Experts prep feed mill managers for FSMA implementation

Experts recently discussed how feed mill managers should prepare for Food Safety Modernization Act (FSMA) compliance, specifically the new rules for good manufacturing practices (GMP) and preventive controls, monitoring and verification activities.
“In your food safety plan, for every hazard that you have detailed or every area that you feel needs to have some measurement, you need to build control procedures,” said Brad Tipton, director of quality assurance with Pilgrim's, during his presentation on “FSMA in the Feed Mill: One Company’s Implementation” at the USPOULTRY-sponsored 2015 Feed Mill Management Seminar in Nashville, Tennessee.
He noted that as part of the new rules for the GMP, feed mill managers are now mandated to maintain a written food safety plan, which must include a hazard analysis and preventive controls. He also reminded the managers of the importance of retaining proper hazard, maintenance and standard operating procedure records. “In the eyes of inspectors, if you did not write it down, you did not do it,” he said.
Dr. Henry Turlington, director of quality and manufacturing regulatory affairs for the American Feed Industry Association (AFIA), provided an overview of FMSA and the impact on feed mills. Turlington said the new law applies to all ingredient processing, all feed manufacturing, pet food, transportation, and feed and ingredient imports, saying that “current good manufacturing practices are good business practices.” He stressed the need to start with a process flow diagram, organize documents to meet needs, verify and validate current good manufacturing practices, and identify hazards and preventive controls.

Canadian Grain Commission seeks input on feed mill licensing

The Canadian Grain Commission on February 9 began consultations on its proposal to license feed mills in western Canada and to extend payment protection to grain producers who sell grain to feed mills.
The Canadian Grain Commission is seeking input from feed mills, grain producers, producer groups, current licensees, and industry stakeholders on its proposal to license feed mills and to assist in the development of licensing requirements for feed mills. The intent is to assess the feed mill industry in western Canada. Information collected will be considered when determining a threshold for commercial feed mills to be licensed.
Relevant information, including a description of the issue and a full description of the proposal, are available on the Canadian Grain Commission's website. Information is also provided on the website on how stakeholders can comment on the proposal. Stakeholders have until April 9, 2015 to submit input.


Fast facts


• As part of its licensing and producer payment protection programs, the Canadian Grain Commission issues licenses for primary, terminal and process elevators, as well as grain dealers.
• Feed mills are currently exempted from licensing in the Canada Grain Regulations. Should feed mills be licensed, they could be subject to some of the same requirements as process elevators.
• A feed mill is an operation where a process or a combination of processes is used to produce or manufacture feed for livestock or poultry consumption.
• Feed mills that could be subject to licensing include on-farm feed mills or commercial feed mills that purchase grain from producers, to be used either on farm, sold to a livestock operation, or for resale.
• These operations would be licensed and would be required to provide security as a condition of licensing. Payment protection would only apply to eligible deliveries for the 20 grains defined in the Canada Grain Regulations.

Groups attempt to clarify fall-protection directive

The National Grain and Feed Association (NGFA) and the American Association of Grain Inspection and Weighing Agencies (AAGIWA) issued a joint statement in an effort to clarify that a recent fall-protection directive "applies only to FGIS employees."
According to the statement, the U.S. Department of Agriculture's Federal Grain Inspection Service (FGIS) published Directive 9170.14, which provides procedures for identifying rolling stock fall hazards and for conducting a fall-protection feasibility assessment.
However, the directive NGFA and AAGIWA stress "applies only to FGIS employees," and "officially designated agencies are not required to adopt the policy."
Instead, NGFA and AAGIWA state that officially designated agencies "may adopt the policy or use it as a guideline to establish their own policy to comply with federal and state safety and health requirements."
NGFA and AAGIWA also noted that work environments and circumstances vary greatly at grain handling facilities. The organizations encouraged their members to "establish safety policies and procedures tailored to each individual location to comply with all federal and state safety and health requirements, including those pertaining to rolling stock fall protection." However, they say, "those policies and procedures may differ from those found in the FGIS directive.”


Background
The directive was developed by FGIS in response to citations, issued by the Occupational Safety and Health Administration (OSHA) in 2011, for failing to conduct fall protection assessments, train employees on fall hazards, and train supervisors to identify potential hazards. Fall protection long has been one of OSHA's emphasis areas. Yet, the existing regulations under OSHA's walking-working surfaces and personal-protective equipment (fall-protection systems) standard -- also known as Subpart D -- do not specifically include rolling stock (such as rail cars) and motor vehicles. OSHA defines "rolling stock" as any locomotive, railcar or vehicle operated exclusively on a rail or rails, or a trolley bus operated by electric power supplied from an overhead wire.
Also relevant to this matter, OSHA in 1996 attempted to provide guidance to the grain handling industry on this uncertainty by issuing an internal memorandum -- commonly known as the "Miles Memo" -- that directed OSHA inspectors not to issue citations for rolling stock under Subpart D. The memo was OSHA's response to the NGFA's request for clarification of the agency's rolling stock enforcement policy. Specifically, the OSHA Miles Memo document states, " ... falls from rolling stock would not be cited under the fall-protection standard because it was not appropriate to cite exposure to fall hazards from tops of rolling stock unless the stock was inside of or contiguous to a structure where fall protection is feasible."
As a result, the 1996 memorandum allows employers to rely on administrative controls, which include training, physical evaluation of an employee's ability to work safely atop rail rolling stock, and company procedures to ensure employee safety when working in staging yards and other areas away from the facility's railcar loading point.

How to utilize HACCP to mitigate mycotoxin risk

Elizabeth Santin, Professor, Federal University of Parana, presents during the Mycotoxins & More session at the 29th Alltech Annual International Symposium.

