Further, concerning the numerous prerequisite program requirements proposed within the voluntary standard, the NGFA, among other things, recommended that SSAFE:
- Further clarify the proposed provisions that would require a facility’s site boundaries to be “clearly identified” and access to the site “controlled.” In doing so, the NGFA stated that installing physical barriers frequently are not necessary, practical or cost-effective for product safety because of the configuration of the facility, its surroundings and/or the relative risk identified through a facility vulnerability assessment. Further, the NGFA noted that facilities should implement controls appropriate to their respective threat levels to prevent unauthorized persons from having access to critical assets or areas, as identified through a risk assessment.
- Delete from the standard a proposed requirement that would prohibit the use of compressed air for cleaning. In adamantly opposing this proposed requirement, the NGFA stated that using compressed air is a practical and effective method to remove debris and improve sanitary conditions within a facility. Further, the NGFA said it is unaware of valid scientific evidence that indicates use of compressed air for cleaning contributes to potential animal food safety issues by “spreading contaminants throughout the facility,” as alleged in the draft proposed standard.
- Delete the proposed provision that would require equipment to meet established principles of hygienic design, including “framework not penetrated by holes or nuts and bolts.” The NGFA stated, to its knowledge, there are no established consensus standards that specifically describe the hygienic design principles to be incorporated within equipment used in the manufacture of animal food. Further, the NGFA stated it was not aware of any evidence that the very common occurrence of nuts and bolts penetrating the framework of storage bins and other various equipment used in the manufacture of animal food and feed ingredients poses animal food safety issues.
- Clarify a proposed provision that would require product contact surfaces to be “corrosion-free.” Specifically, the NGFA requested that SSAFE provide a definition for “corrosion-free.” The NGFA noted that the use of stainless steel materials for product contact surfaces during the manufacture of dry animal food is not common, and, more importantly, not necessary to assist in controlling potential food-safety contaminants. Further, if SSAFE is referring to the use of stainless steel materials when it uses the term “corrosion-free,” the NGFA said, it strongly disagrees with the proposed requirement and recommended that it be deleted.
- Delete the proposed requirement that a “list of materials that are an acceptable (positive) and/or unacceptable (negative) prior use of bulk conveyances and containers shall be maintained.” The NGFA strongly disagreed with this proposed requirement, stating that: 1) it virtually is impossible to create a negative list that encompasses all of the potential prohibited materials that may be objectionable; and 2) creating a negative list erroneously implies there are situations where conveyances cannot be used to convey animal food materials, regardless of the methods used to clean and sanitize such conveyances.
The NGFA’s membership encompasses all sectors of the industry, including country, terminal and export elevators; feed and feed ingredient manufacturers; biofuels companies; cash grain and feed merchants; end users of grain and grain products, including processors, flour millers, and livestock and poultry integrators; commodity futures brokers and commission merchants; and allied industries. Canadian and Mexican firms also are NGFA members, and use its Trade Rules and Arbitration System by specific reference in their contracts.