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U.S. Department of Health and Human Services

Animal & Veterinary

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AAFCO Ingredient Definitions: Setting the Standards

by Jon F. Scheid, Editor
FDA Veterinarian Newsletter 2007 Volume XXII, No V

The Association of American Feed Control Officials (AAFCO) first started defining feed ingredients in 1909, just as the commercial feed industry was beginning to take shape in the United States. Since then, the nature of feed ingredients has become increasingly complex, but AAFCO has continued its role of defining ingredients, and now the Association has an agreement to formally work with scientists from the Food and Drug Administration to ensure the safety of ingredients.

AAFCO’s function is to ensure the development and implementation of laws, regulations, standards, definitions, and enforcement policies for regulating animal feed throughout the United States. AAFCO itself has no enforcement authority, but its members do. AAFCO’s membership includes regulatory officials from each State who have the authority for ensuring the safety of feed. Although members of the feed industry and the public may participate with AAFCO and its committees, only regulatory agencies and officials are actually members and able to vote and conduct other official business.

FDA recently recognized AAFCO’s process for developing its ingredient list by signing a Memorandum of Understanding (MOU) with AAFCO. (See related story, “CVM, AAFCO Sign Agreement on Feed Ingredient Listing,” on page 3.) The MOU specifies how FDA can work with the Association in reviewing the ingredient petitions submitted for new ingredient listings or for modifications of existing listings.

Acceptable feed ingredients along with their definitions are listed in AAFCO’s Official Publication (OP), published annually. New ingredients are added or existing definitions changed by means of petitions submitted by industry representatives. The petitions are reviewed by an AAFCO investigator, who has the responsibility for the applicable category of ingredients. AAFCO has more than 30 feed ingredient investigators, each with a different ingredient specialty.

Most of the investigators belong to State feed control agencies, but six, including Shannon Jordre, who is chair of AAFCO’s Ingredient Definitions Committee and a Consumer Safety Officer with FDA’s Center for Veterinary Medicine, work for FDA. (Mr. Jordre’s ingredient specialty is miscellaneous and special purpose feed ingredient products.)

When a petition arrives, an AAFCO investigator or FDA scientist reviews it to make sure it contains the information required by The Guide to New and Modified Ingredient Definitions in the OP, such as information about the ingredient and its intended use (including limitations). The investigator also makes sure the petition includes copies of the scientific literature cited concerning the product’s safety, and presents any concerns about toxicity or carcinogenicity, Mr. Jordre said.

Mr. Jordre said that investigators submit nearly all petitions to FDA for a safety review. FDA may not need to review petitions requesting only simple changes, such as a change to an ingredient’s nomenclature, he added.

Any time an ingredient presents a safety concern to the animal that consumes it, or the use of the ingredient will create a food safety risk, FDA will recommend against AAFCO adopting a definition until the ingredient has been the subject of an approved food additive petition.

If FDA finds that a proposed new ingredient is suitable for use in animal feeds, the AAFCO investigator will then submit the request to AAFCO’s Ingredient Definitions Committee during one of the two public meetings AAFCO holds each year. If accepted by AAFCO, the definition will appear in the next edition of the OP. In the meantime, the sponsor may market a product after receiving a letter from FDA saying that the Agency will use regulatory discretion and not take action against the use of the ingredient, when labeled and used as directed.

The ingredient listings in the OP reflect the increasing complexity of the feed industry over time. Some of the earliest definitions, dating back more than 80 years, were relatively straight forward. For example, “Ground Ear Corn” and “Wheat Bran” were added to AAFCO’s official list prior to 1920. More recent additions, such as “Soybean Meal, Dehulled, Mechanical Extracted,” added in 2004, show how new technology used in ingredient manufacturing has changed the type of ingredient submitted for a definition and listing in the OP.

Copies of the OP are available from AAFCO through its Web site.