FINAL DRAFT August 6, 1999
FEED AND FEED INGREDIENT SAFETY AND QUALITY COALITION
August __, 1999

Dr. Stephen F. Sundlof
Director
Center for Veterinary Medicine
7500 Standish Place Metro Park North 2, Room 482
Rockville, MD 20855

The Feed and Feed Ingredient Safety and Quality Coalition is a broad-based coalition of associations representing the feed ingredient, feed manufacturing, and animal production industries.

The Coalition's members are listed above, and a detailed description about each organization is attached. The Coalition is dedicated to producing safe, high-quality animal feed and recognizes that such feed is an essential element in maintaining and enhancing the safety and integrity of the American food supply.

The public comments of a number of Food and Drug Administration representatives have indicated that FDA is moving toward imposing hazard analysis and critical control points (HACCP) requirements on the feed and feed ingredient industries. While individual Coalition members have a range of views on HACCP, the consensus of the Coalition is that the underlying science base for mandatory HACCP requirements for the feed and feed ingredient industries do not exist today.

As we understand the Agency's plans, the principal objective of imposing HACCP requirements on the feed and feed ingredient industries is to achieve a "safe" (e.g., salmonella negative) feed/food stream. This would be accomplished by focusing on the control of microbiological hazards in the production of feed/feed ingredients.

However, even if "safe" feed/feed ingredients could be produced, there can be no assurance that the product would remain "safe", given the numerous opportunities for microbiological contamination to occur, both during transport and in the feed trough. Imposing mandatory HACCP requirements on the feed/feed ingredient industries but excluding the transportation sector and the feed trough, appears unjustified.

The Coalition would like to share its preliminary concerns with you and your staff and, at the same time, gain a better understanding of the Agency's thinking. We would like to discuss the following matters with the agency:

1. The specific human food safety concerns that FDA hopes to address through mandatory HACCP requirements for animal feed and feed ingredients.

2. The available scientific testing and data that establish a risk to human health from feed and feed ingredients.

3. Whether FDA can establish that Salmonella is a human food hazard without first considering the serotype.

4. The available evidence that physical and chemical contaminants in animal feed pose a risk to human health.

5. The apparent FDA decision to adopt mandatory HACCP requirements for the animal feed and feed ingredients industries before it has imposed such requirements on the entire human food industry.

6. Whether the same requirements can -- or should -- be imposed on the feed ingredient, feed manufacturing, feed and feed ingredient transportation, and animal production industries.

7. Whether FDA intends to target specific feed ingredients.

8. Recontamination during transportation and feeding of "sterile" animal feed and feed ingredients.

9. The economic impact of mandatory HACCP requirements, including the impact on small businesses.

10. FDA's enforcement priorities if mandatory HACCP requirements are adopted.

We will contact you shortly to schedule a meeting at a mutually convenient time. During that meeting, we hope that industry and agency representatives will be able to have a meaningful dialogue on how best to achieve our common goal -- a safe and wholesome food supply.

We appreciate your attention to this important matter, and look forward to meeting with you.

Sincerely yours,

American Feed Industry Association Corn Refiners Association Distillers Grains Technology Council National Cotton Council National Cottonseed Products Association National Oilseed Processors Association National Renderers Association

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