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Association News - Spring 2006
Pet Food Recalls Prompt Reminder of Hazard Control

Recent recalls of pet food and pet deaths due to aflatoxin contamination by one firm with contamination from a pet food plant in South Carolina should serve as a reminder to firms to address the potential hazard of aflatoxin in corn and its co-products, reports the American Feed Industry Association (AFIA). AFIA’s Safe Feed/Safe Food (SF/SF) Certification Program requires firms to address a list of potential feed hazards. One of these is mycotoxins, of which aflatoxin is the most common.

The SF/SF program accepts a number of control programs to minimize this hazard leaving the facility in a finished product. Among these programs are the following: requiring a supplier to furnish a certification of analysis for one or more loads of ingredients, doing truck-side quick tests for mycotoxins on a representative number of lots, and requiring suppliers to sign purchasing agreements that the supplied products will be below FDA’s action levels for the specific mycotoxin.

Aflatoxin levels allowed by FDA for corn range between 20-300 parts per billion (ppb), depending on the species. Some firms may require lower levels. The FDA Compliance Policy Guide specifying these levels for aflatoxin can be found at www.fda.gov/ora/compliance_ref/cpg/cpgvet/cpg683-100.html. This is updated occasionally and exemptions or exceptions are provided to specific states depending on that state’s drought status or other variables.

AFIA urges firms to have a control program in place to reduce the potential for harm to animals and humans. For more information on Safe Feed/Safe Food, visit www.afia.org/Safe_Feed_Safe_Food.html. A free copy of the SF/SF Webcast on CD-ROM is available by contacting AFIA at This e-mail address is being protected from spam bots, you need JavaScript enabled to view it Information on aflatoxin guidance levels or other mycotoxins also is available from Richard Sellers at This e-mail address is being protected from spam bots, you need JavaScript enabled to view it

Safe Plant Applications Welcomed

AFIA member locations will soon receive applications for the 2005 Safety Awards. This annual recognition is awarded to plants with no recordable work cases on their OSHA 300 Log for the previous year. A list of the winning locations will appear in AFIA Journal and Feed Management magazine. Plants that are eligible for recognition are encouraged to return the application to AFIA by March 31, 2006.

Waiting List for Grain Bin-Rescue Course

The Grain Elevator & Processing Society (GEAPS) reports that its grain-bin rescue course set for June 14-15 in Frankenmuth, Mich., already is full, and that just five slots remain available for the same course in Berlin, Md., May 9-11. GEAPS advises interested parties to place their name on the waiting list now. To get on the list, contact Amy McGarrigle, GEAPS, 612-339-4625; This e-mail address is being protected from spam bots, you need JavaScript enabled to view it

The courses are designed to raise awareness about bin-rescue procedures and equipment, and will provide hands-on training. Participants will gain experience in using technical rescue equipment, such as ropes and harnesses, cofferdams, breathing apparatus, tripods, davit arms, communications systems, bin-anchorage points and victim “packaging.”

The Safety and Technical Rescue Association (SATRA) will provide the training. SATRA provides search-and-rescue services and training for a wide range of emergency situations worldwide. The association assists local first responders when they need help, or with specialized equipment or skills.

GEAPS Approves More Distance-Learning Courses

With more than 60 people completing GEAPS’s first distance-learning course, “Grain Facilities Planning & Design I,” the International Board has approved development of two additional courses: a follow-up facilities planning-and-design program and a session on grain quality management. The online courses are planned, developed and administered in conjunction with Purdue University. Course materials, including lectures, are on CDs that are mailed to students.

“Grain Facilities Planning and Design II” will (tentatively) be offered this fall, while the Grain Quality Management course would be offered in the spring of 2006.

Plans are underway to offer the first five-week course again next February due to heavy demand. Both facility-design courses are based on material presented at GEAPS’s 2002 Facility Design Conference. Students completing the distance-learning courses receive a certificate from GEAPS and Purdue.

NGFA Supports FDA Proposal to Strengthen BSE-Prevention Safeguards

The National Grain and Feed Association (NGFA) has submitted a statement to the FDA supporting most aspects of the agency’s proposal to implement additional safeguards to reduce the risk of bovine spongiform encephalopathy (BSE) in the U.S.

The NGFA strongly supported the agency’s proposal to ban the use of brain and spinal cord from cattle 30 months or older from all animal feed as a science- and risk-based step to strengthen existing safeguards. Studies have shown that upwards of 90 percent of the infectivity in a BSE-infected animal nearing clinical onset of the disease resides in these tissues, and that the disease does not express itself in younger cattle, says the NGFA.

