The AFIA has asked the FDA to streamline or remove several federal regulations and recordkeeping requirements that it said are unclear, duplicative, antiquated or do nothing to enhance the safety of the animal food supply.
The AFIA submitted formal comments to the agency on Feb. 5 in response to its federal docket (FDA-2017-N-5104) requesting input from industry and other stakeholders on current human and animal food safety regulations and information collection requirements that could be improved upon or reduced.
Under the Obama administration, the AFIA hired several new staff members to keep up with the depth of new regulations affecting the feed industry, said Richard Sellers, senior vice-president of public policy and education at the AFIA. He said the AFIA appreciates the current administration’s goal of rolling back unnecessary and burdensome regulations.
“As such, we hope our comments, and those of many others, are not stored somewhere and never reviewed,” Sellers said. “We believe the development of meaningful regulatory reform ideals would provide tremendous benefit in time and resources not just to the regulated industry, but also to the FDA, and urge the agency to seriously and swiftly review these comments and move toward a concerted effort to make positive changes in regulations.”
The AFIA’s letter outlines several requests for the FDA to consider:
• Aligning the Food Safety Modernization Act (FSMA) current good manufacturing practices (CGMPs) with those of the medicated feed CGMPs, which have been in place for 40 years.
• More clearly defining when the FSMA written preventive controls and written supply-chain programs are or are not required. As currently written, most facilities will assume they must follow preventive controls. These controls are estimated to cost the industry an excess of $800 million with very little benefit to animal food safety.
• Removing several elements of the FSMA hazard analysis (i.e., illness data, scientific reports and the assessment and determination of the probability of hazards), which would be overly cost-prohibitive for small animal food manufacturers to comply, with little indication that such egregious hazards exist.
• Establishing speedier and more consistent ingredient review processes that allow innovative products to come to market to benefit animal nutrition, animal food safety and human food safety.•Eliminating several other unnecessary or duplicative written record keeping requirements, including: under Part 11 Veterinary Feed Directive and medicated feed CGMPs, FSMA’s written assurances, and the FDA’s annual drug establishment registration for medicated feed mill license applications.