The American Feed Industry Association (AFIA) submitted comments Monday to the U.S. Food and Drug Administration (FDA) on what AFIA describes as the most massive overhaul of animal food industry regulations since 1958. The comments, which address the Food Safety Modernization Act (FSMA) "Current Good Manufacturing Practices and Hazard Analysis Risk-Based Preventive Controls for Food for Animals" rule are more than 100 pages and cover five major areas.

Nineteen regional and state feed associations also signed on to AFIA's letter as a statement of their support.

"AFIA and its membership are extremely satisfied with the comments generated during the brief, yet productive, comment period," said Richard Sellers, AFIA senior vice president of legislative and regulatory affairs. "If more time had been allotted, we would have ideally provided FDA with more examples of the overall impact of the proposal. However, given our time constraints, AFIA focused primarily on how this rule would impact the many varied segments of the industry to strive for practical and easily understood requirements by the industry, FDA and state investigators that will inspect and audit these new requirements."


One major area of AFIA's comments is its focus on current good manufacturing practices (CGMPs). The organization stated CGMPs should be "more practical and less prescriptive," which will allow its members and the industry as a whole to be more innovative and have a better understanding as it is the first time many companies will use CGMPs, as they have previously only been a requirement for medicated feed. AFIA is also requesting FDA to simplify terms and concepts used throughout the rule such as replacing "utensils" with "tools" or "sanitation" with "cleaning," and seeks assurance the rules are dedicated to the animal food industry not the human food industry, from which they originated.

"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," Sellers said. "A blatant example is where the proposed rule suggests ill employees can contaminate animal food, hence making the animal sick."