training exercises.
Prior to RTS, AFIA hosted a one-day Food Safety Modernization Act Phase III training themed, “The Future is Now.”
AFIA’s legislative and regulatory staff members covered a variety of topics at the FSMA training including AFIA’s reaction to the animal food final rule and how to complete an animal food safety plan, current good manufacturing practices and what records are necessary for FSMA compliance. Dan McChesney, Ph.D., of the U.S. Food and Drug Administration Center for Veterinary Medicine, provided an overview of the animal food rule, touching on the Foreign Supplier Verification Program (FSVP) and third-party rules.
“Don’t look at the (FSMA) rules and say what do I have to do, but look at the rules and say what am I doing and see if there are gaps. You may be further along than you think,” McChesney said at the conclusion of his presentation.
The RTS training that followed also discussed numerous FSMA implementation aspects, exploring FSVPs and accreditation bodies, preparation for FDA inspection and the documentation process.
Keynote speaker Andrew Walmsley of the American Farm Bureau Federation discussed food policy issues currently up for debate in Washington, D.C., including genetically modified organisms. Walmsley continued to explain, “We have been genetically modifying food since we stopped being hunter-gatherers.”
Attendees also heard from various AFIA staff members and Bob Hahn and John Dillard from AFIA’s outside legal counsel, Olsson, Frank and Weeda; Dave Edwards, Ph.D., FDA-CVM; Rebecca Fecitt, U.S. Department of Agriculture’s Foreign Agricultural Service; April Hodges, Ph.D., FDA-CVM; Kristi Krafka, Kemin Industries; Angela Mills, Southern States Cooperative; Eric Mittenthal, North American Meat Institute; Ron Moser, Ph.D., JBS United; Eric Nelson, FDA-CVM; Dr. Jack Shere, USDA’s Animal and Plant Health Inspection Service; Kay Johnson Smith, Animal Agriculture Alliance; and Will Stone, USDA’s Agricultural Marketing Service.
AFIA will host another identical FSMA Phase III training at the International Production & Processing Expo on Jan. 27, 2016, from 8 a.m. to 5 p.m.

AFIA to host FSMA Phase III training

The American Feed Industry Association (AFIA) will host its second Food Safety Modernization Act Phase III training January 27, 2016, as part of the International Production & Processing Expo (IPPE) in Atlanta, Georgia. The one-day session will cover various components of the new law, published in the Federal Register on September 17, Current Good Manufacturing Practice and Hazard Analysis and Risk-Based Preventive Controls for Food for Animals.
The seminar is ideal for all employees involved in feed, ingredient and pet food manufacturing. AFIA staff experts and Daniel McChesney, PhD, of the US Food and Drug Administration’s Center for Veterinary Medicine, will address:

• Completing an animal food safety plan
• Current Good Manufacturing Practices
• Developing an effective supply chain program
• Foreign Supplier Verification Program and Third-Party Rules
• Records for FSMA compliance

AFIA’s next steps

“AFIA was ready for the release of the FSMA final rule and you can rest assured our staff is preparing to make the implementation process as smooth as possible,” said Henry Turlington, PhD, AFIA director of quality and manufacturing regulatory affairs. “This training will help plant managers, quality associates and feed industry personnel gain a better understanding of the animal food rule.”
You can register online or on site.
IPPE is expected to attract more than 28,000 attendees and is a collaboration of three trade shows — International Feed Expo, International Poultry Expo and International Meat Expo — representing the entire chain of protein production and processing. The event is sponsored by the American Feed Industry Association, US Poultry & Egg Association and the North American Meat Institute.

