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Animal Feed Safety
on August 12, 2014

NGFA urges FDA to make changes to Food Safety Modernization Act

Proposed rules would apply to shippers, carriers and receivers

The National Grain and Feed Association (NGFA) has urged the Food and Drug Administration (FDA) to make significant changes in its proposed rules implementing the sanitary food transportation provisions of the Food Safety Modernization Act (FSMA).

FDA's proposed rules would apply to shippers, carriers and receivers transporting agricultural commodities, food, feed and feed ingredients, and other agricultural products by truck and rail.

The centerpiece of the NGFA's statement presses that FDA's regulations not undermine the fundamental responsibility of carriers to comply with their statutory obligation to provide conveyances that are clean, appropriate and in safe condition suitable for the type of human or animal food intended to be shipped.

"This legal obligation is reasonable because the carrier or other provider of the transportation conveyance is in the best position to monitor the use of transportation conveyances and equipment, know the contents of the previous load(s) hauled, and implement prudent and effective clean-out procedures to protect product safety," the NGFA said.

The NGFA commended the agency for not applying the proposed rules to barge and vessel transportation, as well as for not prescribing specific sanitation practices for clean-out of rail and truck transportation conveyances and equipment, thereby giving shippers, carriers and receivers the flexibility to continue to utilize appropriate sanitary transportation practices that have evolved over time.

The NGFA also strongly supported FDA's decision not to restrict access for human and animal food to certain classes or types of rail or truck conveyances or transportation equipment, which it said was particularly important given constrained U.S. transportation capacity and severe rail service disruptions.

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