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U.S. Department of Health and Human Services

Animal & Veterinary

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FDA Letter Reminds Feed Manufacturers of Their Obligations

by Walt D. Osborne, M.S., J.D., Assistant Editor
FDA Veterinarian Newsletter 2007 Volume XXII, No II

The extensive recall of pet foods that began in March 2007 due to contamination with melamine and its analogs led to the issuance of a letter in May 2007 from CVM Director, Dr. Stephen Sundlof, to feed and feed ingredient manufacturers reminding them of their legal responsibilities.

Specifically, every ingredient used in an animal feed or feed ingredient must be safe for its intended use, whether the product is meant to be used to feed animals intended for human consumption or to feed non-food animals, such as pets. In the letter, manufacturers were encouraged to make sure they have procedures in place that ensure the safety of the products and ingredients in their products, as well as the safety of the packaging and processing supplies they use. In addition, manufacturers should also verify that their suppliers have such procedures in place.

As the letter noted, manufacturers are responsible for taking their own measures to ensure the safety of their marketed products. They should not wait for possible FDA testing of their materials before pursuing the necessary steps to achieve a high level of safety.

Screening procedure

Companies that are interested in performing their own tests for melamine and its analogs can refer to FDA’s Web site. The methodology used by the Food Emergency Response Network laboratories can be found there. As indicated at the link, this version (2.1, dated May 16, 2007) of the gas chromatography (GC) and mass spectrometry (MS) method for the presence of melamine, ammeline, ammelide, and cyanuric acid should be regarded as interim. This procedure was developed to screen various matrices for the presence of melamine and some related compounds at the established minimum reporting level of 10 micrograms per gram and above, using GC/MS. Samples are extracted using a mixture of acetonitrile/water/diethylamine, and the analytes are subsequently converted to trimethylsilyl derivatives for analysis.

Surveillance

As part of a protein ingredient surveillance assignment FDA issued on May 1, 2007, FDA, in conjunction with State regulatory authorities, has been performing inspections of various food and feed facilities. A variety of protein ingredients commonly used in food and feed manufacturing have been sampled and tested for the presence of melamine and melamine-related compounds, all of which are known as triazines. Protein concentrates such as wheat gluten, corn gluten, corn meal, soy protein, and rice protein concentrate imported from China or transshipped from China will be tested. During these inspections, FDA will point out the importance of ensuring the safety and security of the manufacturers’ ingredients and products by knowing their manufacturing and packaging operators, ingredient suppliers, contract manufacturers, and sources for all incoming materials.