AFIA said in the comments, Congress' intent when generating Sec. 211 of FSMA, which amends Sec. 417 of the FD&C regarding the Reportable Food Registry requirements, was only designated for human food products and not intended to affect animal feed or pet food. The organization stated "the statutory language does not mention 'animal food,' it addresses notification to 'consumers' and requires that notifications be published in 'grocery stores' only."

"The 'consumers' of animal food products are livestock or companion animals. These animals are not capable of purchasing the products or reading a notification regarding a product. Customers or purchasers would have been the more appropriate term if Congress intended this provision to apply to animal food products," the comments continued.

AFIA also noted the law's exemptions only include "raw agricultural commodities" of fruits and vegetables — not including grains used that occur in their raw or natural state — further stressing Congress' focus on human food versus animal food. 

The organization highlighted its support for every animal food facility having a recall plan under FSMA in combination with an effective Reportable Food Registry system enforced by FDA, which AFIA stated would prevent "most products that could cause serious or adverse health consequences or death to humans or animals should be in the process of being recalled or will not have ever reached a grocery store shelf."