The "Focused Mitigation Strategies to Protect Food Against Intentional Adulteration" would require registered domestic and foreign food facilities to address hazards that may be intentionally introduced by acts of terrorism.
AFIA explained in its comments the significant differences between risks in human food and animal food, particularly when dealing with intentional adulteration, which is recognized by Congress in the Food, Drug and Cosmetic Act.
"What is nutritious for a ruminant cow may not be nutritious for a pig. Sheep, for example, have an increased sensitivity to copper. Risk varies between humans and animals as well. For example, humans can be allergic to a host of things from peanuts to shellfish, while animals simply do not have this same risk," the organization stated.
The creation of Section 420 in the FD&C Act states FSMA requires FDA to establish regulations for facilities to review the potential risk of intentional adulteration of food -- further noted in Part C, this applies only to human food.
"AFIA fully supports FDA's findings and proposed exemption of animal food in the intentional adulteration rule as we believe it is Congress' intent," said Richard Sellers, AFIA senior vice-president of legislative and regulatory affairs. "FDA has indicated the proposed rule's purpose is 'to protect food from intentional adulteration when the intent is to cause large-scale public harm' and AFIA firmly believes animal food has a significantly lower risk of impacting human health."
The final rule on intentional adulteration will be published by May 31, 2016.