AFIA to host 9th annual Pet Food Conference

The American Feed Industry Association (AFIA) will host its ninth annual Pet Food Conference January 26, 2016, as part of the International Production & Processing Expo (IPPE) in Atlanta, Georgia. The education-packed conference is designed to inform pet food industry representatives about the latest industry initiatives, including speakers from government entities, private companies and universities.
Attendees will engage with a well-rounded cast of presenters to discuss industry issues including country of origin labeling, pet obesity trends, allergen research and the newly published Food Safety Modernization Act and its implications on the pet food industry.
“Every year attendees from around the world congregate at the Pet Food Conference to acknowledge, discuss and rectify pertinent issues affecting the pet food industry,” said Leah Wilkinson, AFIA director of ingredients, pet food and state affairs. “The conference offers an opportunity for industry professionals to unify and learn about the latest in the field.”
 IPPE is expected to attract more than 28,000 attendees and is a collaboration of three trade shows — International Feed Expo, International Poultry Expo and International Meat Expo — representing the entire chain of protein production and processing. The event is sponsored by the American Feed Industry Association, U.S. Poultry & Egg Association and the North American Meat Institute.

AFIA to host FSMA training session

The American Feed Industry Association (AFIA) will host a one-day Food Safety Modernization Act Phase III "The Future is Now" training on Dec. 8, 2015.
The session is part of AFIA’s 2015 Regulatory Training Seminar (RTS), which will be held at the Westin Arlington Gateway in Arlington, Virginia.
RTS provides an opportunity for regulatory professionals in the feed, ingredient and pet food industries to come together to develop the necessary skills to navigate through the regulatory maze. The program is ideal for regulatory directors with several years of industry experience and will cover advanced topics and regulatory strategies.
"It is important for regulatory professionals to have the opportunity for continued education, learning the latest changes in regulations and honing their skills by working through case studies," said Leah Wilkinson, AFIA director of ingredients, pet food and state affairs. "This seminar will help participants wade through regulations, ask questions, get answers and learn from each other's best practices."
 The interactive agenda consists of discussions with expert panelists about preparation for U.S. Food and Drug Administration inspections, training exercises concerning reportable food registry and recalls, how to work with state regulators and Association of American Feed Control Officials, and much more.

AFIA pleased with final rule on CGMPs for animal food

Upon the release of the Food Safety Modernization Act "Current Good Manufacturing Practices and Hazard Analysis and Preventive Controls for Food for Animals" final rule by the U.S. Food and Drug Administration, the American Feed Industry Association (AFIA) has provided the following statement based on its initial reaction and brief overview.
"AFIA is pleased with how transparent FDA has remained throughout this entire rulemaking process. This has been no easy endeavor for the agency and they should be commended. The rule's finalization will now allow AFIA to move forward with preparing our members and the industry for implementation of the largest change to animal food regulation since the 1950s.
"Upon brief review, AFIA is pleased FDA followed through with our request for a phase-in approach to implementation, giving all animal food manufacturing facilities additional time to execute CGMPs (Current Good Manufacturing Practices) first, followed by the hazard analysis and preventive controls. The phase-in process, as we have said all along, benefits everyone. It allows firms more time for adjustment to basic program requirements such as CGMPs before adhering to more complicated aspects of the final rule.
"AFIA is also pleased FDA recognized animal food is different from human food in revising the CGMPs to be more applicable to animal food facilities and addressing the hazards in our industry.
"Due to the adaptation of the phase-in approach and the revisions to the CGMPs, the animal food rule cost-to-benefit ratio is more realistic. Although AFIA maintains FSMA will always be a costly regulation, we acknowledge FDA's attempt to equalize the gap between the cost and the limited benefits in the final rule.
 "With the release of the rule, the clock starts ticking for the industry as we inch closer to the first implementation deadline in September 2016. AFIA will proactively be reading, studying and helping industry implement the rule at their facilities. We also plan to continue the conversation with FDA as this process moves forward to better understand FDA's intentions and ensure transparency."

