ABA recently provided input to FDA on their preventive controls rule for animal food and feed that could impact bakers that send bakery waste to animal farms in an attempt to get human food manufacturers exempt from the proposed rule. ABA raised three critical points with the Agency:
1) All baking companies are subject to good manufacturing practices (GMPs) and will be subject to the promulgated Hazard Analysis and Risk-Based Preventive Controls for Human Food regulations up to the point of diversion to animal feed;
2) Bakeries are not operating their facilities with the intent to produce animal food and diverted food should not be considered “animal foods” or be subject to the rules for animal feed;
3) ABA believes that FDA should exempt human food manufacturers from the proposed rule, and that the obligation to ensure the safety and nutritional suitability of diverted human food for animal food/feed use should properly lie with the receiving animal facility. That recipient is best-equipped to determine whether such safe and lawful human food is safe and appropriate for the animals to which it will be fed.
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