In January 2011, President Obama signed into law the Food Safety Modernization Act (FSMA), the largest and most sweeping changes to food and feed safety legislation since the Food Drug and Cosmetics Act was originated in the 1930s. It has taken several years for final rules to be written by the FDA, but this year the FDA has completed its rules on feed manufacturing, transportation and storage. While the industry has provided preliminary comment on the rule, it is expected that the vast majority of the rule will be upheld in its current form, and within a year become a requirement for all feed manufacturers in the United States.
The new FDA rules mean major changes for how the industry does everyday business. Milk Products has been watching the rule changes very closely and we are happy to say we welcome the changes the FDA has made and that we are already in compliance with them. To explain these changes and how they might affect you, we will break up the proposed changes into several sections.
Hazard Analysis and Preventative Controls
The first part of the FDA rule is requiring all facilities to complete a hazard analysis of the feed production process. The hazard analysis reviews all possible chemical, biological, physical and radiological hazards that could be introduced or increased at each step in the process, the ingredients and the handling of a feed product. For each hazard found, the facility must institute preventative controls to reduce those hazards to an acceptable level. The widely accepted way to perform this hazard analysis is to make a HACCP (pronounced hassup) plan. HACCP is an acronym that stands for Hazard Analysis Critical Control Point. HACCP is widely used in the food industry, and is the gold standard for hazard analysis programs. HACCP planning requires extensive time and usually involves a large monetary investment (in both capital and personnel with experience with HACCP) from facilities. Feed manufacturers that do not have a HACCP plan (once the rule goes into effect) run the risk of fines or product recall.
Milk Products has extensive experience in HACCP and has invested in bringing in personnel with many years of experience in food manufacturing to ensure our feed manufacturing works under industry best practices.
Inspection and compliance
The FDA has been charged with increased inspection guidelines for feed manufacturers. Generally speaking this means that the FDA will be in feed facilities more often and will be looking deeper during their visits at every facility. The current trend in FDA regulation treats feed manufacturers more and more like human food manufacturers in ways that have never been seen before, and it is holding facilities responsible to those new expectations.
Milk Products has years of experience working with the FDA in both food and feed plants, and we have a proven track record of maintaining good relationships with our regulatory agencies. We know what to do to protect our customers and their brands.
Food and feed safety begins where ingredients are produced. The FDA recognizes that a safer food chain must begin at the initial ingredient producer and follow all the way through to the end user. As such, the FDA is requiring all facilities to ensure their suppliers are reviewed, approved and compliant with FDA regulations. This is especially true of imported ingredients and products. Apart from our long history of working with local suppliers that are regulated through the FDA, Milk Products already has stringent requirements for our suppliers. We go above and beyond current requirements: the team at Milk Products reviews suppliers’ feed safety policies, programs, procedures and perform on-site audits.
These are just a few examples of how changing legislation in the Food Safety Modernization Act will affect the feed business from top to bottom. In keeping with our tradition of excellence, we go above and beyond regulation - Milk Products has implemented a GFSI style Quality Management System to ensure we make safe, quality feed in every package, every day. Milk Products is ready for FSMA and has the people and tools needed to stay ahead of changes in the industry – can all of your suppliers say the same?
For more information on FSMA and feed visit: