AAFCO Moves Forward with GMPs

The Association of American Feed Control Officials’ Feed Manufacturing Committee, chaired by Judy Thompson of the Canadian Food Inspection Agency, has completed its eight-year drafting of the Model Good Manufacturing Practices Regulations (GMPs) for Feed and Feed Ingredients.

The committee voted to send the draft to the AAFCO Board of Directors with the recommendation that it be forwarded to the AAFCO Model Bill Committee for review and formatting. The Board will likely honor that request, and if that committee concurs, it will return the draft to the Board for review and development of a recommendation to the AAFCO membership. Subsequent action will likely occur at the AAFCO Midyear Meeting in San Antonio, Texas, January 28-30, 2008. Although this seems like a fast-track approach, both industry and AAFCO agreed the scenario was necessary.

These model regulations, when adopted by AAFCO, will be available for any state to adopt, which is required for enforcement. AFIA has argued strongly that only a few states will adopt them in the next few years, making the uniform enforcement of such rules nearly impossible. Due to the costs of compliance, any feed mill located in a state adopting these rules will be at a competitive disadvantage to those in surrounding states that do not adopt the rules.

A recent survey of the states by the the American Feed Industry Association (AFIA) Feed Regulatory Committee found only half the states that responded had a thorough knowledge of the draft rules and less than half were intent on adopting them. As these rules are a major undertaking, it is likely that few states will actually go through the rulemaking process.

AFIA will argue for a one-year implementation phase for any state adopting the rules to provide training about them and for firms to begin formatting a regulatory program to comply.

Generally, the rules govern what a facility must do to minimize the potential risk of hazards that can contaminate feed and affect the health and well-being of animals or humans that consume the meat, milk, eggs or fish from the animals. In the preamble, it states that the rules " ¦shall also govern those instances in which failure to adhere to the regulations has caused feeds that are manufactured, processed, packed transported or held to be adulterated." This is same standard utilized in the federal medicated feed GMP regulations.

AFIA believes its Safe Feed/Safe Food Certification Program meets and in many cases exceeds the requirements AAFCO is expected to adopt. The AAFCO proposed rules are more proscriptive than the SF/SF program, which allows firms to define how compliance with the guidelines can be achieved.

AFIA urges those firms involved in feed, ingredient and pet food manufacturing to review and become familiar with the proposed rules. This will enable firms to adequately address any concerns that arise during their respective state's adoption process.

Please direct any questions regarding the proposed regulations to AFIA VP Richard Sellers: sellers@afia.org.

Final draft link