Avoiding the health effects and financial losses of mycotoxins will always be a top-of-mind concern for the animal feed industry. According to Alltech, global surveys indicate that 98 percent of feed ingredients contain at least one mycotoxin - and 93 percent contain multiple mycotoxins. In the breakout session, "Mycotoxins ... & Much More," held at Alltech's 29th Annual International Symposium in Lexington, Ky., a rotating panel of eight speakers discussed advancements in contamination mitigation in three installments: detection and risk assessment; management; and solutions.
While the first and last session focused on the technology behind mycotoxin management through testing instrumentation, data collection and, in cases of high contamination, adsorbent usage, the portion entitled "Mycotoxin Management" offered tips for identifying and monitoring critical control points as part of a mycotoxin risk management and prevention strategy.
Dr. Elizabeth Santin, a professor at the Federal University of Parana's department of veterinary medicine in Brazil, stressed the importance of knowing when and where mycotoxins are entering the supply chain. She points to the application of a Hazard Analysis and Critical Control Points programs as an important tool for managing mycotoxins in feed mills.
Keeping in mind that grain is at its best the day it is harvested, the decline in condition and the increase of mycotoxin levels will likely rise once it is placed in storage. While in the bin and in transit, varied moisture levels produce ideal growth conditions for fungi, which may lead to the introduction and cultivation of new mycotoxins after initial tests have been conducted.
She suggests collecting samples when the grain is acquired to establish a baseline metric. Frequent sample testing in the mill allows the manufacturer to engage in preventative measures, such as moisture control or the introduction of binders, to fight potential mycotoxin losses.
"The only way to control [mycotoxins] is to know the problem exists, to identify the risk and take measures to address it - good sampling at critical points is the only way to know what you're working with," Santin says. "[The goal is to] mitigate mycotoxin risk and apply the hazard controls before you have problems in the animals."
She offers these tips for managing critical control points:



• Conduct mycotoxin analysis before the grain enters the mill
• Monitor toxin levels while the grain is in storage
• Perform a facility audit, evaluate storage conditions
• Track the maintenance and condition of transportation units
• Inspect equipment within the feed mill; identify accumulations; and establish a cleaning schedule
• Make sure samples are collected correctly and tested with the proper equipment


Santin suggests conducting weekly tests at critical control points and reevaluating these points every six months to ensure they haven't changed. Also, be aware of new vulnerabilities.
"Take proactive measures to control mycotoxins when you have few problems. If you do, you will have an opportunity to experience a real response," she concludes.
The 29th edition of Alltech's Annual International Symposium attracted more than 2,300 attendees from 72 countries. The three-day event, held at the Lexington Convention Center in downtown Lexington, Ky., featured two plenary sessions and 21 diverse breakout sessions. 

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.

Food Safety Modernization Act focus at feed mill forum

Vice President of Feed Regulation and Nutrition for the American Feed Industry Association Richard Sellers addressed feed mill managers at a recent seminar, focusing on the Food Safety Modernization Act and its ramifications on the industry.
During the event, sponsored by the U.S. Poultry & Egg Association’s Poultry & Egg Institute, Sellers said that the industry is experiencing some of the most significant changes in the Food and Drug Administration's regulation of feed since 1958. “You need to know what is in the Food Safety Modernization Act in order to comply,” said Sellers. “You will not see anything like this law in the history of the Food and Drug Administration and probably will not see anything to the magnitude of this bill in the future.”  
The new law applies to all ingredient processing, feed manufacturing, pet food, feed and ingredient imports and transportation. Sellers discussed some of the new facets of the law that he said need to be addressed by all companies:

• Determining each company’s risk level
• Foreign supplier compliance to ensure they comply with the FSMA
• User fees for re-inspections
• Implementation timelines

Other talks at the event included Jim Norris, senior safety administrator of Bunge North America, presenting “Safe Entry and Reclaim from Flat Storage Spaces;" Andy Yersin of Kemin Industries presenting "Salmonella Control and Prevention;" and Don Holman of Tyson Foods discussing "Transportation Guidelines — Comprehensive Safety Analysis 2010."

Grain, feed groups recommend OSHA retain grain-handling safety rules

The National Grain and Feed Association has urged the U.S. Occupational Safety and Health Administration to retain its existing grain-handling facility standard, and to exempt grain elevators, feed mills and grain processing plants already covered by those regulations from its planned development of a comprehensive combustible dust standard.
The association's statement, developed in collaboration with the American Feed Industry Association and Pet Food Institute, was submitted in response to OSHA's October 21, 2009, advance notice of proposed rulemaking, in which the agency signaled its intent to develop a broad, comprehensive combustible dust standard that would apply across different industry sectors.
The National Grain and Feed Association noted that OSHA's own regulatory review in 2003 determined that the grain-handling standard should continue without change. Fire and explosion incidents in grain-handling facilities have declined by 65%, as measured in five-year increments since 1976, according to the association. Meanwhile, the reduction in the number of injuries and fatalities has declined 86% and 94%, respectively. This improved safety record occurred even as the volume of grain being handled by U.S. facilities increased by nearly 60% over the same time span, the statement said.
The association attributed the progress to a combination of governmental safety rules and an extensive $3.5 million industry research program that discovered the causes of and developed new techniques for controlling fire and explosion risks, coupled with ongoing education and training efforts.
The statement to OSHA opposed modeling a combustible dust standard after voluntary standards developed by the National Fire Protection Association, which do not evaluate practical implementation or cost impacts, and do not permit broad public participation in their development, according to the feed group. The statement said that the National Fire Protection Association’s potential recommendation of a 1/32-inch or less action level for combustible dusts, compared with the 1/8-inch standard now applicable to grain dust in priority housekeeping areas around bucket elevators, would increase compliance costs by several fold without materially contributing to improved safety.