Written by: Leah Wilkinson | March 23, 2021
I was three weeks into my new job with the American Feed Industry Association when then-President Obama signed the Food Safety Modernization Act into law and the learning curve began. I was working for Richard Sellers, who wisely offered the advice that there is no better way to learn an industry than to go through a massive overhaul of its regulations! Many reams of paper, hundreds of hours of conference calls, countless pounds of chocolate consumed, and now, the law has been implemented via the regulations and the industry has excelled in its compliance.
While the law has been in place for over a decade, it is important to remember that it took the Food and Drug Administration several years to write the regulations, draft guidance and train state and federal inspectors on how to inspect against the regulations. Now, with four years of compliance under our belts, I can say that I do not believe FSMA drastically changed the way we produce safe feed and pet food in the United States, but it has changed the language we use and some of our processes.
For example, most of our manufacturing facilities already had sanitation and prerequisite programs in place for non-medicated feed, pet food and ingredients, but FSMA codified this through the Current Good Manufacturing Practices (CGMP) program. Many manufacturers also had food safety programs, but the new law required them to identify and address hazards through a written animal food safety plan unique to each facility. However, FSMA did institute a few new requirements for verifying the safety of ingredients coming from foreign suppliers and for the sanitary transport of feed and pet food. These measures have served as an added bonus to our constantly evolving biosecurity programs.
Over the years, our association called upon the FDA to allow the industry flexibility in complying with the regulations, which provided facilities the opportunity to develop innovative solutions based upon their specific needs and ample time to implement the changes. We thank the FDA for not using a “one-size-fits-all” approach with implementing this massive food safety law and for phasing in compliance with parts of the regulation by facility size to ensure companies could adequately prepare.
Our members spent considerable time and resources preparing their facilities and grounds and training employees to comply with the regulations. At the AFIA, we did our part too – providing training and tools to set our members up for success. This included working with the Institute for Feed Education and Research to conduct a literature search that assisted facilities in conducting their hazard analyses, developing a sample food safety plan for facilities to reference, creating instructional videos and holding in-person courses to train over 600 preventive controls qualified individuals.
As with any industry during times of change, we saw some attrition with some smaller companies struggling with the costs and resources needed for compliance, but most companies were already headed in the right direction when it came to improving their safety practices as the science has evolved. FSMA just gave those companies greater opportunity to shine.
Overall, I think FSMA has helped our facilities compile all their food safety information into robust food safety plans and boost employees’ awareness of their role in promoting feed and pet food safety. Animal food manufacturers have a good food safety story to tell and FSMA has given them the opportunity to articulate it clearly to regulators, suppliers and our customers. Moving forward, especially as we emerge from the pandemic, we expect that in-person FSMA inspections will ramp up again and with more data, we will only continue to improve in demonstrating our compliance with FSMA requirements.