Food Producers Push Back on FSMA's Feed Rule

A number of food producers, impacted by FSMA Animal Feed Regulation, have commented to FDA about the impositions that the regulation will make.

Many of the waste products generated by food processing plants, including grains generated by distillers, will be subject to the feed regulation because these products are fed to animals.  The concern is that the producers will have to absorb additional costs to implement additional food safety controls over their waste streams.  And in reality, there have been really no issues to support the need for this level of control.

 

For many, it may come to the point where it is more cost effective to dump rather then use these items for feed.  From a sustainability standpoint, this is not the way to go.  The regulation needs to written that makes it easy, yet safe, for producers to continue to use their waste streams, when appropriate, as a source of animal feed.


AgWeb
http://www.agweb.com/article/nmpf_asks_fda_to_rewrite_draft_animal_feed_regulation_NAA_News_Release/
NMPF Asks FDA to Rewrite Draft Animal Feed Regulation
April 1, 2014
By: News Release


Source: The National Milk Producers Federation

The National Milk Producers Federation has asked the Food and Drug Administration to rewrite a draft livestock feed regulation, saying the agency went beyond the intent of Congress by seeking to impose requirements that will not make animal feed safer.

In comments sent to the agency Monday, NMPF asked FDA to substantially revise the regulation and requested the agency establish a new round of comments from industry and the public. "FDA has the authority to re-propose the regulation and still comply with (a) court-ordered deadline to publish a final rule by August 30, 2015," NMPF said. NMPF made the request in two sets of comments, one focused on dairy plant safety and the other addressing animal feed.

The draft regulations were issued under the Food Safety Modernization Act (FSMA), which gave the FDA broad new authority to regulate food. NMPF said it supports efforts to implement the 2010 law, but believes that the draft animal feed regulation goes too far, particularly because it would make it harder to use brewers’ grain as animal feed, a practice in use for hundreds of years.

Among other things, NMPF, the Washington voice of more than 32,000 dairy producers, said the draft regulation incorrectly imposes safety standards on animal feed that are similar to those for human food. The proposed regulation incorrectly establishes manufacturing standards that equate animal feed and human food. "The innate hygienic standards of humans exceed the hygienic standards of livestock," the organization said. It asked FDA to propose manufacturing standards specific to animal feed.

The proposed regulation also unnecessarily regulates by-products from brewing when they are used in animal feed, even though there is no public health risk associated with these products. This "will result in unnecessary increased costs to dairy producers," NMPF said. It joined the Beer Institute and the American Malting Barley Association in requesting FDA use the existing authority in the FSMA to exempt animal feed products made during the production of alcoholic beverages.

In separate comments submitted jointly with the International Dairy Foods Association, NMPF also identified unnecessary and duplicative requirements for dairy processing plants which may divert some food production materials such as cheese trim and liquid whey to animal feed. These plants are already subject to FSMA requirements for human food production. NMPF stated the proposed standards "do not reflect the inherent differences between foods for human and animal consumption" for diverted food production materials and requested regulatory relief for these dairy processing plants.

With the substantial changes requested, NMPF asked FDA to conform the regulations with the intent of the FSMA and issue a new draft. "Given the very significant nature of these regulations, a second opportunity for stakeholders comment is essential to ensure the final rule is practical, achievable and fosters the safe production and distribution of animal feed," NMPF said.

The National Milk Producers Federation, based in Arlington, VA, develops and carries out policies that advance the well-being of dairy producers and the cooperatives they own. The members of NMPF’s cooperatives produce the majority of the U.S. milk supply, making NMPF the voice of more than 32,000 dairy producers on Capitol Hill and with government agencies. Visit www.nmpf.org for more information.



Beerbound
http://www.brewbound.com/news/2014/beer-institute-urges-fda-to-exempt-american-brewers-from-regulation
Beer Institute Urges FDA to Exempt American Brewers from Regulation
 Posted March 31, 2014 at 4:00 PM by Press Release

WASHINGTON, DC – Today, the Beer Institute filed joint comments with the American Malting Barley Association in order to protect a centuries-old and environmentally-conscious practice of brewers marketing their brewers’ grain to local animal producers. Please click here to view the comments, filed today.

The Beer Institute has been working for more than a year with Members of Congress, regulators and allied organizations from dairy farmers to agriculture scientists in order to present a strong economic and scientific argument proving that it is completely unnecessary for the Food and Drug Administration (FDA) to add additional regulation to brewers’ spent grain and other by-products of brewing. The Beer Institute is the national trade association representing brewers of all sizes, beer importers and industry suppliers like hops farmers and can and bottle manufacturers.

The National Milk Producers Federation also filed comments that expressly reference and include support for the Beer Institute’s comments.

Brewers’ spent grain exist as a natural and necessary result of the brewing process. For centuries, brewers, large and small, have disposed on their spent grain by giving or selling them to farmers and ranchers. This recycling process supports community green initiatives, but could end if this FDA rule is upheld. Instead, some brewers will be forced to throw away this valuable feed, a cheaper option than complying with the costly proposed regulations, which the Beer Institute estimates may cost a single brewery more than $13 million in one-time and reoccurring costs.

Chris Thorne, Beer Institute Vice President of Communications said: “This regulation is onerous and expensive, but really it’s just unnecessary. There has never been a single reported negative incidence with spent grain.” Thorne added, “We have had very positive conversations with the FDA and other concerned stakeholders making us cautiously optimistic.”

This letter was filed in response to the Food and Drug Administration’s (FDA) proposed rule on “Current Good Manufacturing Practice and Hazard Analysis and Risk-Based Preventive Controls for Food for Animals” under the Food Safety Modernization Act (FSMA) [Docket No.: FDA-2011-N-0922] RIN: 0910-AG10.

Additional Background

In November of 2013, the Beer Institute filed two additional comments with the FDA regarding proposed FSMA regulations. The first comment, filed jointly with the Brewers Association, asked the FDA to add hops to the list of produce that is exempt from regulation under FSMA because hops are not consumed raw and are quite safe.

The American Malting Barley Association again joined the BI in our second letter last November – asking the FDA to exempt brewers’ spent grain from FSMA regulation for human food because they are safe and merely the byproduct of brewing.

The Beer Institute will continue following all developments with the FSMA and any proposed regulations that may impact U.S. brewers.