With a new administration, the US feed industry should expect changes in policies and enforcement as well as an increased focus on environmental issues, said speakers during the American Feed Industry Association’s (AFIA) Feed Production Education Program.

“My advice to you is buckle up, it could be a very wild ride,” said Gary Huddleston, director of feed manufacturing and regulatory affairs at the AFIA. “We know for sure there’s going to be lots of COVID-related stuff coming down the pike and we’ll have to deal with that first. As AFIA has always done, we’ll watch that for you and make sure you are informed of anything that you need to know.”

The program was part of the 2021 virtual International Production and Processing Expo, which is normally held in Atlanta, Georgia, US, at the end of January and attracts more than 30,000 visitors. Because of coronavirus (COVID-19) restrictions, the event was held virtually with 34 hours of educational sessions and an online marketplace with participation from 131 countries. The event had the largest number of TECHTalk presentations and new product showcase videos, with a combined 200-plus submissions.

Organizers are planning an in-person event next year from Jan. 25-27, 2022, at the Georgia World Congress Center in Atlanta.

Policy expectations

The Biden administration has made it clear that a top priority for the Occupational Safety and Health Administration (OSHA) will be creation of an emergency temporary COVID standard, said Huddleston, who addressed possible changes within the Department of Labor and OSHA.

“It’s an emergency standard that will likely become a permanent pandemic standard so it’s likely something we’ve got to deal with forever,” he said.

More aggressive enforcement, especially when it comes to COVID, is likely along with recordkeeping expansions and whistleblower retaliation actions.

Gary Huddleston, director of feed manufacturing and regulatory affairs for AFIA. Photo courtesy of AFIA.

“I think we’re going to see more inspections around COVID-19, not just waiting on complaints,” Huddleston said. “We’ll see more inspectors in the field making sure different industries are compliant with the standards.”

Some states already have COVID standards, which provides some insight into what a federal standard might look like, he said. It will apply to every place of employment and have requirements based on exposure risk levels, training, PPE, hazard assessment, cleaning and disinfecting, and an infectious disease preparedness plan.

“Every facility is going to have to have a written COVID plan in place; I’m certain of this, with this emergency temporary standard,” Huddleston said.

Within the Department of Labor, there also likely will be an increased amount of inspections, especially in the area of COVID, as well as continuing to seek maximum penalties.

“There could be a return to the naming and shaming campaign prevalent during the Obama administration,” Huddleston said. “There could be lots of news releases where offending companies are going to be named and shamed. We’ll see a different tone in those news releases than what we’ve seen over the last four years.”

Climate and environmental issues are other key issues the Biden administration already is addressing, said Christian Richter, principal, The Policy Group, who spoke about what to expect from the Environmental Protection Agency (EPA). A regulatory freeze was issued, which is common with a new administration, so any regulations or guidance in the pipeline is currently on pause. This includes about 120 to 130 decisions in the EPA.

The United States has rejoined the Paris Climate Accord, which the Trump administration had reversed from the Obama administration.

“We’re going to see a lot of activity on the international stage,” Richter said. “The US is reengaging that way.”

On the domestic side, Biden has appointed Gina McCarthy as the climate czar to deal with coordination among the federal agencies. The feed industry worked with McCarthy on the prepared feeds rule when she was the EPA’s head administrator.

“While she had significant demands institutionally, she was able to sit down with us and talk about how to have the best rule possible,” he said, noting that she was able to open the final rule and make some changes after problematic errors were discovered.

The administration has had ambitious discussions on what kind of response and actions it will take on climate change. The EPA is going to play one role in the broader federal activities, Richter said. The nominee to lead the EPA, Michael Regan, is considered to be a fairly even-handed decisionmaker, he said.

Discussions on the climate front are very different from what they were the last four years, Richter said. So far, agriculture has not been named one of the top-shelf priorities, but major action is expected on the power and vehicle sector in terms of greenhouse gas and carbon emissions. Changes also are expected in the federal Clean Water Act jurisdictional rule.

“EPA will take a look at the Trump version of that rule, but not right away,” he said. “We’re going to see a more aggressive revision of the Trump version or rolling that back.

“We’ll see a bit more activity on the chemicals office side of EPA that will spill into some of the agriculture chemicals. We’ll have new discussions with EPA on those matters.”

FDA inspections

While the Food and Drug Administration modified its inspection schedules due to COVID, a number of inspections had already taken place prior to state lockdown, said Leah Wilkinson, vice president of public policy and education. The FDA came closest to its goal in Current Good Manufacturing Practice inspections, largely because state inspectors continued to work through the pandemic while the FDA shut down in late March.

