NGFA Weighs in on Voluntary International Animal Food Safety Standard

The National Grain and Feed Association (NGFA) has submitted extensive recommended changes to a new proposed draft voluntary standard designed to establish a common set of requirements for prerequisite programs used by facilities to assist in controlling food safety hazards in the manufacturing of animal foods and ingredients intended for use in the production of animal food.

In a statement submitted this month in response to the British Standards Institute’s (BSI) request for stakeholder comments, the NGFA commended the SSAFE organization — an international public/private partnership formed to integrate food safety, animal health and plant health across food supply chains — for sponsoring the proposed BSI standard that would establish voluntary food safety requirements for the prerequisite programs used for manufacturing food and ingredients for animals.

In doing so, the NGFA noted that the growing awareness about the vital role that food for animals plays in achieving the safe production of meat, milk and eggs likely will increase the demand for firms engaged in the animal food industry to be certified to a recognized and accredited food safety standard. The NGFA also noted that a single, internationally recognized standard could be very beneficial in alleviating the potential need for animal food manufacturers to obtain multiple food safety certifications based upon different standards that likely would provide limited benefits in enhancing animal food product safety, and instead create additional and excessive costs that ultimately largely would be passed on to consumers.

Established in 1896, the NGFA is a U.S.-based nonprofit trade association that consists of more than 1,000 grain, feed, processing and grain-related companies comprising more than 7,000 facilities that handle more than 70% of U.S. grains and oilseeds. Affiliated with the NGFA are 26 state and regional grain and feed trade associations. The NGFA also has strategic alliances with the North American Export Grain Association and Pet Food Institute.

In its statement, the NGFA provided overarching comments pertaining to several concepts incorporated within proposed standard, including:

• Hygienic Standards Necessary to Ensure Animal Food Safety: The NGFA stated that it fundamentally believes that recognized and accepted safety requirements for human foods are not always appropriate or necessary to ensure the safety of animal food and animal-based foods consumed by humans. The NGFA stressed that a distinction in the necessary manufacturing practices for human foods versus animal foods is proper and has a sound scientific basis. As an example, the NGFA noted that the innate hygienic standards of humans clearly exceed the hygienic standards of livestock, poultry and other animals. As such, the NGFA said it is reasonable that the hygienic safety standards necessary to manufacture human foods should exceed the hygienic safety standards for animal food and ingredients used in animal food, and that it is imperative that requirements within the proposed BSI standard for animal food appropriately reflect that fact.

• Scope of Applicability: The NGFA noted that the scope section of the proposed standard states, “This (publically available standard) is applicable to all organizations, regardless of size, location or complexity, that are involved in the supply and manufacturing (including storage, distribution and/or transportation) steps related to compound animal food and ingredients utilized in the manufacture of such animal food, and that wish to implement a (prerequisite program).” In this regard, the NGFA said it would be a daunting task to develop a single prerequisite program standard that establishes the appropriate requirements necessary to assist in controlling food safety hazards for the entire gamut of firms serving the animal food industry. To assist in alleviating this challenge, the NGFA urged SSAFE to include within the proposed standard additional criteria that could be used by a facility to justify that it should be exempt from a given requirement established by the standard.