Thank you. It looks like it is still up in the air as to how much animal feed the facility must sell in a year to come under these proposed regulations. They appear to have put in $500,000 a year in average annual sales as a starting point in the discussions for that threshold. The implication is that if your annual sales are under whatever that threshold is, this does not apply to you. Really small businesses are exempt. If they give it away instead of selling it, they are probably exempt. I doubt they are just giving it away though and if they are selling a certain amount they have to comply.
It looks like they got the greater than and less than signs mixed up. Otherwise that threshold makes no sense. These things exempt small businesses and only apply to the big boys.
If this applies, the business has to have a food safety plan. I copied that section below, but to summarize, they would have to identify how that food could become dangerous to the animals and come up with a plan to minimize the risks of the food becoming dangerous to the animals.
What part of that is objectionable to you? Should they not handle that spent grain in a way that it doesn’t become dangerous to your animals? It doesn’t say they have to change what they are doing if what they are doing is safe. There probably would be some recordkeeping requirements they don’t have now. It’s quite possible one the risks identified is strangers digging through those barrels before the farmer shows up. That may mean they can’t give it to you but maybe they can work that out. You may just have to log in that you took some. I don’t know how they might handle that.
That document is open to public comment. Instead of just say I’m against it, how about letting your congressman and senators know what part is objectionable to you and how you would propose to change it. That’s the way the system is supposed to work. I’ve seen other proposals like this changed because of public comment. That monetary threshold thing looks wide open right now and is real subject to change.
Each facility would be required to prepare and implement a written food safety plan, which would include the following:
A Hazard analysis that would identify and evaluate known or reasonably foreseeable hazards for each type of animal food manufactured, processed, packed, or held at the facility.
Preventive controls, which would be identified and implemented to provide assurances that hazards that are reasonably likely to occur would be significantly minimized or prevented. These preventive controls would need to be appropriate for the facility and the animal food being produced, and could address, for example, animal food processing, prevention of cross-contamination, and sanitation affecting animal food safety. A recall plan for animal food for which there are hazards that are reasonably likely to occur would be required. It is unlikely that all possible prevention measures and verification procedures would be applied to all animal foods at all facilities. FDA believes a supplier approval and verification program is a risk-based and appropriate control to significantly minimize or prevent hazards from raw materials and ingredients that is consistent with current scientific understanding of food safety practices. Although it is not included in the proposed requirements, it is discussed in the preamble and FDA is seeking comment on such a program.
Monitoring procedures that would provide assurance that preventive controls are consistently performed and records to document the monitoring.
Corrective actions that would be used if preventive controls are not properly implemented. Facilities would be required to correct problems and minimize the likelihood of reoccurrence, evaluate the animal food for safety, and prevent affected animal food from entering commerce. If specific corrective action procedures were not established for the problem, or if a preventive control is found to be ineffective, the facility would also be required to re-evaluate the food safety plan to determine if modifications are needed.
Verification activities to ensure that preventive controls are consistently implemented and are effective. Verification activities might include records review of monitoring, correction actions, or instrument calibration. Preventive controls would also be required to be validated to ensure they are effective in controlling the hazard. In addition, the food safety plan must be reassessed at least every three years and otherwise when necessary. FDA recognizes that product and environmental testing programs are scienceâ€ï¿½based verification activities that are commonly accepted in many sectors of the food industry. Although they are not included in the proposed requirements, they are discussed in the preamble and FDA is seeking comment on these programs. FDA also is asking for comments regarding review of customer and other complaints as part of verification.
Recordkeeping: Firms would be required to keep a written food safety plan, including the hazard analysis. They would also be required to keep records of preventive controls, monitoring, corrective action, and verification procedures.