AFIA adds new certifying body for FSC36 Safe Feed/Safe Food

The American Feed Industry Association (AFIA) recently added SGS North America as a certifying body for FSC36 Safe Feed/Safe Food. SGS is the fourth certifying body recognized by AFIA to complete FSC36 Safe Feed/Safe Food audits.
"We are excited to add a well-recognized company such as SGS North America as a certifying body for facilities seeking FSC36 Safe Feed/Safe Food certification," said Henry Turlington, AFIA director of quality and manufacturing regulatory affairs. "This addition to the certifying bodies already offered -- Eurofins, NSF International, and Validus -- provides our members and the total feed industry with a variety of choices for optimal food and feed safety."
FSC36 Safe Feed/Safe Food is administered by the Safe Quality Food Institute and is designed primarily for North American feed manufacturers and ingredient suppliers. The program promotes the fundamentals for compliance with the Food Safety Modernization Act.
"FSC36 is designed to help the industry prepare for the changes accompanied by the Food Safety Modernization Act," Turlington added.
SGS also completes the other Safe Feed/Safe Food certifications: FSC34 Manufacture of Animal Feeds; FSC32 Manufacture of Pet Food; and International Safe Feed/Safe Food. The certifying body is a world leader with 130 years of experience in food safety audits and certifications around the world and supports audits and certifications in a variety of quality and food safety systems in multiple industries.
 AFIA's Safe Feed/Safe Food Certification Program was launched in 2004 to promote quality and feed safety within the feed industry. The program is beneficial to both feed manufacturers and feed ingredient suppliers.

AFIA designs broadened biosecurity document

In the aftermath of the 9/11 terrorist attacks, the government asked animal agriculture industries to release guidelines to its manufacturing facilities regarding the protection of the nation's agriculture assets. The American Feed Industry Association (AFIA) developed the 2012 Bioterrorism Awareness Guidelines, which it recently redesigned as a broadened biosecurity document for the feed and ingredient manufacturing industries.
"During the last two years, AFIA discussed the development of a foreign animal disease risk model with the Animal and Plant Health Inspection Service, formed a working group and reevaluated our 2012 bioterrorism guide," said AFIA President and CEO Joel G. Newman.
"This is a tremendous resource for our members, and I greatly appreciate the leadership of this task force for developing a high-quality guidance document that will assist our members and the industry in the control of biological hazards. I especially appreciate the assistance of the associations that participated to provide insight and recommendations," Newman added.
The working group -- including scientists from the feed industry and representatives from the National Grain and Feed Association, National Pork Board, National Pork Producers Council and National Renderers Association -- rewrote the guide with a focus on protecting the feed industry's assets and ensuring the latest science was considered in order to protect AFIA's customers' premises and animals from the spread of animal disease.
The document's purpose is to provide feed and ingredient manufacturers with recommendations to develop a biosecurity plan to help control the potential spread of animal disease through the manufacturing, transport and use of feed and feed ingredients.
Each facility, location or business should develop a biosecurity plan based on the potential hazards and risks of occurrence within its processes. Procedures should be developed to ensure the plan is implemented and remains effective as situations change. The new guidance document focuses on the development of biosecurity practices for feed and ingredient manufacturers to control biological hazards that may contribute to the spread of animal disease.
 "We greatly appreciate the dedication and support of the 14 members and organizations that provided insight and recommendations on updating this document," said Dr. Henry Turlington, AFIA director of quality and manufacturing regulatory affairs. "We are confident the new guidance will help our industry deal with current animal diseases to become better prepared for the next animal health issue."

