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OABA joins AFIA and NGFA in letters commenting on the proposed FDA animal feed and pet food requirements

The Ohio AgriBusiness Association joined several other state and national organizations in signing letters commenting on the Food and Drug Administration’s proposed current good manufacturing practice (CGMPs) and preventive controls requirements for animal feed and pet food. The proposed rule is not consistent with the statutory framework provided by the Food Safety Modernization Act (FSMA) and the FDA’s proposal would add unnecessary requirements that cause the industry to direct scarce resources towards complying with regulatory obligations that will not benefit the safety of animal feed and pet food.

"It is quite clear the majority of the proposed CGMP requirements come directly from the human food rule and it has been left up to the feed industry to prove why the requirements are unnecessary as many do not relate to animal food in the slightest," said Richard Sellers, American Feed Industry Association (AFIA) senior vice president of legislative and regulatory affairs. "A blatant example is where the proposed rule suggests ill employees can contaminate animal food, hence making the animal sick."

According to the National Grain and Feed Association, the following changes need to occur to the proposed rule in order for its requirements to conform to the intent of FSMA’s statutory language and provide sufficient flexibility to allow facilities to adopt animal feed and pet food safety practices that are practical and effective for their specific, individual operations.

  • FDA should provide a clear exemption for low risk holding and packing activities of raw agricultural commodities, other than fruits and vegetables.
  • The CGMPs requirements for animal feed and pet food should differ significantly from those established for human food.
  • Preventive controls regulation should not mandate HACCP.
  • FDA should not establish additional requirements without proposing codified language for stakeholder comment.
  • Compliance dates for CGMPs and preventive controls should be staggered.
  • FDA’s preliminary regulatory impact analysis does not provide a realistic estimate of anticipated compliance costs.
  • FDA should modify and re-propose the regulation for further comment.

Click here for AFIA’s complete response to the proposed rule for CGMPs and preventative controls for animal feed and pet food.

Click here to view NFGA’s comments related to the proposed rule.

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