Some EU regulations are slightly different from United States feed regulations. American companies doing business with European customers have had to rely completely on self-audits to ensure that their feed meets EU standards.
Companies who trade globally, such as Alltech, could use the SF/SF program as an example of how to self-audit for EU regulations, but could not rely on FCI audits alone. “The SF/SF program has not been recognized and did not satisfy the requirements for trading in Europe,” says Timmons. “SF/SF gave us the basic foundation for a system, which we then took further to meet the EU requirements. The EU requirements include a Hazard Analysis and Critical Control Point component in addition to the quality system of SF/SF. SF/SF gave us the experience to add the necessary HACCP components.”
The key difference between EU and FDA regulations is the inclusion of HACCP. In the EU, there are mandatory HACCP regulations, with specific HACCP requirements for feed, ingredient and pet food facilities. EU facilities had to be compliant with HACCP principles starting in 2006, and imports from countries such as the United States have had to comply since 2007.
“U.S. officials and feed and ingredient manufacturers believe there are several routes to making safe feed that meets both government requirements and individual quality standards. HACCP, which is required in the EU, is one such tool, but it is not the only one used by U.S. firms,” says Jerrod Kersey, AFIA director of ingredients and state legislative affairs.
Since American feed companies must now comply with EU regulations in order to trade with Europe, it’s important for associations to create these third-party certification programs because the FDA only inspects for U.S. regulations. “For example, at this time, U.S. officials will not certify that any U.S. facility is compliant with the European Union’s feed hygiene regulation [Regulation 183/2005] and other EU rules,” says Kersey. “Certain EU requirements on the manufacture of feed, pet food and ingredients are generally not found in the United States and vice versa.
“The EU’s focus on implementing Regulation 183/2005 had been initially on its member-states, but now the EU is beginning to apply the regulation to the United States and other countries. This means it’s all the more important for feed industry stakeholders in the United States and the EU to cooperate and boost education and understanding,” says Kersey.
The establishment of an international Safe Feed/Safe Food Certification Program will go a long way toward making sure U.S. and EU firms have the same understanding of the regulations they face. While EU and U.S. regulations vary, the auditing process will help ensure facilities on separate continents are on the same page.
“It makes sense for AFIA to select FEFANA’s FAMI-QS [European Feed Additives and Premixtures-Quality System] program to partner with at this time,” says Kersey. FAMI-QS is one of three such programs recognized by the EU in the European Journal, and it is one of two with an active certification program for ingredients. FAMI-QS is specifically designed to help feed and ingredient makers meet the regulatory requirements of the EU.”
Once the international version of the SF/SF Certification Program is fully up and running, FAMI-QS inspectors will certify U.S. facilities, and FAMI-QS-certified facilities in Europe may apply for SF/SF certification.
If a facility is already in SF/SF and would like to be part of the international program, employees would have to incorporate the additional principles into the plant’s day-to-day routine and inspection process.
If a firm is not currently participating in SF/SF and only wants to be part of the international version of the SF/SF program, then a new type of inspection not already used at the plant would be required. As the basic SF/SF program does not meet EU feed hygiene requirements, a FAMI-QS audit would be required to comply with the EU requirements.