Animal feed safety programs combine for streamlined auditing

The American Feed Industry Association (AFIA) and the National Renderers Association (NRA) have announced a partnership of two animal feed safety certification programs -- AFIA's FSC36 Safe Feed/Safe Food  and NRA's Rendering Code of Practice (COP) -- resulting in an updated and more user-friendly auditing process.

The announcement was made after updates to both programs to better align with industry standards, including the soon-to-be-published regulations by the U.S. Food and Drug Administration to implement the Food Safety Modernization Act (FSMA).
"Updating FSC36 to align with FDA's updates is vital to our members' facility operations' compliance," said AFIA President and CEO Joel G. Newman. "AFIA is proud to partner with the NRA to align their COP with FSC36 Safe Feed/Safe Food so that together we are preparing our members for tomorrow's challenges."
"The rendering industry takes its stewardship role very seriously," said NRA President and CEO Nancy Foster. "This joint venture is one more step to emphasize transparency, accountability and commitment to animal food safety by NRA members."
The decision to pair the programs allows AFIA and NRA to require only one audit from the facilities seeking FSC36 Safe Feed/Safe Food certification and NRA's COP certification. As before, the Safe Quality Food Institute (SQFI) will administer the FSC36 Safe Feed/Safe Food Certification Program on behalf of AFIA. Renderers seeking FSC36 certification via SQFI will be automatically certified in both programs after a successful audit. Rendering facilities interested in obtaining only the renderer's COP certification may bypass SQFI and request a COP audit directly from Validus, a third-party certifying body.
"We are excited about the opportunity to partner with NRA to support their animal food safety certification," said Henry Turlington, AFIA director, quality and manufacturing regulatory affairs. "The updates to the FSC36 are important changes to help drive continuous improvement in quality and food safety programs for our members as well as support compliance with the new FSMA compliance."
FSC36 is considered a firm foundation for AFIA's other certification programs such as FSC32 Manufacture of Pet Food (Global Food Safety Initiative benchmarked) and FSC34 Manufacturer of Animal Feeds (GFSI benchmarked for animal feed manufacturing), which have more stringent certification requirements. The Rendering COP was originally developed in 2005 by the Animal Protein Producers Industry (APPI) organization, which has merged with NRA.
"Many renderers see value in one-stop, dual certification to meet customer expectations for feed safety and prepare for regulatory compliance with FSMA," said Dr. David Meeker, NRA senior vice president of scientific services. "To facilitate this, NRA's companion guidance for FSC36 includes differences between feed manufacturing and rendering so each audit will be appropriate for the type of facility."

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.

NGFA seeks to change proposed rule on petfood, animal feed

The National Grain and Feed Association (NGFA) during a recent public meeting urged the US Food and Drug Administration (FDA) to make significant changes to its proposed rule that would establish for petfood and animal feed new requirements for current good manufacturing practices (CGMPs) and hazard analysis and risk-based preventive controls.
The FDA conducted the public meeting to receive stakeholder feedback on four major re-proposed rules associated with its implementation of the Food Safety Modernization Act (FSMA). The four re-proposed rules address produce safety, CGMPS and preventive controls for human food, CGMPs and preventive controls for petfood and animal feed, and foreign supplier verification programs.
The FDA issued the reproposed animal feed rule on Sept. 29, 2014 to provide the agency's current thinking on requirements after its review of comments received in response to its original proposal issued in 2013. The NGFA submitted extensive comments on the 2013 proposal, and recommended that FDA make major changes and re-propose the rule for additional stakeholder comment given the very significant nature of the regulations, and the extent of changes recommended by the NGFA and other stakeholders.
During the public meeting, Max Fisher, NGFA director of economics and government relations, said he commended FDA for re-proposing the rule and allowing additional comment. But Fisher said the NGFA remains concerned that "many of the proposed CGMP provisions continue to mirror those established for human food, and do not reflect the realities associated with feeding animals, nor are they necessary to assure the safety of feed products."
In prior statements to FDA, the NGFA has urged the agency to develop final requirements that are practical, achievable and serve to benefit the safety of petfood and animal feed. In doing so, the NGFA has cautioned that adding unnecessary regulatory burdens and costs would undermine the industry's ability to serve the animal agriculture industry and divert finite resources away from effective practices that already are assuring a safe and abundant supply of petfood and feed.
"The NGFA requests that FDA carefully consider the economic impact of its proposed requirements and weigh the extensive costs against anticipated benefits, which the agency has yet to quantify," said Fisher. The NGFA's economic analysis of FDA's original proposal indicated the requirements would cost petfood and animal feed facilities more than US$500 million annually—approximately four times more than estimated by FDA.

