AAFCO 2021 virtual annual meeting covers COVID-19 inspections, new guidelines and more  

By David Fairfield, Senior Vice President, Feed 

More than 400 industry representatives and regulatory officials from 46 states and seven countries participated on Aug. 2-4 in the virtual annual meeting of the Association of American Feed Control Officials (AAFCO) to discuss a variety of animal food regulatory issues. 

Timothy Schell, Ph.D., director of the U.S. Food and Drug Administration (FDA) Center for Veterinary Medicine’s Office of Surveillance and Compliance, provided the keynote address during the meeting. Topics covered by Schell during his presentation included:

·       Inspections During the COVID-19 Pandemic: FDA in May released a report – Resiliency Roadmap for FDA Inspectional Oversight – that summarized the agency’s inspectional activities during the COVID-19 pandemic and its strategy for future inspections. In accordance with the plan, FDA now is performing routine surveillance inspections at animal food facilities but is still providing advance notice – typically 1 to 2 days – prior to arriving at the firm. When scheduling routine surveillance inspections, FDA prioritizes facilities based on risk factors outlined within its Comprehensive Animal Food Inspection Compliance Program Guidance Manual, which also details regulatory expectations for animal food compliance programs.

 

·       Inspection Observations: Common observations noted during FDA inspections for compliance with its Food Safety Modernization Act (FSMA)-related animal food current good manufacturing practice and preventive controls regulations include: 1) no written food safety plan; 2) inadequate hazard evaluation; 3) failure to implement a preventive control; and 4) prerequisite programs for a hazard are inadequate or lack consistent implementation.

 

·       Remote Regulatory Assessments: FDA in February announced a new pilot study for select medicated animal feed facilities to voluntarily opt in to have the agency conduct Remote Regulatory Assessments (RRA) of records associated with Veterinary Feed Directive (VFD) regulations. Under the program, firms voluntarily share information associated with the VFD regulations to FDA electronically and separate from an on-site inspection. Approximately 60 percent of firms invited by FDA to participate in the pilot program accepted the invitation. Although outcomes from the pilot are still being evaluated, FDA expects to expand the RRA concept in the future.

·       Status of Pre-Market Animal Food Ingredient Reviews: Additional Congressional funding supported by NGFA has allowed FDA to hire 12 new staff members to enhance the timeliness of pre-market animal food ingredient reviews. This additional staff support has enabled FDA to complete reviews in a more timely manner and also establish goals to further improve the process.


AAFCO is the professional organization of federal and state feed regulatory officials. NGFA feed industry members and NGFA staff serve as non-voting advisers to AAFCO committees and participate within committee discussions.

 

Among the other significant issues addressed during the AAFCO meeting were:

 

  •          Common Foods: The AAFCO membership approved a new guideline for a Common Food Index (CFI). The CFI will be a repository of common foods that may be appropriate for use in animal food and are not defined by AAFCO. The CFI is intended for ingredients that are considered common foods that do not require a regulatory safety assessment. The CFI is not a substitute for the regulatory approval processes for new feed ingredient definitions; Chapter 6 of the AAFCO Official Publication, alone, maintains the officially recognized feed ingredient definitions.
  •            Definition of Labeling: The Model Bills and Regulations Committee’s workgroup established to consider revisions to the existing AAFCO definition for labeling is still considering the topic, and likely will have recommendations to present during the next AAFCO meeting. The current definition is as follows: “The term ‘labeling’ means all labels and other written, printed or graphic matter (1) upon a commercial feed or any of its containers or a wrapper or (2) accompanying such commercial feed.” At issue is whether the definition should address just the material that is placed on or accompanies the feed product during distribution, or whether the definition should also encompass other materials, such as marketing information, associated with the product.
  •           Labeling of Flavors: The Model Bills and Regulations Committee’s workgroup established to evaluate whether guidance or other information should be added to the AAFCO Official Publication to provide more interpretation on how to appropriately label products used as flavors, as well as animal foods that contain flavors, is still considering the topic. In addition to flavors the workgroup was charged to consider whether guidance or other information related to animal food colors is warranted.
  •          Vit. D Guarantees for Rabbit Feed and Supplements: The Feed Labeling Committee considered establishing a maximum vitamin D guarantee for rabbit feed and supplements but took no action on the topic. In other business, the committee established a workgroup to review label requirements within the AAFCO Model Regulations and make recommendations on potential revisions.
  •          Menadione Sodium Bisulfite Complex: A workgroup established by the Ingredient Definition Committee recommended that Menadione Sodium Bisulfite Complex (MSBC) be used as a safe and suitable source of Vitamin K activity in the food for all animals in the United States in accordance with good manufacturing and feeding practices. MSBC has been widely used for decades in a variety of animal foods, but is recognized for use in only poultry feeds. In response, the committee made recommendations on how to formalize the acceptability of MSBC for use in other animal feed within the AAFCO Official Publication that will be further considered.

 

  •            Education and Training: AAFCO is developing training courses to address the following topics: 1) understanding pet food labels; 2) feed labeling; and 3) AAFCO’s ingredient definition process. The introductory-level courses will be offered in a virtual, self-paced format and made available to both regulators and industry. In addition, AAFCO is developing a virtual, self-paced training program consisting of several modules that will provide a comprehensive review of the ingredient approval submission methods through which a substance can be recognized as acceptable for use in animal food.
  •           Feed Contaminants/Hazards: The Feed and Feed Ingredient Manufacturing Committee approved revisions to the AAFCO guidelines for contaminant levels permitted in mineral feed ingredients. In response to concerns expressed by industry, the committee agreed to make editorial changes to the document to clarify that levels listed in the guidelines are not intended to be used for regulatory enforcement action. In other business, the committee formed a workgroup to identify animal food nutrients that if included in complete animal food in excess of normal use levels could be considered a hazard or adulterant.

·       Hemp and Animal Food: During the Ingredient Definitions Committee meeting, it was announced that FDA is still reviewing the submission made by the Hemp Feed Coalition to gain approval for the use of hemp seed meal in poultry feed. Currently, there are no hemp products approved by FDA for use in the United States in animal feed or pet food. AAFCO has published guidelines pertaining to hemp to provide information about its regulatory status, and is in the process of updating the document in response to approval for the use of hemp in certain animal foods by some states.

·       Pet Food: AAFCO’s “human grade” pet food guidelines finalized by the Pet Food Committee in May currently are available for public comment. The associated United States Department of Agriculture’s Agriculture Marketing Service (AMS) Process Verified Program for use in voluntary AMS human grade pet food labeling is still under development. In other business, the committee outlined a timeline for completing its initiative to modernize the labels of pet food products. The modernization would establish new label requirements for: 1) pet nutrition facts boxes; 2) nutritional adequacy graphics; 3) ingredient statements; and 4) safe handling directions. The proposed changes are posted publicly on the AAFCO website and the Association is requesting written comments via emailing pflm@aafco.org by Oct. 22.

AAFCO’s next meeting – currently slated to be in-person – will be held on Jan. 18-20, 2022, in Mobile, Ala.