“AFIA supports a strong approach to FSMA training, compliance and enforcement, one that is clear to the regulated industry and allows innovation and different approaches to achieve the same goals in the new law,” stated AFIA’s vice president of feed control and nutrition Richard Sellers.
Sellers added, “AFIA believes much of the information FDA is requesting is necessary for the agency to collect…[but] there are some areas of concern both in terms of the burden on facilities to gather the information and the ability of FDA to protect this information as confidential.”
The comments explained that many AFIA members consider their quality assurance programs and food safety plans as proprietary and confidential. AFIA reiterated to FDA that for firms to provide this type of information to FDA means firms needs a clear protection from disclosure to the public.
Regarding the submission of hazards associated for each products and the preventive controls offers little to no value to determine the level of risk for a specific facility. Sellers explained, “AFIA believes that preventive control programs are facility specific and should be reviewed at individual facilities. With over 1,000 ingredients used in feed, the hazards can be numerous.”