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AAFCO Forms HACCP Task Force to Create National Feed HACCP "Standard"

AFIA requests AAFCO Board to halt progress on development of a National Feed HACCP Standard until the industry has had a chance to discuss this issue with the Board and voice its concerns

December 27, 2007

AAFCO Forms HACCP Task Force to Create National Feed HACCP "Standard" 
 
The Association of American Feed Control Officials Board of Directors authorized Dr. Tim Herrman, Texas State Chemist, to form a HACCP Task Force and begin creation of a National Feed HACCP (Hazard Analysis and Critical Control Points) "Standard." AFIA has objected to the formation of this group and has asked the AAFCO Board to halt progress until the industry has a chance to discuss this issue with the Board and voice its concerns.

HACCP is a scientifically-based, risk assessment and management tool for hazards in the food industry. It is mandatory for poultry and meat processors, juice processors and seafood. It was developed by the food industry in the 1970s for the space program. AFIA's textbook Feed Manufacturing Technology V contains a chapter written by AFIA VP Richard Sellers detailing HACCP basics and providing some resources. To order this textbook, visit the AFIA website at www.afia.org.

AAFCO President Ricky Schroeder of Texas, who works for Dr. Herrman, has not responded to AFIA's request for a meeting and holding off on this program. This Board meets on January 28th in San Antonio, TX, prior to the AAFCO Midyear Meeting. AFIA will request time to meet with this group to explain its concerns about the speed of this program.

AFIA's Sellers told the AAFCO Board in a letter that the development of such a HACCP program is a long-term endeavor that AFIA believes will take the industry two or more years to develop. Although AFIA's Safe Feed/Safe Food Certification Program (SF/SF) is a HACCP-based program, it does not follow the straight-line HACCP approach. However, a stepwise approach to HACCP development is necessary. That approach includes the development of prerequisite programs, such as good manufacturing practices that identify hazard control points but not critical ones that are required to be identified by a formal HACCP approach.

In Dr. Herrman's proposal to the AAFCO Board, he indicates that the development of this HACCP "standard" would be completed in time for adoption by the AAFCO membership at its August Annual Meeting with implementation and training shortly thereafter.

Of concern is the use of the term "standard," which Sellers said should not be utilized, but instead use the term "guidelines." A "standard" implies a mandatory program, while guidelines imply voluntary guidelines, of which the SF/SF program is. Dr. Herrman is now proposing to develop a voluntary guideline after AFIA's objection.

The proposal also indicates that AAFCO would hold training and do voluntary inspections. Sellers raised the concern about AAFCO doing training for industry programs and indicated the association's concern for allowing state investigators in feed plants for voluntary inspections for which the firm is paying the investigator a fee for service. This, Sellers stated, would compromise an investigator. Moreover, investigators would be duty bound to take some type of regulatory action against any firm if a serious violation is uncovered during a voluntary inspection. The question was raised, "Why would a feed mill allow a voluntary inspection by a state or federal agent when there are private organizations providing HACCP inspections and certifications?" Also Sellers will raise the concern of utilizing AAFCO and state resources toward voluntary programs depriving the private sector of inspection business.

For a copy of the AAFCO proposal, please contact Sellers at AFIA.

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