FDA releases high-risk food facility criteria under FSMA

The Food and Drug Administration recently released its criteria for classifying high-risk food facilities that will require more frequent inspections under the Food Safety Modernization Act. 
The administration's two main classifying criteria are known safety risks of foods, such as related Class 1 recalls and illness outbreaks, and the facility's compliance history. Under the Food Safety Modernization Act, high-risk facilities must be inspected once in the first five years after enactment of the Food Safety Modernization Act, then once every three years after the initial inspection. Not-high-risk facilities must be inspected at least once in the first seven years after enactment of the Food Safety Modernization Act, then once every five years after the initial inspection. 
Of the 82,000 domestic facilities listed in the Food and Drug Administration's inventory, 22,325 are considered to be high-risk facilities. To determine if a facility is classfied as "high-risk," the administration uses a decision-making process based on the risk factors identified in section 421(a)(1) of the FD&C Act, including:


• Known safety risks of the food manufactured; 
• Compliance history of a facility; 
• Facility's hazard analysis and risk-based preventative controls; 
• Facility's priority under section 801(h)(1) of the FD&C Act;
• Certifications for imported food;
• Any other criteria deemed necessary

FDA issues interim final record-keeping rule for pet food companies

The US Food and Drug Administration issued an interim final rule amending its regulations on record-keeping by food and pet food companies be consistent with the agency's authority for access to records, which was expanded by the Food Safety Modernization Act.
The new interim final rule, effective March 1, makes the reference to records access in the food-firm record-keeping requirements under the Food Safety Modernization Act consistent with the current statutory language in the Federal Food, Drug and Cosmetic Act. The interim final rule also allows FDA access to records beyond those relating to specific suspect food articles, if the agency has a reasonable belief that other products are likely to be affected in a similar manner.

FDA published a new draft guidance, “Draft Guidance for Industry: FDA Records Access Authority under Sections 414 and 704 of the Federal Food, Drug, & Cosmetic Act,” to provide more detailed information regarding the updated record-availability requirement. This latest draft guidance is a revision of FDA’s November 2005 guidance, “Guidance for Industry and FDA Staff Guidance for Records Access Authority Provided in Title III, Subtitle A, of the Public Health Security and Bioterrorism Preparedness and Response Act of 2002; Final Guidance.” FDA also published an updated "Guidance for Industry: Questions and Answers Regarding Establishment and Maintenance of Records (Edition 5)," to be consistent with new Food Safety Modernization Act requirements.  

Pet Food Institute urged state Senate committee to strip pet food tax provisions from bill

The Pet Food Institute expressed its appreciation to the West Virginia, USA, Senate Agriculture Committee for amending a bill to remove pet food tax provisions.
The Senate Agriculture Committee passed an amended version of S.B. 479 that removed the pet food tax provisions, which would have funded a spay and neuter assistance program with supplemental money from the fee increase on pet food retailers and distributors, the group says. Instead, the bill now funds the program through the general state budget, and supplemental revenue is raised through an income tax refund checkoff. As part of its initiative to fight the petfood tax provisions, the Pet Food Institute launched a Facebook campaign called "Save our Pets from Onerous Taxes," which the group says received the support of more than 1,300 Facebook users within the first two days of being created.  “It is not fair to tax responsible pet owners to fix a situation they did not create. We are grateful that the concerns of West Virginians were heard and that the unfair tax provisions were stripped from S.B. 479,” said Duane Ekedahl, president. “Every state that has debated a proposal to tax petfood to fund spay/neuter programs ultimately rejected a tax on pet food. Now West Virginia joins that list.” 

