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U.S. Department of Health and Human Services

Animal & Veterinary

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Pet Food, BSE, Discussed at AAFCO Mid-Year Meeting

by Rod Noel, John Breitsman, and Sharon Senesac 
FDA Veterinarian Newsletter 2002 Volume XVII, No II

The Association of American Feed Control Officials (AAFCO) held its mid-year meeting in Austin, Texas on January 27-30, 2002. There were representatives from 23 States, Canada, U.S. Food and Drug Administration (FDA), the U.S. Department of Agriculture (USDA), and industry.

An Environmental Nutrition Symposium was conducted on Sunday, January 27, 2002. Dr. Floyd Byers, USDA/ARS, spoke on Environmental Nutrition - Focus and Future in Food Animal Production and Dr. L. Wayne Greene, Texas A&M gave a presentation entitled "Feeding Management, Beef Cattle - Perspective". "Biological Assays for Amino Acid Bioavailability in Animal Feeds" was the title of Dr. Steven C. Ricke's presentation, and the symposium ended with Dr. Kyle Newman, Venture Laboratories, discussing "Mannan Oligosaccharides: Defining Structure with Function".

The National Academy of Sciences held an open forum to discuss planned changes to the NRC Dog & Cat Nutrient Requirements Series on Tuesday, January 22, 2002. A new addition to the mid-year meeting was a members-only session where the AAFCO Board discussed important issues with the AAFCO members. This was well-received and will be continued at future meetings.

AAFCO's BSE Task Force held an open session that included an update by CVM's Gloria Dunnavan on FDA's revised BSE inspection checklist and the Agency's activities involving BSE. Dr. Svetlik, a representative from USDA, provided a report on the Harvard Risk Assessment on BSE. Gloria Dunnavan also led a discussion on improving communications between the States and FDA on sharing inspection information and other pertinent information. The BSE Task Force recently completed developing a BSE educational/informational brochure that is now available for distribution. FDA will provide copies of this brochure to the States for distribution in their continuing education effort to achieve full compliance with 21 CFR Part 589.2000.

During the Feed Manufacturing Committee (FMC) meeting, a discussion was held concerning adoption by the members of the "Guidance/Framework for Best Management Practices for Manufacturing, Packaging and Distributing Animal Feeds and Feed Ingredients." A small working group had developed a preamble to the document that provides the intent and purpose of this document. The guidance document was adopted by the membership at the General Session on January 23, 2002. This committee also decided to develop a checklist for use in evaluating and measuring the implementation of this guidance by industry and regulators. As part of the AAFCO's Feed/Food Safety Initiative and with the support of the AAFCO Board and members, the FMC will move forward with the development of process controls for all feeds and feed ingredients. It will start working on principles that would be applicable to all feed manufacturing. Efforts will be made to secure industry cooperation and participation in this project. The FMC must make a decision to pursue these changes as a proposed Federal regulation or as changes to AAFCO's Model Bill & Regulations to be adopted by individual States or both. Finally, the Voluntary Self Inspection Program (VSIP) for medicated feeds was discussed. FDA hopes to launch a pilot program in the very near future and the FMC has offered to assist the agency in that effort.

The Enforcement Strategy for Marketed Ingredients (ESMI) Working Group produced a planned coordinated strategy to address unapproved feed/pet food ingredients and approved ingredients distributed for unapproved purposes. Model regulatory letters and a fact sheet have been developed and are currently available for use in the enforcement of both Federal and State statutes and regulations. With the assistance of CVM, an ingredient will be identified for the State members to take a coordinated uniform enforcement action later this year. To assist in this event, one day of the AAFCO's Feed Administrators Seminar in April will be devoted to training administrators in the background and mechanics for this regulatory event.

The AAFCO Surf Day Working Group discussed the results from its follow-up surf day effort. The information collected during the surf days will be further compiled and distributed to the States, FDA and USDA for possible enforcement actions. The feed industry and AAFCO members have identified e-commerce as an ongoing regulatory issue.

The Pet Food Committee meeting had a full slate of issues. Dr. Bill Burkholder, CVM, presented a proposal to make some changes to the AAFCO Feeding Protocols. These included recording all pet food weights during the trials and limiting the number of years that a feeding protocol would be valid. Five years was the suggested timeframe. Dr. Burkholder also updated everyone on certain label claims such as dental, hairball and FUS. A discussion on the use of the term "Human Grade" on labels was held. Other issues discussed were salvage/distressed pet foods, species name on label, educating the public about pet food labels, organic pet foods and requiring additional guarantees on labels.

The Botanicals and Herbs Committee recommended to the AAFCO Board of Directors that it be disbanded and a single investigator be established. The committee has received no submissions for ingredient definitions since its inception. The AAFCO Board of Directors accepted the recommendation and decided to establish an investigator at such time as there is interest in pursing ingredient definitions in this category.

The Lab Methods & Services Committee continues to work on improving consistency and uniformity in analytical methodology. The Feed Labeling Committee is nearing completion of the feed labeling handbook that is intended to assist both the feed industry and government regulators with understanding labeling requirements. The Feed Labeling Committee is also working on finding a resolution to accurately labeling and monitoring salt guarantees in animal feeds. The Environmental Issues Committee is working on developing a bio-security policy statement for AAFCO and will be gathering existing State bio-security plans. The Ingredient Definition Committee (IDC) has proposed a number of new definitions and proposed changes to others. The IDC is also discussing the status of the animal protein products collective term and if changes are needed. The Collaborative Check Sample Committee has recommended to the AAFCO Board of Directors to support funding a web-based program for processing the data. The Board has agreed to support this recommendation.

A small working group from the Inspection and Sampling Committee and the Feed Manufacturing Committee is working on developing the structure for a Certifying Body (CB) that would oversee the process by which Federal and State inspectors could be certified in the area of animal feed regulation. Members of the CB would consist of key AAFCO members and FDA staff. Discussions are under way with the Division of Federal-State Relations (DFSR) and others in ORA about ORA University serving as the possible Certifying Organization (CO) to implement the inspector certification.

This year's AAFCO mid-year meeting was very productive as the association moves forward with initiatives to address serious regulatory compliance issues, BSE, GMP's for all feed, unapproved feed ingredients, and e-commerce. Solutions to these issues are best achieved in a cooperative effort between Federal and State regulatory agencies, industry and the public. AAFCO meetings provide the forum so that the partnerships can be developed with the impacted parties.

For more information concerning AAFCO, please visit their web site at www.aafco.org.

Rod Noel is AAFCO Secretary-Treasurer. John Breitsman is AAFCO President, and Sharon Senesac is AAFCO Assistant Secretary-Treasurer.