WUD critical of proposed FDA feed rule

April 4, 2014 - - Western United Dairymen has written a comment letter to the U.S. Food and Drug Administration (FDA) criticizing its draft livestock feed regulations. The draft regulations were issued under the Food Safety Modernization Act (FSMA), which gave the FDA broad new authority to regulate food. The rule has encountered opposition in recent weeks from many animal agriculture organizations who believe the draft animal feed regulation goes too far, particularly because it would make it harder to use brewers’ grain as animal feed, a practice in use for hundreds of years.
“California’s agricultural environment is considerably different than the rest of the states and that environment needs to be considered as FDA drafts this feed rule,” said CEO Michael Marsh in WUD’s comments. “Hundreds of crops are grown in the Golden State and many of these crops produce by-products which are fed to livestock. This provides a quality feed for livestock, including dairy, and a useful outlet for these by-products other than land filling or other wasteful practices.”

Marsh explained, “This rule needs to be risk based and it is not currently clear what risk is being mitigated by these costly requirements. The costs that are borne by the providers of our feeds to comply with these rules will be passed down to farmers, including small farmers, which have struggled with high feed costs in recent years.”

Marsh concluded, “It appears that many of the regulatory concepts, definitions and terms in the proposed rule were lifted from rules appropriately applied to human food. We believe that the FDA must base this regulatory program in science and risk analysis as it relates to animal food and to focus on mitigating animal food hazards that are known to occur or are reasonably foreseeable to occur that pose risk to animal and/or human health.”