In response to the proposed rule for “Current Good Manufacturing Practice and Hazard Analysis and Risk-Based Preventive Controls for Food for Animals” requirements established by the Food Safety Modernization Act (FSMA), AHPA recommends revisions intended to ensure the final animal food rule will meet the Congressional intent behind FSMA, maximize flexibility for compliance and be written in a manner that eliminates confusion for affected businesses.
"AHPA views the proposed animal food rule as a complex new set of regulations with large and broad economic and cultural consequences and is suggesting significant revisions," said Michael McGuffin, AHPA President. "AHPA supports effective implementation of FSMA in a manner that minimizes the costs and burdens that will be borne by the regulated industries that will be impacted by the regulations and ultimately by consumers."
AHPA’s full comments can be read HERE.
FDA issued the proposed animal food rule on October 29, 2013 with the goal of establishing regulations regarding the manufacturing, processing, packing, or holding of animal food. The regulations would create new current good manufacturing practice (cGMP) regulations that specifically address the manufacturing, processing, packing, and holding of animal food, as well as including new preventive control provisions intended to implement section 103 of the FDA Food Safety Modernization Act (FSMA) for animal food.
The trade group has previously submitted comments relating to "Standards for the Growing, Harvesting, Packing, and Holding of Produce for Human Consumption," "Preventive Controls for Human Food Current Good Manufacturing Practice and Hazard Analysis and Risk-Based Preventive Controls for Human Food" (the proposed GMP HA/PC rule), and "Foreign Supplier Verification Programs for Importers of Food for Humans and Animals".
AHPA is “generally supportive” of “reasonable cGMPs” for animal feed, it says, and added that proposals from FDA to analyze and control hazards for each species for which food is processed in a facility will put “even greater costs and burdens on animal food facilities than will be borne by human food facilities, because it will require animal food facilities to implement a more extensive HA/PC program than human food facilities.
“AHPA believes it is not desirable or logical for animal food manufacturers to bear costs and burdens that are equivalent to or even greater than those human food manufacturers are expected to bear.”
AHPA also requests a clarification on the exemptions from facility registration requirements, as well as calling for longer time frames for companies to ensure facilities comply with GMPs. The current FDA proposal is for one year for medium and large businesses, two years for small businesses, and three years for very small businesses.
Since other organizations have suggested significant revisions to the proposed animal food rule, AHPA said that FDA should not issue a final rule as the next step in the animal food rulemaking process. Instead, the trade group said that FDA should publish a second proposed rule and invite additional comments.