Feed traceability systems improve with evolving regulations
Advances meet the challenges of the modern food supply chain
According to the U.S. Department of Agriculture (USDA), animal products bring in more than $100 billion in cash receipts annually — that’s more than half of the total cash receipts in the agriculture sector. And with the United States producing the most beef and poultry in the world, feed safety is a great responsibility for feed mills.
This broad reach through animal feed inspired the Public Health Security and Bioterrorism Preparedness and Response Act in 2002. After the 2001 terrorist attack on the World Trade Centers, Congress feared the safety of the food systems was a potential target. On June 12, 2002, President Bush signed the Bioterrorism Act into law, mandating that feed facilities keep records that allow Food & Drug Administration (FDA) inspectors to trace grains and feed through the manufacturing, processing, transporting and receiving stages.
However, animal feed traceability goes back further. Medicated feed mills have been required to record ingredients since 1986 through regulations, such as the 21 CFR 225 to ensure feed mills were manufacturing medicated animal feed reported all medications to the FDA.
“From a medicated feed standpoint, we’ve been dealing with this issue for several decades,” says National Grain and Feed Association (NGFA) vice president of feed services David Fairfield. “In a broader sense, feed traceability came in to effect after the Bioterrorism Act that mandates U.S. food facilities — grain, feed, human food — to establish and maintain records on the feeds coming into their facilities.”
FSMA heightens regulations
In 2011, feed traceability made another leap when the FDA issued the Food Safety Modernization Act (FSMA). The goal of FSMA is to focus more on preventing food safety issues rather than focus on the response to issues by giving FDA legislative power to require science-based preventive controls such as safe production standards.
“With the passage of FSMA, the regulatory environment in the United States has become increasingly challenging,” says Jay Davis, director of business development, Repete Corporation. “Until recently the U.S. animal nutrition industry was not as aggressive in tracing feed as the feed industries in some other parts of the world. That is changing rapidly.”
Davis explains that along with the implementation of FSMA, a lot of U.S. feed producers manufacture globally and have developed traceability practices that meet some of the most challenging regulations.
Insurance for feed mills
Feed traceability isn’t just for regulatory means. It is also a preventative measure for companies against litigation and recalls.
“The ability to verify quality, guarantee product integrity, or to transfer liability is valuable, or even essential for many operations,” says Davis.
Fairfield agrees: “If a company gets involved in a product recall it can be very costly from a brand and public relations standpoint,” he says, adding that companies aiming to minimize public relations or product liability risks are trying to enhance their ability to trace products back and forth between their facilities. Coupled with stricter regulations, these risks drive companies to invest in feed tracing technology, such as plant management software and barcoding systems.
But at the end of the day, the level and process of traceability comes at a cost.
“I see some firms that have established paper records that keep track of everything while other companies have established pretty sophisticated bar codes to efficiently track products that go through their facility,” says Fairfield. “We’re seeing a wide array of activities that are occurring in the industry to comply with the existing regulations whether it is paper records or software.”
The increasing demands of FSMA and other regulatory requirements will continue to challenge producers who utilize manual methods of traceability, notes James Phillips, president, WEM Automation.
“Automation allows for immediate traceability review and eliminates common errors in connecting the dots and perhaps more importantly, the missing dots,” says Phillips. “It is merely a matter of time, which is not long, where manual recordation will not be acceptable by regulatory agencies.”
According to Davis, whether it is in traceability technology or not, the capital investment needs to be based on its potential return on investment or a regulatory requirement. But he adds that any business that is at risk of government enforcement actions from regulatory non-compliance should consider investing in feed traceability technologies.
“It’s a safe bet that the trend will continue towards stricter regulation, an increase in verification of good manufacturing processes, more product liability risk, and a more litigious society,” says Davis. “Tracking and tracing strategies can address, or mitigate many of these factors.”
Future of feed traceability
The feed industry is working with the FDA to review the current Good Manufacturing Practice (cGMP) regulations to ensure they are appropriate for the animal feed industry. Some of the main changes to the proposed rule include the definition of business size, as well as how to register feed mills that are associated with vertically integrated farm operations.
The proposed rule for Preventive Controls for Animal Food will be finalized on August 30, 2015.
In the past few decades feed traceability has come to the forefront due to stricter regulations, but also as a way to protect businesses in the case of recalls.
“Recalls can be very costly not only in immediate bottom line but the longer term impact by consumer perception,” Phillips says. “These costs can be significantly minimized by instant data and reporting that only automation can provide. In addition, once areas of concern are identified it can more easily be disseminated for immediate implementation of an action plan. Immediate identification through automation also allows for faster recovery of the mill production.”
“It’s amazing where the industry is at today compared to where it was 30 years ago,” says Fairfield.
Davis agrees, and says that in the next 30 years he expects more government regulation, and increased risk management to play a large part in feed traceability.