By Chandler Hansen, Special to NEAFA
During the NEAFA Annual Meeting this past June at the Turning Stone Resort in Verona, NY, Louise Calderwood, Director of Regulatory Affairs at American Feed Industry Association, presented an AFIA update to attendees.
Calderwood opened by sharing information on the animal feed trade. “U.S. feed exports total $7.5 billion,” said Calderwood. “$5.5 billion of this total are feed & feed ingredients, and the remaining $2 billion are pet food products. The top three export markets are China, Japan, and Singapore. China in particular has seen a large increase in exports, going up 33% since 2020. Alfalfa/hay and other feed products have been the top commodities getting exported to China.” When asked why China and other nations in Southeast Asia have been growing, Calderwood shared that many nations in the area are developed enough now that having pets is more common, which means there are more feed needs in the region.”
Port/Export container issues have been an ongoing problem that Calderwood spoke about. “Increased cost of Asian-based imports, increased fees, inability to export, lack of containers, and COVID-19 lockdowns in China have all created problems,” said Calderwood. “Some solutions that AFIA has been advocating for are an Infrastructure package that includes funding for port upgrades and the passage of the Ocean Shipping Reform Act. However, more port infrastructure in general and more collaboration on the intermodal system are still needed.”
FDA and State inspections were the next portion of the address. Calderwood showed statistics of FDA Current Good Manufacturing Practices inspections and FDA Preventive Controls inspections. Both of these showed that the vast majority of inspections deemed that there was “no action indicated,” said Calderwood. “Some observations from CGMP inspections were that feed manufacturers should evaluate the quality of their raw materials and ingredients, and should take precautions to ensure that plant operations don’t contaminate animal food. Issues observed through PC inspections were typically a failure to identify and implement PCs, a lack of a written Food Safety Plan, and a lack of a written hazard analysis or evaluation of each known or foreseeable hazard.”
Calderwood also talked about OSHA and EPA update. “Some of the Department of Labor’s early priorities have been increased budget, more inspections, increased news releases of inspection results, and they are continuing to seek maximum penalties,” said Calderwood. “Some of the items on OSHA’s watchlist have been Powered Industrial Trucks Rule Update, Lockout/Tagout Rule Update, Potential Infectious Disease Standard, Potential Heat Illness Prevention Standard, Potential Emergency Response Preparedness Rule Update, Occupational Injury and Illness Recordkeeping Regulation Update.”
Some EPA actions that have been affecting the feed industry involve rodenticides, formaldehyde, and chlorpyrifos. Calderwood explained, “Rodenticides are currently undergoing its normal 15-year registration review. AFIA has had conversations with the EPA, USDA, and FDA on this matter. There is a very good chance that bulk forms of these products may become ‘restricted use’ pesticides. In the case of formaldehyde, it is undergoing three risk assessments by the EPA. It is classified as a human carcinogen, and it is used in animal food as an antimicrobial. AFIA is encouraging the EPA to follow the science on this matter. Lastly, the EPA recently ruled on chlorpyrifos and food containing residue of chlorpyrifos would be considered adulterated. The FDA will practice enforcement discretion for products containing the substance.” Calderwood also briefly mentioned PFAS and work being done in various states with that problem. In Maine, there is an observational study for the substance. In Vermont, more focus is on its presence in the soil, while in New York the focus is more on water.
A portion of Calderwood’s presentation was devoted to the threat of African Swine Fever. AFIA has been working with government agencies and feed industry organizations in devising a response if an outbreak of ASF should occur in the U.S. “In the event of an outbreak, a federal order will input a nationwide 72-hour standstill where no movement of swine or germplasm will be allowed,” said Calderwood. “Infected zones will be identified and depopulation of infected herds will start. After 72-hours, states will take over the response, controlling infected areas and limiting and tracing movement in infected areas. We encourage producers to determine ways to ease the impact of an event like this, and it may involve creative solutions like working with a competitor.” ASF can spread not just through swine to swine transmission, but also through pork products or equipment and clothing, so the importance of biosecurity was greatly stressed to attendees.
Lastly, Calderwood discussed label claims. In September 2020 AFIA made an appeal to the FDA to modify a portion of its CVM Guide. The request asked for the establishment of a policy for products that act in the digestive tract to be regulated as food, and for alignment with the regulation of structure/function and health claims in developed countries. Calderwood explained that any changes that result from the request will be revised by December 2022 and the implementation of the changes will occur in 2023.