AFIA names new chair, directors, members

Members of the American Feed Industry Association's board of directors met May 12-13, 2015, to discuss top priority issues affecting the animal food industry and address those issues with legislators during the association's annual spring visit to Washington.
AFIA's board also recognized Dr. Alan Wessler, MFA Incorporated, for his leadership as its chair during the 2014-15 year, welcomed his successor, Rob Sheffer, Waycrosse, and announced its chair-elect and new directors, and elected new members to the organization's executive committee.
Sheffer is an active AFIA board member, serving since 2009, and has served on the executive committee since 2012.
Sheffer is the president and CEO of Waycrosse in Wayzata, Minn. Prior to transitioning to his new role, Sheffer served as the group director for Cargill Feed and Nutrition, where he was responsible for leading the U.S. retail and commercial feed business and providing strategic direction to Cargill Animal Nutrition. He holds a bachelor's degree from Cornell University and is active in the fight against global hunger.
Sheffer's one-year term began May 1.
In related business, the board voted to accept the nomination of Paul Phillips, Maxi-Lift Inc./Southwest Agri-Plastics, Inc., to become chairman-elect of the organization. Phillips will succeed Sheffer in May 2016.
The following individuals were elected to three-year terms on the AFIA board and began their service at the May board meeting: Eric Arnold, Bill Barr & Company; Cory Berg, QLF-Quality Liquid Feeds, Inc.; Roy Brister, Tyson Foods, Inc.; Jim Conway, Darling Ingredients; Mark Etienne, Potashcorp; Frank Goode, ILC Resources; John Howe, Manna Pro Products, LLC; Raj Lall, Vets Plus, Inc.; Chuck Loefer, ADM Alliance Nutrition, Inc.; Diane Loiselle, Hill's Pet Nutrition, Inc.; Joe Lucas, Phibro Animal Health Corporation; Mike Manning, The F.L. Emmert Company; Rod Paulson, CHS Inc.; Paul Phillips, Maxi-Lift Inc./Southwest Agri-Plastics, Inc.; Mike Rivard, International Ingredient Corporation; and John Thorpe, Kent Nutrition Group, Inc.
The six nominated individuals chosen as additions to AFIA's Executive Committee were approved: Kevin Baker, Valley Proteins, Inc.; Tim Belstra, Belstra Milling; Lisa Deverell, Land O'Lakes, Inc.; Lee Hall, Hallway Feeds; Dennis Hart, Diversified Ingredients; and Mindy Whittle, Monsanto Company.
 Jeff Cannon, Diamond V, and Ed Galo, Novus International, Inc., were elected as new trustees to the Institute for Feed Education & Research Board of Trustees by AFIA's board of directors. The existing eight trustees were reelected for a consecutive one-year term: Cathy Bandyk, Westway Feed Products, LLC; Marc de Beer, DSM Nutritional Products; Bruce Crutcher, Trouw Nutrition USA; Al Gunderson, Vita Plus Corporation; Dr. C. Ross Hamilton, Darling Ingredients; Dr. Wes Jamison, Palm Beach Atlantic University; Chad Risley, Berg+Schmidt American, LLC; and Eddie Wells, Milk Specialties Global. IFEEDER, created by AFIA in 2009, addresses the education and research challenges our U.S. food and feed production industries will face in the next 40 years and beyond, as the world's population grows by almost 2.5 billion people. The Executive Committee also renewed the appointment of Dean Warras, Phibro Animal Health Corporation, as IFEEDER's chair.

AFIA webinar to discuss Safe Feed/Safe Food

The American Feed Industry Association (AFIA) will host a Safe Feed/Safe Food webinar April 7, at 2 p.m. EST, to discuss its recent certification program updates. The webinar -- coordinated by the Safe Quality Food Institute -- will address the major changes to the FSC36 Safe Feed/Safe Food guidance document, how the changes will impact facilities and the purpose behind the newly revised guidance document.

Changes to the program are listed in the FSC36 Safe Feed/Safe Food guidance document and include updates to the registration and certification process, implementation process, introduction to the guidance document, guidance document for FSC36, glossary and use of seal or logo.
"The implementation process now provides facilities with a more user-friendly format by allowing auditors to spend additional time reviewing documentation and manufacturing processes, and streamlining the program to support compliance with the Food Safety Modernization Act. In addition, the ‘self-audit’ has been replaced with a ‘surveillance audit,’ which will be completed by the certifying body," said Henry Turlington, AFIA director of quality and manufacturing regulatory affairs.
The new FSC36 Safe Feed/Safe Food guidance document will assist facilities with designing, developing, implementing and maintaining a quality and feed safety program that complies with the desired requirements of the program, and assist auditors with auditing locations seeking certification for FSC36 Safe Feed/Safe Food. There are numerous examples provided within the guidance document to assist facilities with preparation for compliance with the requirements.
Register for the webinar here.

AFIA’s Safe Feed/Safe Food program updated to comply with FSMA

The American Feed Industry Association (AFIA) has updated the requirements of its FSC36 Safe Feed/Safe Food Certification Program to support the new requirements outlined in the Food Safety Modernization Act (FSMA) as well as help drive continuous improvement within a location's quality and feed safety program.

