AFIA was pleased the guidelines seemed well constructed, including their breadth and depth. The report, developed for a more harmonized approach to Life Cycle Assessments (LCA) in the animal feed industry, takes into account the various production sectors involved. The draft also defines the methods necessary to produce consistent LCAs across the animal feed industry.
"AFIA appreciates the Technical Advisory Group, Secretariat and Steering Committee, especially Salil Arora (ADM) and Dr. Frank Mitloehner of University of California, Davis, for their time and efforts in crafting the guidelines," said Richard Sellers, AFIA senior vice-president of legislative and regulatory affairs. "We worked with our membership to review and draft comments because we want to make this document applicable to North American agriculture.
"Dr. Gary Hartnell (Monsanto Company) provided additional assistance as Mitloehner, Arora and Hartnell served as AFIA's experts for the last two years working on this project. AFIA is grateful for their institutions for allowing them to cooperate on this important sustainability project.”
The organization requested FAO report reasonable ranges of uncertainty in LCA's, commenting AFIA members feel these ranges should likely be large.
"Explicitly stating data sources and sensitivity analyses results should be included as elements of the LCA report will help ensure higher credibility of the guidelines," stated the comments. "Additional clarity on time-related representativeness of data collection (page 45, lines 11 and 12) would also be helpful."
AFIA also commented FAO should clarify how the LEAP guidelines relate to the Product Environmental Footprint guide-the reference document that currently receives the greatest attention and drives significant market share-and requested clarity in accounting for co-products.
"We suggest in our comments that FAO give credit for human food co-product that is used in animal food, as it transfers otherwise needed nutrition and those nutrients would go to waste if not recycled by the animal food industry," said Sellers.
In addition to LEAP, AFIA continues to work on a number of sustainability projects including the Specialty Feed Ingredients Sustainability project and the Global Network for the Development of Nutrition-related Strategies for Mitigation of Methane and Nitrous Oxide Emissions from Ruminant Livestock project. Both of these projects are envisioned to be included in LEAP in the near future.