FSMA & Animal Feeds
I recently had the opportunity to participate in a Pennsylvania Department of Agriculture update of the proposed rules from the Food Safety Modernization Act related to animal feed manufacture and transport. The speaker was a representative from the FDA qualified to speak on the subject and he did his level best to provide everything that he knew to be fact with a fair amount of assumption and supposition thrown in for good measure. The meeting was very well attended. My state is blessed with large, medium and small feed manufacturers, all of whom want to know how this is going to affect them. The consensus at the conclusion of the Q & A was that this meeting only created more questions, with very few being answered.
As a professional schooled in the ways of regulatory bodies I empathized with these folks. Unless you live the lingo day in and day out the idea of new rules can be very intimidating. In the best of cases it’s who you know and what questions you ask that best lead you to success. In this particular topic there really is no one to ask. The FDA speaker had as many questions as most others in the group. I remain both confused and disappointed that a law so touted as necessary is so fraught with controversy and indecision.
My takeaway from the meeting and my readings on this proposed rule is that, in the end, it is fairly basic. The facilities that manufacture and transport feed are required to perform a risk assessment based upon their processes and maintain a documented food safety plan to address these risks. I’d bet a majority of the mills already have the beginnings (or more) of this requirement. What they really need is someone to help translate all the regulatory lingo into English and make it make sense. Why the government hasn’t offered this service is beyond me. That is one of the many failings of this now 3 plus year old process.
As could be expected, the comment period has been extended. I encourage all to make your comments, however rudimentary, to show your interest and have your say. Only by raising our collective voices can we have a practical end result that truly makes the process safer instead of just more complicated.
All the information for commenting and progress can be accessed here.
All the best to those of you entering the fray.