The FDA created Compliance Policy Guides (CPGs) to direct field staff regulating compliance policy for animal feed or feed ingredients contaminated with salmonella and for products which come into direct contact with humans, such as pet food.
AFIA members will be affected by these guidelines and applaud the agency for creating a scientifically-justified policy for salmonella in feed. Realizing this is a rare occurrence, AFIA also notes that the eight serotypes listed in the CPG are very rare in feed. For the uncommon occurrences that have been documented by FDA, the most commonly occurring are not known to be animal health concerns. FDA has rightly focused the CPG on the health concerns of animals given the lack of research data relating to Salmonella in feed and any human health concerns.
“For many years, AFIA has urged FDA to separate how the agency polices Salmonella in food and feed, and we applaud this separation. Now, Salmonella found in feed will not always be deemed adulterated, which is a break with the past and a good break,” said AFIA Vice-President Richard Sellers.
AFIA has initiated the Salmonella in Feed Research Coalition in conjunction with the U.S. Department of Agriculture’s Agricultural Research Service (ARS). The purpose of the coalition is to define research priorities for salmonella in feed and begin to map out research protocols at ARS facilities. The first formal coalition meeting is tentatively scheduled for early 2011. Scientists from the Center for Veterinary Medicine’s Office of Research have been encouraged to participate as observers at the coalition meetings.
Although several groups have commented that all salmonella should be prohibited in feed, a number of scientists have professed to AFIA such a position is neither scientifically defensible, nor realistic. There are currently no scientific data to justify a complete ban given the lack of data on infectious dose, types of serotypes appearing in feed, and the changing landscape of Salmonella on the farm. AFIA believes that the proposed CPG is realistic, scientifically-based and takes into account the known research on the issue.
AFIA strongly supports this CPG and urges FDA to issue and implement a final guidance as quickly as possible. AFIA also looks forward to FDA’s participation in the research coalition and to providing the agency with continuing reports on the coalition’s findings.