West Virginia, USA, considers pet food package permit fee increase

The Senate Agriculture Committee of West Virginia, USA, is considering a bill that would create a pet spay and neuter fund by raising the permit fee on select pet food packages, according to a report.
Senate Bill 479 establishes a Spay Neuter Assistance Fund to subsidize spay and neuter programs throughout West Virginia, USA, in an effort to decrease the number of animals euthanized in West Virginia shelters, the bill says. The bill would raise pet food registration fees from US$50 to US$75 per product, allocating the $25 increase to the spay and neuter fund.
The Pet Industry Joint Advisory Council opposes the bill, saying the cost of spay and neuter services should not be only the responsibility of petfood distributors and retailers.

Webinar on FDA pet food regulation to be held February 23

On Febrary 23, a 90-minute webinar training event will provide an introduction to the US Food and Drug Administration's rules governing petfood product development; formulation, manufacturing and labeling; and marketing and promotion.
The webinar will by instructed by Karl Nobert, a food and drug regulatory attorney with Squire Sanders law firm in Washington, D.C., USA. Specific topics covered include FDA's regulation of pet food products; various components of a pet food label; the process for introducing a new ingredient or feed additive to the market; differences between the Pre-Market Clearance Process, the Food Additive Petition Process and the process for having an ingredient deemed Generally Recognized As Safe; update on the status of the Proposed GRAS Self-Affirmation Notification Program; a summary of FDA's recent enforcement activity, and recent trends and areas of particular enforcement risks; FDA's regulation of those veterinary products marketed and sold as dietary supplement and nutraceutical in the US; and a brief introduction to the animal drug approval process.
More information on registering for this upcoming webinar is available online. 

Release of regulations for Food Safety Modernization Act delayed

The US Food and Drug Administration’s release of proposed regulations to implement the cornerstone of the Food Safety Modernization Act has been delayed by the White House Office of Management and Budget, which is still in the review stage.
The Food and Drug Administration had hoped to release four separate sets of proposed regulations on January 4, the one-year anniversary of the Food Safety Modernization Act's signing into law. Two of those sets of proposed rules will pertain to the requirement that food and feed facilities analyze hazards, implement appropriate preventive controls and develop written food/feed safety plans — each of which is intended to minimize or prevent the potential for products to be adulterated or misbranded. The set pertaining to animal feed, feed ingredient and pet food manufacturers will consist of a 200-page preamble, 100-page economic analysis and the text of the proposed regulations. The other two sets of proposed regulations pertain to law’s requirements that food and feed facilities implement a foreign supplier verification program; and produce growers and handlers implement hazard analysis, preventive controls and product-tracing systems for such products as fruits, vegetables, spinach and lettuce. The final regulations must take effect by July 3. 

North Dakota seeks pet food manufacturer comments on feed law

The Agriculture Department of North Dakota, USA, has scheduled public meetings around the state in January 2012 to gather comments and suggestions regarding the state's regulation of animal feed. Agriculture Commissioner Doug Goehring says the department is reviewing its feed regulation program to determine if it meets the needs of today's industry, and welcomes comment from anyone from animal feed manufacturers to pet food manufacturers and retailers.
The afternoon meetings begin January 9, 2012, in Bismarck, North Dakota, USA, and end on January 17, 2012, in Valley City, North Dakota, USA. A full schedule can be found at online. 

AFIA Regulatory Training Short Course concludes

More than 120 people attended the American Feed Industry Association's Regulatory Training Short Course that provided intensive training on how to work as a regulatory professional in the feed, ingredient and pet food industries.

The short course was designed for experienced regulatory directors, allowing them to interact with government officials and develop strategies to tackle the issues impacting their business, with the main focus this year being the Food Safety Modernization Act.
Opening speaker Eric Nelson of the Food and Drug Administration’s Center for Veterinary Affairs spoke about compliance and upcoming FSMA inspections. A panel of AFIA members discussed how to prepare for the implementation, with representatives participating from Land O’Lakes Purina Feed, P&G Pet Care, Milk Specialties Global, Kemin AgriFoods North America, SPF North America, Provimi North America and law firm, Olsson Frank Weeda Terman Matz PC. 

