NGFA outlines 2022 feed industry issues

By David Fairfield, Senior Vice President, Feed

Global consumption of animal protein within diets continues to increase, with growing quantities of crops and other agricultural products being used as feed. The Organisation for Economic Co-operation and Development (OECD) and Food and Agriculture Organization (FAO) Agricultural Outlook 2021-2030 Report projects the quantity of cereal grains, protein meals and processing by-products used as animal feed will increase 14 percent over the coming decade, reaching 2 billion metric tons in 2030.  

After another challenging year with COVID-19, the following are six issues that will be factors for the U.S. feed industry during the upcoming year as it strives to satisfy the growing demand for animal protein in a sustainable manner.         

1. Supply Chain: The COVID-19 pandemic and subsequent surge in consumer demand has resulted in major disruptions within the food and agricultural supply chains, including those related to the U.S. feed industry. One example of disruption is the backlog of container ships currently waiting to unload at the West Coast’s shipping ports. Ongoing congestion and related transportation logistical obstacles threaten the ability of the industry to both import and export feed products. 

NGFA leads the Agricultural Transportation Working Group – a broad coalition of agricultural producer, commodity, agribusiness and food-related national organizations – that recently submitted an extensive statement to the U.S. Department of Transportation on actions that could be taken to improve the freight transportation system and mitigate supply chain issues. 

2. Labor: The U.S. feed industry – like many other industries at this time – is struggling to fill open positions that are necessary to meet production, warehousing and transportation demands. Although a variety of factors are impacting the labor market, the Biden administration’s Emergency Temporary Standard (ETS) that will require COVID-19 vaccinations or routine testing for many employers presents yet another obstacle for the feed industry in hiring much needed and scarce qualified workers. 

NGFA has encouraged the administration to continue to recognize the critical infrastructure status of the food and agriculture sector and provide flexibility for agricultural employers to avoid the negative effects a vaccine mandate would have on the efficiency and reliability of the food and feed supply chain. 

3. Animal Food Safety: Jan. 4, 2021 marked the 10-year anniversary of the signing of the Food Safety Modernization Act (FSMA). Even after years of rulemaking and issuance of guidance documents, the U.S. Food and Drug Administration (FDA) is still implementing provisions of this expansive law that fundamentally changed how human and animal food are regulated in the U.S. 

NGFA will be addressing anticipated actions to be taken by FDA in 2022 related to revising certain provisions with the FSMA animal food rule, proposed revisions to FDA’s definition for a “farm,” and continued use of voluntary remote regulatory assessments. In addition, NGFA will continue conducting industry training and educational programs to assist feed companies in understanding and complying with animal food safety regulatory requirements. 

COVID-19 significantly curtailed the level of FDA inspection activity within the feed industry during 2021, but the number of inspections in 2022 could rebound. These inspection activities serve to formalize FDA’s compliance expectations under the FSMA requirements. As such, NGFA monitors inspection outcomes and communicates as necessary with FDA about situations when compliance expectations are not aligned with industry’s understanding of requirements.

4. Climate: The ability of the U.S. food and agricultural sector to continue as the world’s largest hinges on the availability of cropland to produce raw agricultural commodities.  The abundant and affordable production of raw agricultural commodities is the beginning and most important part of a vibrant U.S. animal agriculture sector and feed industry. 

As federal climate change policies are under consideration, NGFA has urged that climate change actions be directed at working land programs to achieve large environmental and economic benefits by incentivizing broader adoption of best management farming and ranching practices across potentially hundreds of millions of our nation’s best acres for agricultural production. In contrast, NGFA continues to oppose the use of policies that idle non-targeted cropland, which reduces U.S. agriculture output, hurts rural economies, and causes a net increase in atmospheric carbon, due to the addition of global cropland to meet growing demand.

NGFA also has urged FDA to modernize its policies related to feed ingredients that reduce enteric emissions, so products having environmental benefits for animal agriculture can reach the market in a more efficient manner. 

5. African Swine Fever (ASF) Virus: With ASF virus in 2021 reaching the Western Hemisphere for the first time in 40 years, the U.S. feed industry in the coming year will keep playing an important role in safeguarding U.S. animal agriculture from foreign animal diseases. 

Feed industry efforts in this area will include gaining a better understanding of the role feed and feed ingredients serve as potential vectors for disease, enhancing practical biosecurity protocols, implementing disease response and preparedness plans, interacting with FDA and the U.S. Department of Agriculture on potential regulatory responses, and examining further research on feed-mitigation measures. Continued focus also will be placed on imported grains and feed ingredients that originate from countries where foreign animal diseases are of concern, and how the potential risk associated with these products can be minimized.  

NGFA in 2022 will continue to be engaged in forums with other industry stakeholders and regulatory agencies to address the potential introduction of foreign animal diseases, including the ASF virus, into the United States via grain and feed products and advocate that a science- and risk-based approach be utilized to address this issue.

6. OSHA: On the Occupational Safety and Health Administration (OSHA) front, the anticipated implementation of the COVID-19 ETS during 2022 takes center stage. The ETS was issued in response to President Biden’s Sept. 9 order for a regulation requiring businesses with at least 100 employees to mandate workers get fully vaccinated or be tested weekly for COVID-19. 

NGFA actively participates in the “Employers COVID-19 Prevention Coalition” and has urged that implementation of the ETS: 1) be consistent across states; 2) allow employers flexibility to continue with existing vaccination policies; and 3) provide a qualified exemption for industries including agriculture, truck drivers, warehouse operators, food manufacturers, and others critical to the nations critical infrastructure supply chain.

In addition, NGFA has expressed its willingness to partner with the administration to develop solutions and educational programs that will expand the number of vaccinated workers in rural America without introducing additional COVID-related risks to the agricultural supply chain.