The updated requirements are listed as the FSC36 Safe Feed/Safe Food Guidance Document on the Safe Feed/Safe Food website and will take effect beginning March 1.
The goals of the updated document are to assist facilities with designing, developing, implementing and maintaining a quality and feed safety program that complies with the desired requirements and to assist auditors with auditing locations seeking certification for FSC36 Safe Feed/Safe Food. The guidance offers numerous examples to assist facilities with preparation for compliance of the requirements.
"The new guidance document provides a 'user-friendly' FSC36 Safe Feed/Safe Food certification," said Henry Turlington, AFIA director of quality and manufacturing regulatory affairs. "The new requirements improve the certification process that drives continuous improvement of a company's quality and food safety program. FSC36 Safe Feed/Safe Food certification is tool AFIA recommends because it supports compliance with FSMA."
The requirements for FSC36 Safe Feed/Safe Food certification include Current Good Manufacturing Practices for animal feed production as well as the requirements for an effective animal food safety program. FSC36 requirements support a risk-based management system that is documented and implemented by a facility (supplier) of feed or feed-related products to control animal food safety.
"The changes to the requirements to obtain FSC36 Safe Feed/Safe Food are minimal; however, the process for completing the certification has been streamlined to create a more user-friendly program," Turlington said.
"The number of elements has been reduced from 230-plus elements to 77 elements to allow auditors to spend more time reviewing documentation and manufacturing processes," he said. "And, FSC36 will now be a 'Continuous Improvement' program versus a 'Compliant' program."
Previously, facilities were required to comply with each element in order to obtain certification. The new process will allow the auditor to assess the effort and progress by a facility to comply with the FSC36 Safe Feed/Safe Food Guidance Document. The facility will be scored based on these efforts. The assessment process will provide the facility with better direction for continuous improvement and compliance with FSMA. The continuous improvement process is consistent with the FSC32 and FSC34 programs. This also allows AFIA to take advantage of the Safe Quality Food Institute tools more effectively.
"Another change to the program is the 'self-audit' is being replaced by a 'surveillance audit' (or remote audit) that will be completed by the certifying body (CB). The surveillance audit is an abbreviated version of the on-site audit and covers 'mandatory' elements," said Turlington. "The process and the quality of the audit will be greatly improved as the CB is more involved with the assessment and the facility provides supporting evidence only, and an on-site audit will continue to be completed every two years."
Safe Feed/Safe Food launched in 2004, with the first facilities obtaining certification the next year. Since the beginning of the Safe Feed/Safe Food program, the number of certifications has expanded to four options. FSC36 is the most popular certification and is considered the core offering of the program. In 2013, AFIA partnered with SQFI to administer the Safe Feed/Safe Food program.

AFIA food safety seminar clarifies FSMA regulations

Henry Turlington, AFIA director of quality and manufacturing regulatory affairs, talks compliance at the Food Safety Modernization Act—Building a Foundation for Compliance seminar.
The American Feed industry Association (AFIA) hosted a full-day seminar on the US Food Safety Modernization Act (FSMA) at the International Production & Processing Expo (IPPE) in Atlanta, Georgia, Jan. 28. Part of a three-phase training program, AFIA's Phase I Food Safety Modernization Act–Building a Foundation for Compliance seminar is designed to educate and update feed and petfood manufacturers and ingredient suppliers on the various components of the new US law. Nearly 120 expo attendees attended the seminar.
"The implementation of the proposed FSMA rules has been a huge undertaking for the feed and petfood industry, and it is important for industry professionals to understand how to comply with the different requirements," said Henry Turlington, AFIA director of quality and manufacturing regulatory affairs.
The seminar was part of a line-up of 25 educational programs at IPPE. The show attracted an estimated 30,000 poultry, meat and feed industry leader attendees from all over the world. IPPE had 1,288 exhibitors with more than 490,000 net square feet of exhibit space.
Turlington opened the AFIA seminar with an overview of newly proposed FSMA rules and what the regulatory changes mean to the feed industry. He discussed AFIA's recommendations for complying with the new law and how the organization will assist its members during the implementation process.
The seminar provided information on how to build a solid foundation with current good manufacturing practices, key components of a supplier verification program, what is required for an animal food safety plan and why having a plan is beneficial to a facility. Turlington stressed the importance of implementing both a recall plan and training program for preventative measures.
Phase II of the FSMA trainings are slated to take place in 2015. They will educate feed and petfood industry professionals on the next steps in the implementation process.

