FSMA Final Rule Released; AFIA Prepped and Ready
Richard Sellers, senior vice president of legislative and regulatory affairs
Tuesday, September 15, 2015
by: Richard Sellers, senior vice president of legislative and regulatory affairs

Section: Fall 2015

On Sept. 17, the long awaited Food Safety Modernization Act “Current Good Manufacturing Practices and Hazard Analysis and Preventive Controls for Food for Animals" final rule was published in the Federal Register by the U.S. Food and Drug Administration. The American Feed Industry Association is pleased FDA followed through with its request for a phase-in approach to implementation, giving all animal food manufacturing facilities additional time to execute Current Good Manufacturing Practices (CGMPs) followed by the hazard analysis and preventive controls. 
The phase-in process allows firms more time for adjustment to basic program requirements such as CGMPs before adhering to more complicated aspects of the final rule. AFIA applauds FDA’s reorganization that animal food is different from human food in revising the CGMPs to be more applicable to animal food facilities and addressing the hazards in our industry.  
To read AFIA’s initial thoughts post release of the final rule, click here.
In an effort to assist with FSMA compliance, AFIA will co-host an Oct. 7, webinar with Feedstuffs from 2 to 4 p.m., and has scheduled two in-person trainings, one Dec. 8, in Arlington, Va., and the second Jan 27, 2016, at the International Production & Processing Expo in Atlanta, Ga.. To stay up-to-date on trainings and webinars, click here
AFIA provides its member with weekly FSMA newsletters and the AFIA FSMA work groups reactivated to assist in developing clarification questions and discussion groups with FDA and other organizations. The work groups were critical in developing the industry comments. AFIA intends to partner with other organizations to reach the maximum number of firms about the final rule. AFIA expects the major issue of CGMPs versus preventive controls will govern AFIA's training and AFIA will focus on explaining to members how to comply with the FSMA final rules.
Next summer, AFIA plans to provide the industry with a generic hazard analysis that contains nearly all the known or reasonably foreseeable hazards in the feed manufacturing industry and most of the ingredient industry. This document will need to be reviewed by each facility's preventive controls qualified individual—the person the proposed rule says is such by training and/or experience—and adopted as appropriate to the facility and incorporated into the facility's animal food safety plan. To accomplish this feat, AFIA is working with Assistant Professor and Co-director of the Veterinary Public Health and Preventive Medicine Residency Program, Dr. Tim Goldsmith, of the College of Veterinary Medicine at the University of Minnesota. 
Finally, AFIA will continue its work with the Food Safety Preventive Controls Alliance to produce examples, qualified individual training and workshops to fully incorporate the FSMA rules into the industry's practices. This group provides an excellent interface with industry and FDA on the task of training both industry and FDA investigators, soon to be called auditors.
To keep track of FSMA updates from FDA, visit the FSMA webpage, www.fda.gov/fsma, and sign up for email updates. To contact an AFIA staff member regarding FSMA, call (703) 524-0810 or email afia@afia.org.  
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