Follow our guide on FSMA animal rule implementation to cut costs, AFIA tells FDA

Follow our guide on FSMA animal rule implementation to cut costs, AFIA tells FDA

The US Food and Drug Administration (FDA) needs to take additional steps to lower the costs associated with the proposed animal food rules under the Food Safety Modernization Act (FSMA), says the American Feed Industry Association (AFIA).

The feed industry representatives submitted comments to the FDA on Monday to outline where the agency could make the rule less burdensome for the sector. Nineteen regional and state feed associations also signed on to AFIA's letter as a statement of their support.

Richard Sellers, AFIA senior vice president of legislative and regulatory affairs, told us:

“Despite FDA’s work to incorporate the animal feed industry’s comments into the proposed animal food supplemental rule, there is still more work to be done. Our main concern, as we have shouted from the rooftop all along, is the high costs compared to the low benefits of the rule. 

One particular way to lessen the cost of the rule is the separation between current good manufacturing practices (CGMPs) and hazard analysis and preventive controls (PCs).”  

He said it is the association’s belief that all potential hazards in animal feed plants can be controlled if the facility simply adheres to CGMPs. However, Sellers does recognise there is a need for certain hazard analysis and preventive measures in pet food plants to eliminate pathogen related risks. 

“If our approach is implemented in the rule, costs will decrease significantly, hence the reason why the AFIA has been urging the FDA to train its field staff in this area,” he notes. 

Phased introduction of new measures urged

"How to comply with the new animal feed rules and the implementation period is still a large and looming issue within AFIA", stated the comments. 

The trade group has consistently asked the FDA to consider a gradual introduction approach when addressing GMPs and has asked it to then look at adding the preventive control rules on a staggered basis to allow for greater adherence.

“The FDA needs to adopt AFIA’s suggested time lines of one, two and three years for compliance with the CGMP rule, and two, three and four years for conformity with the PC rule for firms that are regular size, small businesses and very small businesses, respectively,” said the lobby group.

The association said training and adequate understanding of the final rule and industry practices are still needed. And the industry representatives want the FDA to continue to support the joint industry and regulatory work taking place within the context of the FSPCA Animal Food Steering Committee. 

The Committee, said the AFIA, should spend quality time on developing relevant, clear and practical guidance documents for dry and liquid feed, pet food, animal-derived products, plant-derived products, vitamin, mineral and amino acid trace ingredients as well as special purpose ingredients. ”AFIA pledges it support and technical assistance in developing these guides,” it added.  

The final FSMA animal food rule is mandated by a court order to be published by 30 August, 2015.

The section of the FDA's website covering the new feed industry rules can be accessed here.

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