The American Feed Industry Association (AFIA) is continuing to push for more timely final animal food product approvals by the US Food and Drug Administration's Center for Veterinary Medicine (CVM).
A newly released report from the trade group is aimed at providing an overview of all the challenges the US animal food sector is facing, the organization’s recent achievements, and the work it is undertaking to advance the US feed and pet food regulatory review processes, among other policy actions.
AFIA president and CEO, Constance Cullman, said the association is advocating for a more efficient and modern regulatory review of animal food ingredients, along with supporting the resiliency of the US animal food industry through customer and supplier market diversification, and by facilitating industry-wide solutions for a more sustainable animal food and livestock production sector.
The feed industry representatives have been working over the past few years to increase resources within the CVM to accelerate ingredient evaluation procedures. The result, said the body, is the creation of the Division of Animal Food Ingredients, which is intended to focus resources on completing ingredient reviews more quickly, a win for the industry.
This year saw the CVM begin working with Congress to modernize its policy to keep pace with scientific innovation through proposed statutory changes to the Federal Food, Drug and Cosmetic Act (FD&C Act). Those changes would establish a new regulatory category – zootechnical animal food substances – to review novel feed ingredients.
Congress, continued the AFIA, is currently considering a legislative solution – the Innovative Feed Enhancement and Economic Development (Innovative FEED) Act – a bill that, if enacted, would put "US agriculture on par with its international counterparts and move the US closer to achieving its public health and environmental challenges.”
The association’s report also identified ongoing barriers to domestic feed and pet food industry development such as supply chain bottlenecks on US highways, railroads, and ports. These issues “continue to increase manufacturers’ business costs, delay essential feed and pet food deliveries and call trade with foreign buyers into jeopardy.”
The trade group highlighted the work it has done to ease shipping concerns, including supporting the Ocean Shipping Reform Act, signed into law in June 2022. This law addresses recent maritime disruptions that hampered the movement of animal food products at US ports. It also holds ocean carriers and marine terminals accountable for unreasonably high detention and demurrage fees, said the AFIA.
And, as part of the Agricultural Transportation Working Group, the feed association is calling on the Biden administration to intervene in rail and West Coast port labor disruptions.
Pet food labels
The organization reported as well that after nearly eight years of effort to modernize pet food labels, the approved changes have finally been accepted by the Association of American Feed Control Officials (AAFCO).
The AFIA, it said, has worked alongside state and federal regulators in the step-by-step process of developing new analysis requirements, packaging narrative and visual prompts to increase consumers’ understanding of pet food labels. “The changes will provide consumers with easier to understand information on their pet food packaging, detailing the nutritional aspects of the pet food and treats, how to select pet foods and safely store remaining food.”
Next steps will involve compliance by AFIA members via state-by-state adoption of the AAFCO-sanctioned amendments, industry application of the new label requirements, and retailer and consumer education about the revised labels.
Dealing with state level challenges
In addition to those achievements, the AFIA said it has been focused on supporting feed and grain associations at US state level to monitor and speak up on state bills impacting the feed and pet food sectors.
“Of note, the association protected the animal food industry by working to change Maryland SB 158, a bill that originally limited the presence of per-and polyfluoroalkyl substances (PFAS) in pesticides (including those used in animal feed) to a bill that required the state to conduct a health and environmental study of PFAS in pesticides and identify appropriate testing methods for them.
“Also in Maryland, the association successfully lobbied for a state budget line item for funding spay, neuter and other pet wellness services, rather than increasing fees on pet food products as proposed through HB 365. In South Carolina, the association successfully blocked HB 3266, which proposed to increase fees on equine feed and custom blends to fund an equine promotion board not involved in the regulation of these products.”
AFIA said it has been working with AAFCO as well to inform state lawmakers and agricultural leaders on the illegal, yet growing use of hemp products in animal food. Yet these efforts did not stop bills in Mississippi (H 1071) and Minnesota (HB 100) from moving forward.
“Looking ahead, the AFIA will continue to fight state initiatives to fund nongermane, social programs that increase fees and push back against state mandates on items such as PFAS and packaging, not regulated at the federal level.”
In 2022, the AFIA attended COP27 in Egypt to represent the US feed sector, striving to ensure “policymakers made accurate statements” with it also explaining to participating stakeholders how feed and feed ingredients could provide sustainable solutions to global environmental and food security concerns.
The trade group is looking to secure official UN observer organization status for COP28, which will take place in late 2023.
Feed management has been the least used practice within the USDA’s National Resources Conservation Service’s (NRCS) conservation programs, according to the AFIA, but it noted that the NRCS is starting to prioritize climate mitigation along with its traditional conservation goals, including targeting practices and programs aimed at providing quantifiable reductions in greenhouse gas (GHG) emissions.
“While the AFIA is making progress to modernize the regulatory process for novel, emissions-reducing ingredients, it is now turning attention toward getting these ingredients into the hands of farmers and ranchers. In 2022, the AFIA submitted comments to the NRCS asking the agency to support the use of the feed management standard within the cost share-based Environmental Quality Incentives Program (EQIP) and Conservation Stewardship Program (CSP).
"Going forward, the AFIA will collaborate with the NRCS to better utilize the feed management standard to raise awareness and utilization of novel feed ingredients and ration innovation with farmers and advocate for sufficient NRCS staffing to fully implement the program.”
Preventing formaldehyde ban
The US Environmental Protection Agency (EPA) has been evaluating whether to effectively ban the manufacture and use of formaldehyde; the AFIA is part of an animal agriculture coalition working to protect formaldehyde’s use, with it speaking at public forums stressing the importance of the chemical as a safety tool and calling for the scientific literature to be reviewed adequately and transparently.
The AFIA is also urging the EPA to engage in “meaningful discussions” with the FDA and the US Department of Agriculture (USDA) on the topic.
Worker health and safety
The US Occupational Safety and Health Administration (OSHA) published its final rule to improve tracking of workplace injuries and illnesses in April 2023.
OSHA listed animal food manufacturing as a ‘highest hazard’ industry with the rule requiring that establishments with 100 or more employees in such sectors submit their injury and illness record-keeping forms electronically on an annual basis through the injury tracking application.
In 2022, the AFIA filed comments on the new rule, registering industry’s concerns that OSHA’s intention to publish the collected data could potentially expose sensitive worker information.
OSHA is also continuing to work on the heat injury and illness prevention in outdoor and indoor work settings rulemaking, with anticipated publication of those rules for comment in late 2023 or early 2024. The AFIA said it will continue to monitor this development and keep its members informed of additional requirements.
The association will also persist in monitoring any potential misinformation on animal food in the media and on social media networks, responding as necessary to ensure the industry’s perspective is heard.