In late November and early December, the U.S. Food and Drug Administration held three public meetings in the Washington, D.C., area, Chicago, IL, and Sacramento, CA, to discuss the animal food preventive controls rule under the Food Safety Modernization Act (FSMA).
The first meeting in College Park, MD, mostly played host to organizations already fairly familiar with FSMA – groups such as the American Feed Industry Association, the International Warehouse Logistics Association, and the Humane Society of the United States.
According to Dan McChesney, director of FDA’s Office of Surveillance and Compliance, as the meetings journeyed west, the people responsible for putting the rule into operation grew in attendance and outnumbered the association representatives.
“The interesting thing is, as we’ve gotten closer to where the people are making the products, you’ll see a change in the questions,” McChesney said. “[They] go from the bigger picture down to ‘here’s to what I do in my facility, what am I going to have to do?’”
Speaking to Food Safety News, McChesney identified three key themes that arose in all of the public meetings: time for implementation, company-specific situations, and the relationship between human and animal food.
So far, FDA has been talking about giving large firms one year to implement the rule. Small businesses would have two years and “very small businesses” – the definition of which has yet to be determined – would have three years.
“We’ve heard comments from people that that may not be enough time for the feed industry because of where they’re starting,” McChesney said. “Then there was a proposal at one of the public meetings from a trade association that those implementation dates of one year, two years and three years be applied to a GMP portion and then an additional year given to year of those for the preventive control portion.”
Under this plan, GMPs and preventive controls would be in place within two years for large firms, three years for small businesses and four years for very small businesses.
“In many ways, that, I would say, makes sense,” McChesney said. “If you look at the human food industry, what we’re asking them to do is implement just the preventive controls in one year, two years or three years. They’ve been implementing GMPs for many years already, so they don’t have to do that part.”
Another thing that stakeholders have been bringing up is company- or product-specific situations.
“We’ve seen some of that on the human side, too,” McChesney said. FDA is looking into these situations that “don’t really fit neatly into these particular rules” and plans to address them through more education measures or adjustments to the rule.
The third theme throughout the meetings dealt with products that move from human food into the animal food supply chain.
These are products that, for some reason, weren’t quite the right quality for human food – potato chips that are too brown, for example.
“A lot of food farms just send that off to animal food,” McChesney said. “Now they’re going to be subject to these requirements, and how’s that going to play out? That’s something we could approach in guidance.”
Ultimately, the people showing up for the meetings are “just trying to understand how to comply and what they need to do,” McChesney said.© Food Safety News