Meanwhile, AFIA asked FDA to revise it to include the following: “No reportable food report is required if a load of incoming product has been sampled, but legal transfer has not occurred, provided the trailer is on the premises of your facility only for as long as is necessary to sample, test and reject the shipment, and no longer. Your facility has not ‘held’ the reportable food. Therefore, you are not a ‘responsible party’ with regard to such food.”
“Microbial contamination:” The definition of ‘microbial contamination’ of animal feeds and raw materials needs particular clarification, AFIA said. The draft guidance implies any positive test result makes the feed or ingredient a reportable food, but it’s well known, based upon studies and testing, that Salmonella found in feed “generally do not make the animals sick and pose little risk to livestock owners.”
The NGFA noted that it is up to the facility to determine whether a particular contaminant, including microbial contamination, meets the reportable threshold based upon current research and scientific understanding.
Sellers points out there isn’t sufficient scientific justification as to the mere presence of Salmonella in feed to conclude any risk rises to the level of having to report the food. He cites a Food & Agriculture Organization (FAO)/World Health Organization (WHO) 2007 report to support the association’s call for clarification that the presence of a human pathogen in a raw ingredient or finished livestock or poultry feed does not cause them to be a reportable food. Sellers acknowledged this would not apply to pet foods.
In addition, Sellers met with two deputy administrators of the USDA’s Agricultural Research Service (ARS) to discuss FDA’s recent release of a new Salmonella Compliance Program Guide (CPG). These FDA guides are Washington directions to the field staff detailing how to enforce FDA laws and rules.
The CPG states specific pathogenic Salmonella found in certain farm animal feed will be considered adulterated and if fed to animals will be reported to USDA for possible recall of the meat, poultry, milk or eggs. Although this appears much better than recalls for any type of Salmonella in feed as in the current policy, The specific salmonellae found in feed could present large potential liability issues for the feed industry given that they are not scientifically proven to be an animal or human health hazard.
The objective of meeting with ARS was to explain the new FDA CPG, ask for assistance in defining infectious dose for the specific Salmonella organisms listed in the guide and determine how industry and ARS could cooperate to create research protocols to address concerns with this policy.
Comments to FDA regarding the Salmonella Compliance Policy Guide are due Nov. 1. AFIA and NGFA will submit comments on this important issue. AFIA plans to continue working with USDA/ARS on a research plan.