FDA and AAFCO Sign Agreement On Feed Ingredient Listing

The Food and Drug Administration’s (FDA) Center for Veterinary Medicine (CVM) has signed a Memorandum of Understanding with the Association of American Feed Control Officials (AAFCO) http://www.fda.gov/OHRMS/DOCKETS/98fr/fda225-07-7001-mou0001.pdf that allows FDA to formally recognize the Association’s list of feed ingredients and defines the role FDA can play in deciding on the suitability of feed ingredients offered for addition to the list.

“This is a significant step forward in FDA’s effort to enhance the safety of feed. And it allows FDA to formally recognize the valuable contribution AAFCO makes in determining suitability of feed ingredients,” said Dr. Dan McChesney, Director of CVM’s Office of Surveillance and Compliance.

AAFCO is a voluntary organization comprised largely of regulatory officials who have responsibility for enforcing their state’s laws and regulations concerning the safety of animal feeds.  Its membership is comprised of representatives from each state in the United States, as well as representatives from Puerto Rico, Costa Rica, Canada, the FDA and the U.S. Department of Agriculture.

“FDA and AAFCO have had a long and successful working relationship,” said Dr. Sharon Benz, Director of CVM’s Division of Animal Feeds.  “This agreement allows AAFCO and FDA to leverage that relationship in a way that will improve feed safety.”

A basic goal of AAFCO is to provide the means for ensuring the development and implementation of equitable laws, regulations, standards, definitions, and enforcement policies for regulating animal feed.  AAFCO has no enforcement authority.

AAFCO publishes an annual Official Publication (OP) that includes a list of all ingredients AAFCO has reviewed and found suitable for use in animal feeds.  The OP also provides a list of ingredient definitions and common or usual ingredient names.  FDA has informally cited the OP’s ingredient list and has acted as AAFCO’s scientific advisor in reviewing petitions for the addition of ingredients to the list or for changes in the ingredient definitions.  However, the OP list does not have the force of law.

FDA’s formal recognition of the AAFCO list is one of the specific recommendations made in a “Framework Document” drafted by FDA’s Animal Feed Safety System (AFSS) Team http://www.fda.gov/cvm/AFSS.htm.  FDA created the ad hoc AFSS Team four years ago to develop ways to modernize the feed safety system in the United States.  The Team has identified “gaps” in the current animal feed regulatory structure (including the fact that FDA has no formal list of suitable ingredients) and offers recommendations for closing the gaps.

AAFCO uses a “New and Modified Feed Ingredient Definitions Process” to determine the suitability of feed ingredients and to establish standard ingredient names, which FDA considers the common or usual name, used on feed labels as required by state and federal law.  This memorandum allows FDA to recognize formally the AAFCO process and to have a clearly defined role in reviewing ingredients for the list.

Under the memorandum, CVM assigns scientists to work with AAFCO in reviewing petitions for new feed ingredients or for modifications to existing ingredient definitions. In addition, before it adopts a new feed ingredient definition or amends an existing one, AAFCO will ask CVM for advice and a letter of concurrence.  The memorandum also requires AAFCO to remove a definition from its OP if FDA provides convincing scientific evidence that the ingredient is no longer suitable for its intended purpose.