NGFA seeks changes to proposed rule on animal feed, pet food

The National Grain and Feed Association (NGFA) during a recent public meeting urged the U.S. Food and Drug Administration (FDA) to make significant changes to its proposed rule that would establish for animal feed and pet food new requirements for current good manufacturing practices (CGMPs) and hazard analysis and risk-based preventive controls.
The FDA conducted the public meeting to receive stakeholder feedback on four major reproposed rules associated with its implementation of the Food Safety Modernization Act (FSMA). The four reproposed rules address produce safety, CGMPS and preventive controls for human food, CGMPs and preventive controls for animal feed and pet food, and foreign supplier verification programs.
The FDA issued the reproposed animal feed rule on Sept. 29 to provide the agency's current thinking on requirements after its review of comments received in response to its original proposal issued in 2013. The NGFA submitted extensive comments on the 2013 proposal, and strongly recommended that FDA make major changes and re-propose the rule for additional stakeholder comment given the very significant nature of the regulations, and the extent of changes recommended by the NGFA and other stakeholders. 
During the public meeting, Max Fisher, NGFA director of economics and government relations, commended FDA for re-proposing the rule and allowing additional comment. But Fisher said the NGFA remains concerned that "many of the proposed CGMP provisions continue to mirror those established for human food, and do not reflect the realities associated with feeding animals, nor are they necessary to assure the safety of feed products."
In prior statements to FDA, the NGFA has urged the agency to develop final requirements that are practical, achievable and serve to benefit the safety of animal feed and pet food. In doing so, the NGFA has cautioned that adding unnecessary regulatory burdens and costs would undermine the industry's ability to serve the animal agriculture industry and divert finite resources away from effective practices that already are assuring a safe and abundant supply of feed and pet food. 
"The NGFA requests that FDA carefully consider the economic impact of its proposed requirements and weigh the extensive costs against anticipated benefits, which the agency has yet to quantify," stated Fisher, while commenting on the costs associated with the proposed rule. The NGFA's economic analysis of FDA's original proposal indicated the requirements would cost animal feed and pet food facilities more than $500 million annually -- approximately four times more than estimated by FDA.

National grain, feed association calls for challenge to freight rail rates

The National Grain and Feed Association has called on the federal Surface Transportation Board to improve its rules and policies to improve the ability of agricultural shippers to challenge unreasonable rail freight rates.
In a statement submitted to the agency, the association commended the board for proposing changes and soliciting public comments on the current methods available to shippers to challenge unreasonable rates. But the association also called for the board to undertake a more comprehensive, in-depth review of its simplified standards for rail rate regulation, with a goal of proposing further and more significant modifications. The association said if the Surface Transportation Board finds that its current methods for challenging unreasonable freight rates are inadequate, the agency should ask Congress for additional statutory authority “designed to provide genuinely simplified and expedited standards for resolving rail rate disputes.”
In its statement, the National Grain and Feed Association also commented on the following things:
• It urged the board to increase to at least $3 million the amount that could recovered over a five-year period using the most streamlined mechanism currently available for challenging freight rail rates — known as the three-benchmark method. Under this method, the board proposed to increase the recovery limit to $2 million, up from the current $1 million.
• It supported the board's proposal to eliminate the current $5 million limit that shippers potentially can recover using a second “simplified” agency mechanism for challenging unreasonable rail rates. But it urged the agency to delete a concurrent proposal that would undermine use of this method for challenging rates by imposing a new burden that would require shippers to calculate the full replacement cost of rail system facilities used to serve the shipper filing the rate complaint.

Feed association urges clarification on cash recordkeeping rules

The National Grain and Feed Association has called on the Commodity Futures Trading Commission to clarify and narrow a proposed recordkeeping rule that could require grain elevators, feed mills, grain processors and others to record all communications, including telephone conversations, with farmers and other commercial firms that ultimately result in cash or cash-forward contract transactions.
The CFTC’s proposal would require records of “all oral and written communication provided or received concerning quotes, solicitations, bids, offers, instructions, trading and prices that lead to the execution of transactions in a commodity interest or cash commodity, whether communicated by telephone, voicemail, facsimile, instant messaging, chat rooms, electronic mail, mobile device or other digital or electronic media.”
The NGFA has expressed concern that such requirements would be burdensome and costly, as well as create challenges with existing technology systems. “At the least, we urge the agency to adopt a generous timeline and flexible attitude toward implementation for futures commission merchants and introducing brokers, especially smaller firms for which short-term adoption of the proposed standards may pose a significant investment," said the NGFA.

Agriculture transportation study highlights systems approach

The National Grain and Feed Association praised a new study by the U.S. Departments of Agriculture and Transportation for recommending federal policymakers take a more systems-based approach to setting transportation policies.
The two-year study recognizes issues that affect all types of transportation including rail, barge, truck and ocean vessel transport for agricultural shippers. The study recognized the interrelationship between all of these transport modes, and noted the benefit of a supply chain approach to transportation policy, according to the trade group.

Industry group: USDA should downsize Conservation Reserve Program

The National Grain and Feed Association has urged the U.S. Department of Agriculture to downsize and significantly reform the Conservation Reserve Program.
In a statement submitted in response to a draft USDA supplemental environmental impact statement on future Conservation Reserve Program policy options, the association said it was “flawed, erroneous and short-sighted” to assess the program’s environmental benefits “in isolation and in a vacuum” without also considering the positive environmental benefits of other USDA conservation programs, modern agricultural tillage practices and existing conservation requirements imposed under USDA farm programs.
“The idling of productive land resources cuts off the economic multiplier inherent in crop, livestock and poultry production, thereby costing jobs and suffocating economic vitality in rural communities,” wrote NGFA President Kendell W. Keith.
Of the three policy alternatives contained in USDA’s draft environmental assessment, the NGFA favored the option that would reduce the size of the Conservation Reserve Program to 24 million acres. But the NGFA encouraged USDA to allocate more than the 4 million acres called for under that policy option to targeted sign-ups of the most environmentally sensitive land.
The NGFA statement said reallocating some of the Conservation Reserve Program’s budget to the Environmental Quality Incentives Program and the Conservation Stewardship Program, which apply to working farmlands, would achieve greater conservation benefits than idling non-sensitive land under the Conservation Reserve Program.
The other two policy options offered in USDA’s draft environmental assessment both call for enrolling 32 million acres in the Conservation Reserve Program.