Kent Kitade of the Association of American Feed Control Officials and FDA-CVM’s Sharon Benz discussed the evolving relationship between the two entities. The AAFCO ingredient review and approval process was also discussed by panelists.

AFIA speakers at the course included president and CEO, Joel G. Newman, vice president of nutrition and feed regulation, Richard Sellers, and director of ingredients and state legislative affairs, Leah Wilkinson. The bi-annual event is planned to next be offered in 2013. 

FDA may get US$50 million for food safety from US Senate

The US Food and Drug Administration may receive additional funding when the 2012 fiscal year starts October 1, 2011, as the Senate Appropriations Committee considers a bill that sets the organization's spending limit, according to reports. 

The report says the Senate's version of the budget bill would allocate approximately US$350 million more than the appropriations bill passed in the House in June. This would be nearly US$50 million more than FDA's fiscal 2011 budget allowed, due to Senate efforts to increase funding for FDA's implementation of the Food Safety Modernization Act. In contrast, the House bill would cut FDA's fiscal 2012 budget by 11%, or US$285 million, compared with fiscal 2011, including an US$87 million cut to food safety.

Former FDA member challenges FSMA pet food regulations

According to Benjamin England, founder and CEO of FDAImports.com, food importers and foreign manufacturers are in for a surprise starting October 1, when a provision of the Food Safety Modernization Act becomes effective requiring the US Food and Drug Administration collect a fee for costs associated with re-inspection of imported food shipments. England is currently launching a coalition of interested manufacturers and food importers to challenge FDA’s broad interpretation of this FSMA provision.

England says the re-inspection fees will cripple the food industry, leaving no other choice but to pass the costs on to consumers. In its Federal Register notice issued August 1, FDA invited comments about the re-inspection fees, which will be accepted until October 31. England points out that the fees, however, will go into effect 30 days before the comment period has closed. Through his coalition, England is working with pet food manufacturers to officially comment on and rally against these new fees.

England, a former 17-year FDA member, will speak about the Food Safety Modernization Act and the FDA re-inspection fees at the upcoming Virtual Petfood Forum 2011 on October 6. Those interested in attending Virtual Petfood Forum can register online to learn more about the Food Safety Modernization Act and other issues affecting the petfood industry.

AAFCO unveils pet food regulation website

The Association of American Feed Control Officials unveiled its new website, “The Business of Pet Food," which was developed to address frequently asked questions about US pet food regulatory requirements.
The site, www.petfood.aafco.org, includes explanations and links to resources from the states and US government with information about registration and licensing, ingredient listing, labeling requirements and laboratories and analyses.

AFIA announces pet food regulatory training course

In October, the American Feed Industry Association will hold a regulatory training short course for pet food industry professionals in Arlington, Virginia, USA.
The course will take place October 11-12, serving as training on how to work as a regulatory professional in the petfood industry. Government officials will help attendees develop strategies to solve issues affecting their businesses, in addition to covering advanced topics and regulatory strategies. The course is designed for regulatory directors with several years' experience, AFIA says.
AFIA offers a short course early registration rate of US$399 for members or US$789 for non-members. Registration is available at www.afia.org.

FDA wants US$1.4 billion in US budget for pet food-safety law implementation

The US Food and Drug Administration wants the US government's fiscal 2012 budget to include US$1.4 billion in funds for FDA's food-safety law that guides FDA regulation in cases of pet food contamination, according to Bloomberg.com.
In June, the US House voted to cut FDA’s fiscal 2012 food-safety budget by 10% to US$752 million, which FDA says would slow progress of Food Safety Modernization Act implementation. 
"The funding needs ultimately will grow, not in fiscal 2012 or 2013, but in subsequent years to meet inspection mandates,” said Scott Faber, vice president for federal affairs at the Grocery Manufacturers Association, a trade group of members including petfood manufacturer Nestle. “If the agency doesn’t have more resources further down the road, the FDA won’t be able to retrain its inspectors and fulfill the promise of the food-safety reforms.”