“The NGFA believes there is substantial merit to removing the vast majority of potential infectivity at the ‘top of the pyramid’ of the animal food and feed chain, thereby making animal-based feed ingredients inherently safe at their source,” the NGFA statement said. “Doing so also will help address the potential for accidental cross-contamination and accidental misfeeding on-farm, as well as mitigate the need for additional down-stream controls (such as requiring the use of dedicated facilities and transportation conveyances, or bans on restaurant plate waste or poultry litter feeding to ruminants) that ultimately would be much less protective of animal health, much more difficult and problematic to enforce, and much more costly and disruptive to implement.”

Requiring removal of brain and spinal cord from cattle 30 months or older also is preferable (from an economic and environmental standpoint) to prohibiting a longer list of so-called specified risk materials (SRMs), which encompass the vertebral column, small intestine and other tissues, NGFA said.

The NGFA added that FDA’s proposal is justified based on existing BSE-prevention safeguards, including the U.S. government’s implementation of firewalls (such as import controls and FDA’s 1997 BSE-prevention feed regulations) before the first case of BSE was diagnosed in North America, as well as what FDA has characterized as a 99-percent-plus compliance rate with its 1997 feed regulations.

The NGFA said FDA’s proposal offers the best opportunity for the United States and Canada to continue their harmonized approach to BSE-prevention feed regulation. The association said the proposal will provide economic benefits to all sectors of the beef value chain by hastening the eradication of BSE from North America and fostering trade in beef and beef products.

However, the NGFA did encourage FDA to amend its proposal with respect to nonambulatory (“downer”) cattle to stipulate that brain and spinal cord be required to be removed only from cattle 30 months or older, provided the ages of such cattle can be accurately and consistently verified. FDA proposed to require removal of such tissues from all nonambulatory cattle, regardless of age. The NGFA said this is inconsistent with the science that shows BSE infectivity does not manifest itself in younger cattle, and is at odds with FDA’s proposal to require removal of brain and spinal cord from live cattle only if such animals are 30 months or older.

The NGFA also advised FDA to evaluate the impact its proposal will have on the environmentally-safe disposal of brain and spinal cord material, as well as of animals that may die on the farm. “In this regard, the NGFA believes that the U.S. government should consider providing an appropriate phase-in period, as well as economic incentives or remuneration to renderers to compensate for the costs associated with converting their operations into disposal or industrial operations, and to encourage the continued pick up of dead stock from farms,” the association said.

Requiring removal of only the most potentially infectious material (brain and spinal cord from cattle 30 months or older) would generate about 1.3 pounds of wet waste per head, compared to the estimated 90- to 120-pounds-per-head of waste material that would result from removal of a more expansive list of SRMs that include the vertebral column, small intestine and other tissues, said the NGFA.

The association also recommended that FDA implement additional safeguards to enhance ongoing BSE-prevention efforts. These include recommendations to require that renderers register with FDA if they handle mammalian material prohibited from being fed to cattle or other ruminants, as well as brain and spinal cord material banned from all animal feed.

The NGFA further recommended that renderers be required to demonstrate to FDA that the systems and processes for extracting brain and spinal cord are effective in doing so consistently and uniformly within parameters/tolerances set by FDA. The NGFA said there was no need for packer-renderers to be subject to this requirement because government meat inspectors already are on-site to verify the effectiveness of such procedures.

The NGFA encouraged FDA to continue to stress in any future rulemaking that its 1997 BSE-prevention feed regulations continue to apply, and the importance of continued strong industry compliance. “In particular, while existing scientific evidence shows that removing brain and spinal cord from cattle eliminates the vast majority of any potential infectivity that may exist in an animal, it is imperative that establishments that manufacture ruminant feed or feed ingredients and handle both prohibited and non-prohibited mammalian material continue to comply with FDA’s requirement to implement written clean-out procedures to minimize potential cross-contamination of facilities, equipment and conveyances,” the NGFA said.

The NGFA repeated its support for government-based inspection and enforcement of FDA’s BSE-prevention feed regulations. In this regard, the NGFA said it does not support the U.S. government requiring the use of (or relying in lieu of government oversight upon) non-governmental, third-party certification of regulated facilities or feed products for compliance with the BSE-prevention feed rule.

The association also reiterated its support for the continued use of animal proteins (including ruminant-derived material) as safe, nutritious and wholesome feed ingredients for species for which they are legally approved, and as an environmentally and economically sound practice. It strongly opposed anticipated calls from some groups to ban the use of all animal protein in animal feed, or to prohibit the feeding of avian or non-ruminant-derived mammalian material in cattle.

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