A hazard analysis and critical control point (HACCP) system is a systematic approach for identifying, evaluating, and controlling food safety hazards. Federal regulations require that certain industries, including meat and poultry producers, retail food service providers, and juice manufacturers, implement an HACCP system, but there is no regulation or requirement at this time for the implementation of an HACCP system for feed manufacturers or ethanol plants producing distillers grain to be used as feed. 

Despite this lack of regulation, the Association of American Feed Control Officials recently published the “Verification Program for a Voluntary Hazard Analysis Critical Control Point Plan.” The basic steps in the program are an initial hazard analysis, establishment of critical control points that lead to each hazard, establishment of maximum limits for each critical control point, establishment of a monitoring system and corrective action plan for responding to deviations in the critical control points, and provision for a record-keeping system. AAFCO developed the framework for those feed producers interested in adopting an HACCP program—the verification program remains entirely voluntary. An online version of the AAFCO program may be found at the AAFCO website, http://www.aafco.org, in the “Regulatory Information” menu. In addition, AAFCO publishes a Guidance/Framework and Checklist for Best Management Practices, both of which may provide additional guidance as to appropriate and best practices in the feed manufacturing industry.

So, if this is entirely voluntary, why should you consider an HACCP system? You may want to because the FDA has made grants to state officials to encourage HACCP adoption. The Iowa Department of Agriculture and Land Stewardship, for example, is set to complete the publication of its feed manufacturing HACCP materials in early 2012. Beginning in April through March 2015, IDALS will make on-site visits to 50 to 100 feed mills and ethanol plants in Iowa each year, surveying high risk behaviors at the facilities and providing information about implementing an HACCP system to reduce these behaviors. The results of the survey will be recorded in a database showing use of HACCP principles at these facilities over time.

In conjunction with this type of survey, state officials may also be testing feed and grain at feed mills and ethanol plants for levels of heavy metals and mycotoxins. For example, the mycotoxins chosen for testing by IDALS are aflatoxins, vomitoxin (DON), zearalenone (ZON), and fumonisins. The FDA has previously issued maximum guidance levels for mycotoxins, and any samples that show levels higher than the maximum guidance level will be immediately reported to the regional FDA office. Heavy metals to be tested through the sampling program include mercury, lead and cadmium. Because there are no current FDA standards for heavy metal content in feed, only samples that show “unusually high levels of heavy metals” will be reported to the regional FDA office. Grain sampling has already begun, and between now and 2015, IDALS will take 80 grain dealer samples and 20 ethanol plant samples each year. Each location will receive a mycotoxin guidance document, and the aggregate results for both mycotoxins and heavy metals will be recorded in a database. 

If your plant has not previously considered implementing an HACCP system, these FDA grant programs and on-site visits provide an ideal reason to open the discussion. Implementing an HACCP system prior to these on-site visits could help lead to early detection of high levels of mycotoxins and allow time for a corrective response if needed.

The increased pressure on feed manufacturers to consider implementing an HACCP system also makes it likely that feed manufacturing HACCP systems could become a requirement in the future. In fact, state feed control officials in Texas and California are now accredited to certify feed operations that take part in the voluntary HACCP program. The European Union has also already made adherence to HACCP principles a legal requirement for “feed business operators” in EU Feed Hygiene Regulation (EC) No. 183/2005. Voluntary implementation now could help resolve any internal difficulties without penalty and prepare your plant for the upcoming visits from state officials.

Authors: Andrew Anderson
Partner, Faegre and Benson
(515) 447-4703
aanderson@faegre.com
 
Diana Palmer
Associate, Faegre and Benson
(515) 447-4715
dpalmer@faegre.com