NGFA–Pet Food Institute Joint Conference Addresses Food Regulation Concerns

Faegre & Benson sponsored and attended the first annual Feed and Pet Food Joint Industries Conference held on September 22–24, 2010, in Chicago.

Topics covered by this conference included emerging trends in animal rights, manufacturer sustainability initiatives, developing a feed–pet food defense plan, global food safety issues, and OSHA and EPA regulatory issues affecting feed operations. Also in attendance were many of the major agribusiness companies as well as many industry leading organizations.

Overall, the consensus among industry and governmental participants was that heightened regulation of the feed sector is inevitable.

Key Information

Dr. Daniel G. McChesney, director of the Office of Surveillance and Compliance of the FDA Center for Veterinary Medicine, provided the keynote address at the conference. His key messages included:

Issues relating to the feed supply are an issue of concern to the current administration.

Regardless of whether statutory changes (i.e. passage of the Food Safety Modernization Act) are made to increase FDA's authority in this arena, change is coming.

    The FDA intends to take a more active regulatory role within the feed industry .

    If the Food Safety Bill is ultimately enacted, according to McChesney, its passage will create 
    a number of changes in line with the FDA's four-pronged approach:

        • Modifying the regulatory regime so it is more prevention oriented (rather than reactive 
          only to food crises) 
        • Developing risk- and scientific-based approaches with regard to decision-making and 
          regulatory activity 
        • Working to hold imported feed to the same standards as domestically produced feed 
        • Working to create an integrated food safety system at the federal level

It is important to note that the FDA intends to take a more active regulatory role within the feed industry regardless of congressional action.  If the Food Safety Modernization is ultimately enacted, this will obviously create a number of changes which align with FDA's overall four-prong approach as outlined above.  Even if this Act eventually fails, however, Dr. McChesney pointed to the FDA's Draft Guidance on Safe Feeding Practices and the FDA's Proposed Rule on Process Control Standards as two examples of initiatives which could go forward. More details on both initiatives can be found on the FDA website.

Stakeholders are advised to pay close attention to the proposed Food Safety Modernization Act and other regulatory developments issuing from the FDA.