In a statement submitted this month in response to the British Standards Institute’s (BSI) request for stakeholder comments, the NGFA commended the SSAFE organization — an international public/private partnership formed to integrate food safety, animal health and plant health across food supply chains — for sponsoring the proposed BSI standard that would establish voluntary food safety requirements for the prerequisite programs used for manufacturing food and ingredients for animals.
In doing so, the NGFA noted that the growing awareness about the vital role that food for animals plays in achieving the safe production of meat, milk and eggs likely will increase the demand for firms engaged in the animal food industry to be certified to a recognized and accredited food safety standard. The NGFA also noted that a single, internationally recognized standard could be very beneficial in alleviating the potential need for animal food manufacturers to obtain multiple food safety certifications based upon different standards that likely would provide limited benefits in enhancing animal food product safety, and instead create additional and excessive costs that ultimately largely would be passed on to consumers.
In its statement, the NGFA provided overarching comments pertaining to several concepts incorporated within proposed standard, including:
• Hygienic standards necessary to ensure animal food safety: The NGFA stated that it fundamentally believes that recognized and accepted safety requirements for human foods are not always appropriate or necessary to ensure the safety of animal food and animal-based foods consumed by humans. The NGFA stressed that a distinction in the necessary manufacturing practices for human foods versus animal foods is proper and has a sound scientific basis. As an example, the NGFA noted that the innate hygienic standards of humans clearly exceed the hygienic standards of livestock, poultry and other animals. As such, the NGFA said it is reasonable that the hygienic safety standards necessary to manufacture human foods should exceed the hygienic safety standards for animal food and ingredients used in animal food, and that it is imperative that requirements within the proposed BSI standard for animal food appropriately reflect that fact.
• Scope of applicability: The NGFA noted that the scope section of the proposed standard states, “This (publically available standard) is applicable to all organizations, regardless of size, location or complexity, that are involved in the supply and manufacturing (including storage, distribution and/or transportation) steps related to compound animal food and ingredients utilized in the manufacture of such animal food, and that wish to implement a (prerequisite program).” In this regard, the NGFA said it would be a daunting task to develop a single prerequisite program standard that establishes the appropriate requirements necessary to assist in controlling food safety hazards for the entire gamut of firms serving the animal food industry. To assist in alleviating this challenge, the NGFA urged SSAFE to include within the proposed standard additional criteria that could be used by a facility to justify that it should be exempt from a given requirement established by the standard.
Further, concerning the numerous prerequisite program requirements proposed within the voluntary standard, the NGFA, among other things, recommended that SSAFE:
• Further clarify the proposed provisions that would require a facility’s site boundaries to be “clearly identified” and access to the site “controlled.” In doing so, the NGFA stated that installing physical barriers frequently are not necessary, practical or cost-effective for product safety because of the configuration of the facility, its surroundings and/or the relative risk identified through a facility vulnerability assessment. Further, the NGFA noted that facilities should implement controls appropriate to their respective threat levels to prevent unauthorized persons from having access to critical assets or areas, as identified through a risk assessment.
• Delete from the standard a proposed requirement that would prohibit the use of compressed air for cleaning. In adamantly opposing this proposed requirement, the NGFA stated that using compressed air is a practical and effective method to remove debris and improve sanitary conditions within a facility. Further, the NGFA said it is unaware of valid scientific evidence that indicates use of compressed air for cleaning contributes to potential animal food safety issues by “spreading contaminants throughout the facility,” as alleged in the draft proposed standard.
• Delete the proposed provision that would require equipment to meet established principles of hygienic design, including “framework not penetrated by holes or nuts and bolts.” The NGFA stated, to its knowledge, there are no established consensus standards that specifically describe the hygienic design principles to be incorporated within equipment used in the manufacture of animal food. Further, the NGFA stated it was not aware of any evidence that the very common occurrence of nuts and bolts penetrating the framework of storage bins and other various equipment used in the manufacture of animal food and feed ingredients poses animal food safety issues.
• Clarify a proposed provision that would require product contact surfaces to be “corrosion-free.” Specifically, the NGFA requested that SSAFE provide a definition for “corrosion-free.” The NGFA noted that the use of stainless steel materials for product contact surfaces during the manufacture of dry animal food is not common, and, more importantly, not necessary to assist in controlling potential food-safety contaminants. Further, if SSAFE is referring to the use of stainless steel materials when it uses the term “corrosion-free,” the NGFA said, it strongly disagrees with the proposed requirement and recommended that it be deleted.
• Delete the proposed requirement that a “list of materials that are an acceptable (positive) and/or unacceptable (negative) prior use of bulk conveyances and containers shall be maintained.” The NGFA strongly disagreed with this proposed requirement, stating that: 1) it virtually is impossible to create a negative list that encompasses all of the potential prohibited materials that may be objectionable; and 2) creating a negative list erroneously implies there are situations where conveyances cannot be used to convey animal food materials, regardless of the methods used to clean and sanitize such conveyances.