Registration open for AFIA Purchasing & Ingredient Suppliers Conference

Registration has opened for the American Feed Industry Association (AFIA)'s annual Purchasing & Ingredient Suppliers Conference (PISC), to be held March 11–13, 2015, at the Hyatt Regency Grand Cypress in Orlando, Florida.
More than 500 buyers and sellers of feed and petfood ingredients are expected to attend the three-day event designed for educational and networking purposes, according to the organization. Highlights of the conference include the sporting clay outing, which will kick off the 2015 event, as well as a variety of presentations addressing issues pertaining to the feed industry, evening receptions and the PISC annual golf tournament, which will be held at the Grand Cypress Golf Club. This year's educational program highlights include: "Grain Outlook," Richard Brock; "Animal Economics," Dr. Chris Hurt; "Connecting the Disconnect," Sarah Muirhead; and "The Patriot Tour," Lt. Peter Scobell.
In addition to PISC, the AFIA Nutrition Committee will host a half-day nutrition symposium on "The Effect of Consumer Preference on Feed and Nutrition" prior to the conference March 10. PISC registrants can attend for an additional cost and hear from key industry experts discussing a breadth of topics including the regulatory environment in Washington, D.C., growth and development research in animals used for meat consumption, the impact of milk on consumer health and the importance of communicating with consumers.

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.

AFIA to host eighth petfood conference at IPPE

The American Feed Industry Association (AFIA) will host a one-day Pet Food Conference at the International Production & Processing Expo (IPPE) in Atlanta, Georgia, on Jan. 27, 2015. The educational conference will discuss nutrition, trade and certification programs impacting today’s petfood and petfood ingredient manufacturers.
More than 10 speakers will address a variety of topics at the conference, including Dr. Daniel McChesney, director of office of surveillance and compliance at the US Food and Drug Administration (FDA)’s Center for Veterinary Medicine, who will provide agency updates and the impact on the petfood industry.
The conference will feature several other industry experts including Dr. Colin Basler, Center for Disease Control and Prevention; LeAnn Chuboff, Safe Quality Food Institute; Marianne Smith Edge, International Food Information Council; Richard Ten Eyck, The Association of American Feed Control Officials; Dr. David Meeker, National Renderers Association; Janet Riley, American Meat Institute; Dr. Charles Starkey, American Proteins; Dr. Kelly Swanson, University of Illinois; Gina Tumbarello, AFIA; and Svetlana Uduslivaia, Euromonitor International. There will also be a petfood safety panel, featuring Jolyda Swaim, Olsson, Frank and Weeda, and other petfood manufacturers and ingredient suppliers, which will give an update on the proposed Food Safety Modernization Act rules, food safety plans and sampling.
IPPE is expected to attract more than 28,000 attendees and is a collaboration of three trade shows—International Poultry Expo, International Feed Expo and International Meat Expo—representing the entire chain of protein production and processing. The event is sponsored by the American Feed Industry Association (AFIA), American Meat Institute (AMI) and US Poultry & Egg Association (USPOULTRY).   

AFIA addresses FDA on Food Safety Modernization Act

The American Feed Industry Association (AFIA) addressed the US Food and Drug Administration (FDA) during a Nov. 13, 2014 public meeting on the four re-proposed Food Safety Modernization Act (FSMA) rules. AFIA and the 575 members it represents submitted comments to FDA in March 2014 and are taking the additional time provided to prepare feedback on the supplemental proposed rules published Sept. 29, 2014.
AFIA said it remains concerned with items addressed in its original comments that are not fully addressed in the supplemental, particularly the differentiation between human food and animal food as well as the looming high costs of the rule for its members. "There are a few proposed CGMP provisions that still appear geared toward human food, not animal food," said Paul Keppy, AFIA government affairs specialist. "This is frustrating because the spirit of the law clearly allows for treating animal food and human food regulations differently. On the other hand, there are places where animal food is left out of important rules."
Keppy said the additions in the supplemental represent significant cost increases. He said FDA's own numbers in the original Preliminary Regulatory Impact Analysis (PRIA) concur, showing the cost of the rule to far exceed the benefit. "Feed is already 70% of the cost of raising an animal," said Keppy. "AFIA members want to make animal food safer, not more expensive. We continue to believe the costs can be reduced by a less prescriptive set of CGMPs and a strong approach to controlling significant hazards through CGMPs."
AFIA will submit comments on the proposed supplemental rules, which are due by Dec. 15.

