As I grew up, one of my favorite lunches was a grilled cheese sandwich and a bowl of alphabet soup. My sister, brother and I used to have contests to see who could spell their name or the longest word with the noodles – lots of fun and good for you too, righWell, it seems that the “alphabet soup” of government regulatory agencies is certainly descending on the feed and animal ag industries recently. FDA, EPA, OSHA, DNR, USDA, CVM and FSMA are just a few of the agencies or programs who “know what is good for us.” But if you had a visit from one of them or an occasion to work through changes due to new, revised or more strictly enforced regulations, I’m pretty sure you would not classify the experience as “fun.”
We have seen a very vigorous effort by the Occupational Safety and Health Administration (OSHA) to visit dairy operations to enforce regulations for farm safety. All of us need to make sure we are thinking about the safety of our employees and that we have processes in place to reduce or eliminate hazards.
Accidents happen because they are just that – something no one expected to happen, which can quickly put someone at risk of injury or even death.
Does your operation have a confined space entry policy? Are the safety guards in place for all your machines? Do your feed bins have ladders? Are bin covers and latches in good working order?
Are power lines properly placed and grounded? Do your employees have the equipment and training needed to work with tons of feed and 1,400-pound cows safely? We believe it won’t be too far in the future when we will need to certify that our sales and technical staff are properly trained to interact with pens of animals as they conduct farm consultations.
The Food and Drug Administration (FDA) is on our radar on two fronts. First, FDA is conducting an ongoing survey of antibiotic residues in milk. This survey is an attempt to quantify the level and types of residues that might be present in milk. Expectations are that we will find that our milk supply is free from residues and that the current system of testing is working well.
However, as a safeguard, we are conducting webinars with our staff and customers to make sure they understand the significant consequences of not adhering to withdrawal times and proper use of the important disease-prevention tools available to us.
We also continue to watch the progress of the Food Safety and Modernization Act (FSMA). This legislation was enacted a little over a year ago and was hailed by the Secretary of Health and Human Services Kathleen Sebelius as “the most significant food safety law of the last 100 years.”
The new legislation gives FDA the power to mandate recalls of contaminated food, requires producers to maintain a safety plan, keep records that show they follow it and gives the agency more power over food imports.
The law is in the final stages of rulemaking and implementation – it will take more than 55 different rules and guidance documents to bring this all into focus as to how the legislation practically functions.
The good news for all of us is that feed will have a different category of regulations to follow that is not as strict as the food regulations. That said, don’t forget that milk is food and is likely to see more scrutiny on handling, transport, processing and recordkeeping issues.
FSMA has a number of main points that will affect food production processes:
1. Registration of facilities
2. Hazard identification and written risk management plan
3. New fees (no kidding)
4. Mandated inspection times for facilities
5. Traceability and recordkeeping
6. Access to records
7. Mandatory recall authority
8. Administrative detention (ability to put questionable products on hold)
In mid-May, I will be in Washington, D.C., to discuss how FSMA is progressing and what FDA is doing to push towards implementation. I will also be part of an American Feed Industry Association (AFIA) team visiting our congressional representatives to hear their views on legislation affecting agriculture in the years to come.
I’ll give you an update in my next column on what you might expect as we move through a very interesting election year.
I hope the “alphabet soup” affecting your operation will not overwhelm you. It’s truly an opportunity to set apart milk and dairy products as a “gold standard” food. PD
Alan B. Gunderson
Vice President of
Sales and Marketing
Vita Plus