Deficiencies and citations in the last fiscal year included problems with hygiene, documentation around personal hygiene and facility cleaning. In Preventive and Hazard Analysis inspections, some facilities did not have a food safety plan, did not adequately review hazards and did not have preventive controls in place to address those hazards.

Leah Wilkinson, vice president of public policy and education for AFIA. Photo courtesy of AFIA.

“Inspections were interrupted in 2020 so it’s hard to pull trends,” Wilkinson said. “The majority of inspections that were occurring were ‘for cause.’ Hang with us over the course of the next couple of years as we traverse through this area and try to continue to draw some trends for you.”

The FDA has set inspection goals for 2021 and discussions are ongoing about what inspections might look like going forward. This summer, the human food side started talking about using remote records for inspections. The Center for Veterinary Medicine has asked the feed industry whether it would consider such a method.

The AFIA said if such a program were put in place, it would only want it used during the pandemic and it would need to be voluntary. The FDA said it would not be considered an official inspection so Wilkinson said that no citations should be issued.

Some of the technologies used during the pandemic could translate into inspections, such as Zoom meetings. Documents could be shared onscreen and the facility staff and inspectors would be able to have a conversation.

“We’ve all gotten more adept at being able to talk to each other through a computer screen,” Wilkinson said. “That will continue and maybe be a better use of our time and have the ability to incorporate more parts of the organization in those conversations, not just the staff at the facility.”

Regardless of whether a plant is inspected, compliance is still needed, she said.

“I still remind you to be prepared,” Wilkinson said. “It is still your responsibility to produce that safe, high quality feed and pet food. While you have this time without an inspector, refresh yourself on your rights as a facility; refresh yourself on their rights as an inspection force. Make sure that your employees know what to do if an inspector shows up: who to call, what records they can copy, all of those types of things.

“Maybe do some mock inspections. Use this time to be able to be prepared.”

COVID-19 lessons

In response to COVID-19, the feed industry took multiple steps to keep employees safe and facilities open during the pandemic. The AFIA sponsored roundtable discussions in late 2020 with more than 50 people to learn what they did, how they adjusted and what they may keep doing in the future. Constance Cullman, president and chief executive officer of the AFIA, shared the findings during a virtual TECHTalk at IPPE.

A top priority, Cullman said, was employee safety. To that end, companies adjusted sick leave policies so employees could stay home if they had COVID-19 symptoms or had to quarantine. They also stopped travel and limited visitors to their facilities.

Work from home was implemented to protect those employees whose presence was needed to get the job done. Open spaces where employees could congregate were shut down and PPE was distributed.

Clear and timely communication was also critical, Cullman said. Companies added new methods of feedback so they would be aware of any challenges team members were facing.

Constance Cullman, president and chief executive officer for AFIA. Photo courtesy of AFIA.

“Transparency was very important, including letting employees know what was going on and how decisions were being made,” she said. “From top management down, an example was set about how to approach COVID. Consistency was key to be able to have all the team members on board.”

A third common theme among the roundtable participants was the importance of investing in the workforce on and off the clock, Cullman said. For example, some companies provided additional sick leave, covered the cost of testing, and even provided testing.

“Many companies recognized the sacrifice that essential workers made was significant,” she said. “They offered bonuses to employees.”

Some offered health and wellness seminars and changed vacation policies so that days could be rolled over instead of lost.

“Many companies had virtual social interactions because that was missing from the normal day,” Cullman said. “It was a way to maintain the morale of employees.”

Easing the burden of work-life balance was even more important as employees dealt with childcare, school, and other challenges. Some companies provided tutors or even helped employees’ children with science fair projects, Cullman said.

Mental health support was offered, and upper management made sure to connect with employees, whether by phone call, video conference, or some other method.

Celebrating successes was helpful in recognizing employees and keeping up morale, Cullman said. One company took out an ad in the local newspaper to recognize employees by name for the work they were doing to keep the food system running smoothly.

Lastly, collaboration was essential in handling the virus and its impact, Cullman said. This included development of cross-functional response teams that could come together across all aspects of the company.

Working closely with agencies such as the FDA and OSHA was important in order to understand guidelines.

“One thing that often times doesn’t happen is agencies were very open and ready to hear from companies about what challenges they were facing and what could be helpful for them,” Cullman said.