AFIA publishes energy management guidelines

In order to assist the feed industry in the conservation of resources, preservation of the environment and reduction of cost in the area of energy management, the American Feed Industry Association (AFIA) has published an updated "Energy Management Guidance Document." The six-chapter guide was drafted by AFIA's production compliance, equipment manufacturer and integrator committees and covers state regulations, the organization and development of an energy management program, feed industry audits, calculating energy cost and methods for conserving energy.
The document is designed to help feed manufacturing facilities understand how to develop benchmarks within their companies and offers suggestions for improvement based on the findings. "It does not matter your profession—professional athlete or feed mill operator—the only way to improve your performance is to measure every aspect of your operation and then develop a plan to make improvements based on those results," said Keith Epperson, AFIA vice president of manufacturing and training.
Key areas the document provides details on are: calculation of electric bills and how to reduce electricity usage in a feed facility; energy audits specific to natural gas consumption, operating temperatures of a boiler, peak demand usage and more; and the proper maintenance of boilers within a mill, especially if operators are pelleting feed or flaking grains. "Our goal is for feed mill operators to welcome this document into their facilities as our members always look to become more energy efficient, environmentally sound and up-to-date with current regulations," said Epperson.

Registration open for AFIA 2014 Import & Export Seminar

Registration is open for the American Feed Industry Association (AFIA)'s 2014 Import & Export Seminar in Arlington, Virginia, Dec. 9–10. The seminar is a collaboration of educational courses and discussions to address issues related to regulatory trade requirements for feed, ingredients and petfood.

The educational event is open to industry professionals interested in learning about current trade industry constraints and how they can support the efforts of the varying agencies. It is ideal for anyone responsible for the importing and/or exporting of products for their company. Foreign Service Agriculture Administrator Phil Karsting will deliver this year's keynote presentation on "Linking US Agriculture to the World." Other speakers include individuals from the Office of the United States Trade Representative, the US Department of Agriculture's Animal and Plant Health Inspection Service and Foreign Agriculture Service, and the US Food and Drug Administration.
"AFIA is thrilled yet again to host an interactive event that benefits an array of key industry professionals who focus on regulatory trade issues," said Gina Tumbarello, AFIA director of international policy and trade. "With the recognized need for education on importing and exporting products, this unique, every-other-year event offers an opportunity for key industry professionals to engage in discussions with various government agencies and their role in regulatory trade."
The early-bird registration is available through Nov. 10.

AFIA comments on revised FSMA rules

The American Feed Industry Association (AFIA) has commented on the pre-publication of four re-proposed rules pertaining to the Food Safety Modernization Act (FSMA), saying that at first glance, the US Food and Drug Administration (FDA) has incorporated many of the changes AFIA recommended in its original comments.

The reissued rules are Produce Safety Regulation, Foreign Supplier Verification Program, Current Good Manufacturing and Hazard Analysis and Risk-Based Preventive Controls for Human Food, and Current Good Manufacturing Practices and Hazard Analysis and Risk-Based Preventive Controls for Food for Animals. AFIA previously submitted comments on five major sets of FSMA-related proposed rules during the last 10 months.
"The American Feed Industry Association is pleased the Food and Drug Administration has issued a revised proposal for these complex rules," said AFIA President and CEO Joel G. Newman. "This re-proposal will allow stakeholders to review these rules one last time before the final rule is issued."
While AFIA believes it is reasonable for FDA to re-propose these rules based on complexity alone, the association said it is concerned with the re-proposal's financial impact. "The additional cost, with very limited added benefit, continues to be a major concern for AFIA," said Richard Sellers, AFIA senior vice president of legislative and regulatory affairs. "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. 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."
With input from membership, AFIA will review the latest rules, develop comments and submit to FDA. AFIA staff also intends to work alongside its animal food coalition partners in hopes of the development of consistent comments on the FDA proposals as needed. The comment period to review all four rules is 75 days after publication in the Federal Register. AFIA plans to request an extension to the comment period as all the rules were released simultaneously versus in succession.

