Posted April 1, 2014
The comment period for the FDA’s Food Safety and
Modernization Act (FSMA) proposed rule on “Current Good Manufacturing Practice and
Hazard Analysis and Risk-Based Preventative Controls for Food for Animals” closed
on Monday, with several groups commenting, according to a Feedstuffs article
available here.
The proposed rule, available here,
seeks to assure that food for animals is safe and will not cause illness or
injure animals or humans. The rule would
require certain facilities to establish and implement hazard analysis and
risk-based preventive controls. In
addition the rule would establish requirements for current good manufacturing
practices in manufacturing, processing, packing, and holding of animal food.
The American Feed Industry Association (AFIA) commented
that it “strongly supported development and passage of the FSMA.”
The National Grain and Feed Industry Association (NGFA)
commented that “the agency’s proposal would add unnecessary requirements that
cause industry to direct scarce resources towards complying with regulatory
obligations that will not serve to benefit the safety of animal feed and pet
food.”
Both groups commented that FDA’s requirements for
animal and pet food should differ “significantly from those established for
human food.”
“AFIA is concerned that FDA has failed to clearly
delineate the human food rules from the animal food rules as Congress
intended. Both the intent and sometimes
the language used in the statute requires a separation of the rules,” the group
commented.
The NFGA opposed the use of the term “contamination” in
the proposed rule, commenting, “We strongly believe that FDA’s regulation
cannot rightfully focus on avoiding and preventing ‘contamination,” when that
term has no defined meaning in the regulatory context. As such, we urge FDA to replace the term ‘contamination’
throughout the proposed regulation with the term ‘adulteration.’”
Breweries also expressed concern that the proposed rule
would limit their ability to supply leftover grain to farmers, according to an
article by the Chico ER available here.
For more information on food safety, please visit the National
Agricultural Law Center’s website here.
