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AAFCO meeting addresses FSMA issues

By Dave Fairfield, Senior Vice President of Feed Services

The meeting of the Association of American Feed Control Officials (AAFCO) conducted Jan. 16-18 in Mobile, Ala., focused largely on the implementation of the new animal feed and pet food safety requirements established under the Food Safety Modernization Act (FSMA).

Joann Givens, director of the Food and Feed Program in the Food and Drug Administration’s (FDA) Office of Regulatory Affairs, provided an update on the agency’s on-going program alignment efforts that are intended to ensure the proper coordination and integration of its field oversight efforts. Under the emerging program framework, FDA is working to implement a “commodity-based and vertically integrated regulatory program” for its inspection, compliance, enforcement and other field-based activities. This means FDA’s field activities will transition from a geographic management to program-based management approach that focuses FDA’s specialized inspection, laboratory and compliance staff around designated types of food and feed products. With the commodity-based focus, FDA envisions bringing greater expertise to designated program areas and streamlined decision-making that will increase the efficiencies of the agency’s field operations.

The initial FDA inspections to determine compliance with current good manufacturing practice (CGMP) requirements established under the FSMA-related CGMP and preventive controls rule for animal food are slated to begin this month. These inspections will be conducted at facilities operated by large businesses (500 employees or more) by a select cadre of federal and state investigators that have received regulatory training on how to evaluate compliance with the requirements. It is anticipated that two or three investigators will be assigned to conduct each inspection. Findings and experiences from the inspections will be used by FDA to shape subsequent regulatory trainings for both federal and state investigators.

Inspections to determine compliance with the preventive controls requirements established under the animal food rule are expected to begin in January 2018 at facilities operated by large businesses. These inspections will focus on the adequacy of the facility’s hazard analysis and written food safety plans, as required by the preventive controls provisions of the rule. Again, a select cadre of federal and state investigators will be involved in conducting the initial preventive controls inspections, with findings used to influence subsequent regulatory personnel training.

Meanwhile, the AAFCO membership voted during the meeting to add language to the AAFCO Model Bill and Regulations that may be used by states to incorporate the requirements established by the federal animal food rule into state commercial feed laws. The approval is significant because most states in part or in whole base their feed laws on the AAFCO Model Bill and Regulations. Significantly, if a state does incorporate the FSMA-related animal food requirements into their state law, that state’s feed regulatory officials would have the authority to conduct inspections to determine compliance by animal food facilities within that state.

AAFCO is the professional organization of federal and state feed regulatory officials, with which the NGFA interacts extensively. Among other things, NGFA feed industry members and NGFA staff serve as non-voting advisers to key AAFCO committees, and participated actively in the meeting. More than 340 individuals attended the latest AAFCO meeting, including state feed regulatory officials from 37 states and 37 representatives from FDA.

Other significant issues addressed during the AAFCO meeting included the following:

  • Feed Ingredient Definitions and Approvals: The AAFCO membership voted to publish in the AAFCO Official Publication tentative definitions for: 1) stearic acid; 2) palmitic acid; 3) taurine; and 4) iron nickel tracer. In addition, the AAFCO Ingredient Definitions Committee voted to move the definition for direct dehydrated alfalfa from tentative to official and to change the crude fiber maximum for wheat middlings from 9.5 percent to 11 percent.
  • Feed/Pet Food Labeling: The Feed Labeling Committee continued its work to finalize a pet food labeling workshop that will be conducted in conjunction with the AAFCO 2017 annual meeting. The workshop is scheduled for Aug. 12-13 in Bellevue, Wash.
  • Feed Manufacturing: The Feed and Feed Ingredient Manufacturing Committee voted to establish a workgroup to evaluate whether to add provisions to the AAFCO Model Bill and Regulations that would require animal food products to be identified by a lot number or other unique identifier. The NGFA will serve as a member of the task force.
  • AAFCO Model Bill and Regulations: During the meeting of the Model Bill and Regulations Committee, the committee voted to approve incorporating model language, pending FDA approval, into the AAFCO Model Bill and Regulations that would facilitate states adopting the veterinary feed directive (VFD) requirements into their state feed laws. If states proceed to do so, this, too, would empower their feed regulatory agencies to inspect feed mills for compliance with the FDA VFD rules.
  • Feed Inspector Training: The Education and Training Committee continued its work in implementing the Animal Feed Regulatory Program Standards – a program designed to improve competencies and skills of state/federal inspectors to enhance the consistency of inspections. Currently, 20 states are participating in the program, which represent approximately 60 percent of the states that have contracts with FDA to conduct federal inspections.
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