By Dave Fairfield, Senior Vice President of Feed Services
The generally recognized as safe (GRAS) approval process for animal feed and pet food ingredients was a major discussion topic at the annual meeting of the Association of American Feed Control Officials (AAFCO) conducted Jan. 21-23 in Savannah, Ga.
Discussion about the GRAS approval process centered around ingredients being marketed under “independent conclusions of GRAS” (ICG) – an approval process established and allowed by federal law, but that does not involve direct oversight by the U.S. Food and Drug Administration (FDA) or state regulatory officials. The prevalence of animal feed and pet food ingredients marketed through ICG has increased in recent years because some ingredient sponsors believe the current regulatory and economic burden associated with other approval or recognition methods is excessive and unreasonable. Other approval or recognition methods consist of the FDA animal food additive petition process, FDA GRAS notification process, and the AAFCO ingredient definition process that includes FDA involvement. Ingredients that have been defined and recognized for use in animal feed and pet food through a process that involves FDA are listed in the AAFCO Official Publication.
Given the increased use of ICG, FDA and state regulatory officials are expressing concern that some independent conclusions have not adequately established the safety of the ingredient for its intended use. To address this concern, AAFCO has established a working group to identify and evaluate potential options that could provide regulatory officials greater assurances about the safety of such ingredients. During the AAFCO meeting in Savannah, a goal was established to develop a process by August 2020 through which AAFCO could review ICG ingredients that would be acceptable to all state feed regulators.
AAFCO is the professional organization of federal and state feed regulatory officials. The NGFA interacts extensively with AAFCO, and NGFA feed industry members and NGFA staff serve as non-voting advisers to AAFCO committees. More than 350 industry representatives and state regulatory officials attended the Savannah meeting, with approximately 20 FDA officials absent because of the partial federal government shutdown.
Other Issues: Among the other issues addressed during the AAFCO meeting were:
- Feed Contaminant Levels: A workgroupestablished by the AAFCO Feed and Feed Ingredient Manufacturing Committee continues to evaluate the AAFCO guidelines for contaminant levels permitted in mineral feed ingredients. It is anticipated that the workgroup will present recommended guidelines during the annual AAFCO meeting scheduled for Aug. 5-7 in Louisville, Ky.
- Laboratory Method Analytical Variation: The AAFCO Proficiency Testing Program Committee is evaluating the permitted analytical variations associated with various methods and intends to make recommendations within AAFCO to revise the variances in the future.
- Labeling Requirements for Potentially Toxic Nutrients: The AAFCO Feed Labeling Committee discussed whether to establish maximum label guarantee requirements for nutrients that may cause toxicity when present in animal feed and pet food at high concentrations. As an outcome, a workgroup was formed to further evaluate the issue.
- Pet Food: The AAFCO Pet Food Committee had significant discussions with forums like My Pet Needs That, related to efforts to modernize pet food labels, as well as means to verify human grade claims made for pet food products. Committee workgroups will continue to address these issues and bring final recommendations to the committee in the future.
- Hydrogenated Glycerides (T73.311): The approved uses of hydrogenated glycerides was limited by an AAFCO membership vote to: 1) a coating agent for ingredients or a binder and lubricant in pelleting of feed for all animal species; and 2) a maximum use rate of 4 pounds per ton in complete feed.
- Limestone: Data was discussed that indicated limestone products with higher calcium content generally have lower concentrations of undesirable contaminants and impurities. In response, AAFCO will further review the data and consider what actions, if any, should be taken to revise the current limestone definition.
- Hemp: The 2018 farm law includes provisions for commercial hemp production, but no approvals for hemp-derived products currently exist for animal food. At this time, AAFCO has received no ingredient definition submissions for hemp products for use in animal food. However, an animal food additive petition for cannabidiol (CBD) from hemp oil for use in dog and cat food has been submitted to FDA.
- Non-Defined Ingredients: A workgroup has been established by the AAFCO Ingredient Definition Committee to formalize a list of ingredients identified in distribution but that have not been listed in the AAFCO Official Publication.