Requirements in the U.S. Food and Drug Administration's proposed animal feed safety rules go further than Congress intended, the National Milk Producers Federation argued in comments sent to the FDA Monday.
The proposed requirements, NMPF says, seek to impose requirements that will not make animal feed safer.
In its comments, NMPF asked FDA to revise the regulation. They also requested that the agency solicit additional comment from the industry and the public. The 120-day comment period on the latest round opened on October 31, 2013, and was extended once to March 31, 2014.
The rules are part of the FDA's sweeping set of food safety regulations intended to focus on prevention of food and feed borne diseases and illness. NMPF said it supports efforts to implement the law, but criticizes the draft animal feed regulation for imposing unnecessary standards on feed production and making it harder to use brewers' grain as animal feed.
Regarding brewers' grains, NMPF joined the Beer Institute and the American Malting Barley Association in requesting FDA use the existing authority in the FSMA to exempt animal feed products made during the production of alcoholic beverages.
As written, the regulations "will result in unnecessary increased costs to dairy producers," NMPF said.
Related: FDA Releases Proposed Animal Feed Rule Under FSMA
The group has several other gripes with the proposal, including concerns that the draft regulation imposes safety standards on animal feed that are similar to those for human food, and establishes manufacturing standards that equate animal feed and human food.
"The innate hygienic standards of humans exceed the hygienic standards of livestock," the organization said. It asked FDA to propose manufacturing standards specific to animal feed.
Dairy processing plant requirements
In separate comments submitted jointly with the International Dairy Foods Association, NMPF also identified "duplicative requirements" for dairy processing plants which they say may divert some food production materials such as cheese trim and liquid whey to animal feed.
These plants are already subject to FSMA requirements for human food production, the groups said.
With the substantial changes requested, NMPF asked FDA to revisit the intent of the FSMA and issue a new draft.
"Given the very significant nature of these regulations, a second opportunity for stakeholders comment is essential to ensure the final rule is practical, achievable and fosters the safe production and distribution of animal feed," NMPF said.
FDA, which is under a court-ordered deadline to publish final FSMA regulations by August 30, 2015, has the authority to re-propose the regulations, NMPF said.