AFIA's Board of Directors have approved a far-reaching proposal involving several recommended changes to the Food and Drug Administration's BSE feed rule. The recommendations include expansion of record-keeping requirements, pertain to everyone using the restricted product, advocate FDA registration of those users and endorse a third-party inspection system.
The proposal is as follows:
Proposed Changes to the BSE Feed Rule (21 CFR § 589.2000)
The following proposed modifications are intended to maintain agricultural use of Specified Risk Materials (SRMs) and non-ambulatory cattle within the current mammalian protein definition as Restricted Use Protein Products (RUPP):
The objective is to reinforce current U.S. BSE protection safeguards and create a "fourth firewall" by establishing stronger restrictions for RUPP material. Under these requirements:
All users except those exempt in the current rule should be required for a period of six years to retain records which detail sources of receiving, supply, formulation, mixing, and distribution. [Current rule requires one-year retention for mixers and none for users. Ruminant feeders are required to maintain labels and shipping records of all animal protein products for one year.]
All users and owners, as defined above, utilizing RUPP must comply. This pertains to renderers, feed ingredient distributor/brokers, feed manufacturers, and any other users which purchase RUPP and use it in a feed product. (This requirement conforms with impending Codex standards based upon a "one step forward and one step backward" tracing system.)
Any owner/distributor/mixer/user, as defined above, of any product containing RUPP must also be FDA registered and submit to an annual third party certification inspection.
Rationale behind this program:
These measures will maintain the essential use of a valuable animal protein supply in feeding protein deficient world without deviating from the science that supports the use of such products in non-ruminants.
This program would prevent the RUPP material from becoming hazardous or solid waste burdens and, consequentially, a potential environmental crisis.
The program makes the users of RUPP directly responsible for its use and accountable for any subsequent tracing with federal sanctions for violations.
Independent third party certification provides a redundant reviewing system in concert with federal/state inspections; thereby adding an additional protection or safeguard.