AFIA completes first phase of FSMA seminars

The American Feed Industry Association (AFIA) completed two more phase I Food Safety Modernization Act (FSMA) regional seminars in Des Moines, Iowa, and Atlanta, Georgia, Aug. 11–12 and Aug. 14–15, respectively. Both of the two-day seminars discussed the developing need for an industry-wide understanding of the largest set of rules to impact the feed and petfood industries. The first training session was held in Sacramento, California, in late July.

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The sold-out Des Moines meeting was attended by more than 130 feed manufacturers, petfood manufacturers and ingredient suppliers interested in learning more about quality and food safety practices. "Our goal is to provide a solid foundation to the quality and food safety programs for businesses as they begin to implement practices and prepare documentation for compliance with the new FMSA requirements," said Dr. Henry Turlington, AFIA director of quality and manufacturing regulatory affairs.
AFIA hosted a second sold-out training course in Atlanta, where one-third of the room represented the poultry integrator sector of the industry. Dr. Adam Fahrenholz of North Carolina State University joined Turlington, speaking on the topic of "CGMPs: The Foundation for an Effective Food Safety Plan." Fahrenholz chaired AFIA's Current Good Manufacturing Practices FSMA Working Group that prepared comments to the US Food and Drug Administration on the proposed CGMP rules.
Turlington said that participants at the training sessions expressed concern and asked questions about efforts to reach compliance. "It is important facilities understand how FMSA impacts them as requirements may differ based on the business and facility's animal food safety plan," said Turlington. "The information shared during the meetings, as well as references provided electronically, will help businesses determine the right steps for them."
AFIA will be back in Atlanta to host an additional phase I FSMA regional seminar training program at the International Production & Processing Expo on Jan. 28, 2015. The one-day meeting will discuss the FSMA proposed rules and the fundamentals for complying with FSMA as was done in all three meetings completed this summer. Registration and event information will be available on Sept. 1, 2014, at http://ippexpo.com/.
Phase II and phase III FSMA regional seminars will be hosted by AFIA in 2015 along with a series of other training tools under construction along with the in-person meetings.

AFIA comments on proposed FSMA sanitary transportation rule

The American Feed Industry Association (AFIA) has submitted comments to the US Food and Drug Administration (FDA) on the proposed Sanitary Transportation of Human and Animal Food rule.

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The FSMA requires FDA to create regulations for shippers, carriers by auto transit or railway vehicles, and receivers to use sanitary transportation practices to ensure food—including animal food—being transported does not become contaminated. The goal of the sanitary transportation rule is to ensure that transportation practices do not create food safety risks.
Although AFIA openly agrees with FDA in certain areas, such as allowing "the industry to continue to use bulk transport equipment in accordance with best practices without limiting industry, by rule, to hauling non-food exclusive of or preceding any food items," the organization listed several points of difference in their nine pages of comments for FDA to review.
In the rule, FDA proposed exemptions for farms and shelf stable products. AFIA suggested those exemptions be broadened to include intra-company shipments (when the company maintains control of the product), short haul transports (as defined by the US Department of Transportation) and finished product or raw agricultural commodities transported from facilities to farms in dedicated vehicles. AFIA also commented that FDA should lower the recommendation on the definition of "non-covered business" to engage businesses with transportation operations with less than US$10,000 in total annual sales.
The organization also made note of the temperature control measures and hand washing facility requirements originally proposed are not appropriate across the animal food industry and would induce unnecessary cost on the industry without improving the safety of animal food products. AFIA would like these requirements to be removed for animal food.
The comments on the proposed sanitary transportation rule were drafted by AFIA members who volunteered as part of a work group to review the rule. FDA, under a court ordered deadline, must issue the final rule on this topic by March 31, 2016.