Formal comments provided to the Food and Drug Administration (FDA) by the American Feed Industry Association (AFIA) recommended revision of definitions relating to “responsible parties,” “transfer” and “reportable food” with respect to the proposed Reportable Food Registry.

The AFIA has requested that the FDA revise the draft guidance to include the following statement: “No reportable food report is required if a load of incoming product has been sampled, but legal transfer has not occurred, providing the trailer is on the premises of the facility only for as long as is necessary to sample, test and reject the shipment, and no longer. Your facility has not ‘held’ reportable food, therefore you are not a ‘responsible party’ with regards to such food.”

The situation under consideration relates to the relative responsibilities of the feed mill and consigner for a shipment of ingredients which may contain an adulterant and the responsibility of the recipient to report the contaminated load before ownership is transferred. The second issue relates to microbial contamination of ingredients in animal feeds. The present draft guidance requires that any positive test result subjects the raw material or feed to be classified as a “reportable food.”

The AFIA has invoked the Food and Agricultural Organization/World Health Organization’s 2007 report relating to the presence of human pathogens in ingredients or livestock feeds. This provision specifically relates to the presence of Salmonella spp. which may be present in feed at low levels but does not “generally make animals sick and poses little risk to livestock owners.”

AFIA Vice President Richard Sellers said the FDA needs to establish when action should be taken to ensure human food safety in relation to animal feeds, basing decisions on the best available science.