The American Feed Industry Association has submitted comments to the Food and Drug Administration regarding the FDA’s final rule amending the procedures for substances Generally Recognized as Safe, noting that the continued approval of new, innovative feed ingredients is critical for the U.S. feed and pet food industries to provide safe, healthy feed for livestock, poultry, aquaculture and pets. 

The FDA reopened the comment period in late 2010 to finalize the rule amending the procedures for GRAS. After 14 years of inaction on the proposed rule, this comment period was necessary to update feedback to the FDA regarding the proposed GRAS notification process.

“While the industry is still able to self-determine the GRAS status of a substance, it is in the best interest for all entities to work together," said Leah Wilkinson, AFIA’s director of ingredients and state legislative affairs. "Finding a workable solution will ensure that the U.S. feed industry continues to be the world leader in bringing novel ingredients to market to help the animal agriculture industries safely feed the growing population.”

The U.S. feed industry has a long history of providing safe ingredients in animal feed, but recognizes the role that federal officials in the FDA's Center for Veterinary Medicine and state feed control officials as part of the Association of American Feed Control Officials can play in reviewing these ingredients. The CVM has said during several public forums that proof of utility (i.e., functionality) of an ingredient must be published. AFIA believes that an absolute requirement for proof and publication of utility is inappropriate and unnecessary. "Although AFIA understands that an intended use must be described and supported in the notice, the pivotal issue is whether the ingredient is safe to feed to animals at the intended level," said the statement. "Both industry and CVM resources could be better used demonstrating the safety of the intended use of the substance with a focus on establishing the worst-case exposure and relating it to available safety information in order to establish a margin of safety. As it stands, the requirement for and public documentation of the utility of an ingredient will predictably stifle innovation in the feed ingredient industry."