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NGFA submits comments on FSMA implementation

Group wants implementation to take risk-based approach

Release Date: 2015-05-29

The National Grain and Feed Association (NGFA) on March 26 submitted comments to the Food and Drug Administration (FDA) regarding Food Safety Modernization Act (FSMA) implementation.

According to the comments, NGFA’s membership “recognizes the paradigm shift FSMA represents in terms of placing the principal focus on prevention of hazards that can pose a risk to human or animal health. The law also codifies a fundamental principle that the grain, feed and grain processing industry has long held — that the industry bears the principal responsibility for producing and distributing safe products.

“That is a responsibility our industry embraces and takes very seriously,” said NGFA.

As such, the association seeks to ensure FSMA implementation takes a risk-based approach with a clear understanding — from regulators and industry — about what is involved under new FSMA-related rules. In its comments, the association focused on:

A common understanding of responsibilities and obligations must be developed: For regulatory officials and industry to have a clear and common understanding of responsibilities and obligations under the new FSMA-related rules, FDA will need to issue multiple guidance documents for various industry sectors in a timely manner after final rules are issued.

According to its statement, NGFA urges “FDA to work closely with the regulated industry while developing such documents so that content reflects the realities of industry practices, aligns with regulatory requirements and serves to further enhance the safety of human food, animal feed and pet food.”

Investigators must undergo comprehensive training: While FDA has signaled that it intends to develop metrics to measure the industry’s compliance with FSMA requirements, the NGFA also believes that the agency must establish clear metrics to accurately measure its investigators’ understanding and application of the regulations.

“Consistent and reasonable inspectional activities will play an essential role in establishing the constructive relationship between regulators and industry that is necessary to advance food and feed safety,” according to NGFA’s statement.

FDA should use an “educate before regulate” approach: NGFA strongly supports FDA’s stated FSMA-compliance philosophy of “educate before it regulates.” However, NGFA urges FDA to provide adequate time for industry to fully understand and comply with the new and far-reaching FSMA requirements.

FDA should use a risk-based approach when setting inspection priorities: NGFA believes that FDA should rely upon currently collected and publicly available information and data when determining whether a facility or its products should be subject to more frequent inspections as mandated under FSMA.

According to its comments, NGFA strongly believes that “FDA’s inspectional resources should be focused on facilities that have a higher risk of affecting human and animal health.”

FDA should continue to use state regulatory officials for inspections: The NGFA strongly supports FDA’s continued use of state feed regulatory officials to conduct FDA-credentialed inspections of animal feed and pet food facilities.

NGFA said, state regulatory officials who are familiar with and knowledgeable about animal feed and pet food facilities and the types of products manufactured and distributed can […]

By |2015-06-01T10:20:37-05:00June 1st, 2015|Articles|0 Comments

Apple Reclaims Title Of World’s Most Valuable Brand

Apple has been battling it out with Google to be crowned the most valuable brand the last few years. Apple claimed the title for three years in a row from 2011-2013, but last year, Google knocked them down to second place. After Apple’s amazing success with the new iPhone 6 though, the company is back on top. Per the WPP and Millward Brown-commissioned research, Apple’s value has grown 67 percent this year to total $247 billion, while Google grew 9 percent to reach $173.7 billion, landing it the No. 2 spot. Below is a chart showing the rest of the brands included in the top 10 Worlds Brands

By |2015-05-28T08:03:17-05:00May 28th, 2015|Articles|0 Comments

A Deeper Look At Early Corn Conditions:

  A Deeper Look At Early Corn Conditions: As I mentioned above, many producers I’ve been speaking with aren’t overly impressed or excited about the current conditions of their corn crop. Nobody seems to horribly disappointed, but nobody is saying this is their best looking crop either. There’s simply a lot of wet ground right now and nobody seems 100% certain as to how it will ultimately play itself out. 

The USDA released it’s first condition rating of the U.S corn crop yesterday and showed 74% of the crop rated “Good-to-Excellent”. Perhaps more important is the fact they are showing very little is in “Poor-to-Very Poor” condition. 

Consider the following: Ohio has 0% of the crop in “Poor-to-Very Poor” condition; IA, MI, ND, PA, WI just 1% of their crop rated “Poor-to-Very Poor”; IN & MN just 2%; CO, IL & KY just 3%; NC & TN 4%; MO 6%; NE & SD 7%; TX 8%; KS 9%. The graphic below shows statewide crop-conditions.

 Since the USDA didn’t release overall “corn conditions” until the first week in June last year, we will wait to provide state-by-state annual comparisons. Also keep in mind these numbers can shift dramatically once more of the crop is actually “emerged”.

By |2015-05-27T09:45:11-05:00May 27th, 2015|Articles|0 Comments

May Could Break Rainfall Records:

The southern Plains have been absolutely pounded by rains this month. Oklahoma has set an all time record monthly rainfall total, reaching 18.69 inches as of yesterday morning. This is more than the average precipitation over a five month period from March through July. Amazingly, every day since May 5 — thats 20 straight days — has brought at least 4 inches of rainfall to at least one location in the state of Texas. Other cities experiencing all-time totals include: Wichita, KS; Colorado Springs, CO; Lincoln, NE; Lubbock Texas, TX; Corpus Christi, TX; and Fort Smith, AR.

  

By |2015-05-27T00:16:39-05:00May 27th, 2015|Articles|0 Comments

What Memorial Day Is All About

I wanted to take just a quick moment and talk about “Memorial Day.” I know I might be preaching to the choir, but many people fail to realize that Memorial Day was originally set aside to exclusively honor the fallen soldiers of our great nation. In fact it was officially proclaimed on May 5th 1868 by General John Logan, national commander of the Grand Army of the Republic, and was first observed on May 30th 1868, when flowers were placed on the graves of both Union and Confederate soldiers at Arlington National Cemetery. The first state to officially recognize the holiday was New York in 1873, hence Waterloo, NY was officially declared the birthplace of Memorial Day by President Lyndon Johnson in May of 1966. Since then the traditional observance of Memorial Day has diminished, as many Americans have now forgotten the meaning and traditions of this great day. To help re-educate and remind Americans of the true meaning of Memorial Day, the “National Moment of Remembrance” resolution was passed back in December of 2000, which asked that all American on Memorial Day at 3 p.m. local time, “Voluntarily and informally observe in their own way a moment of remembrance and respect, pausing from whatever they are doing for a moment of silence for those who have sacrificed their life for our great country.” I now it doesn’t get much air time with the press, but I thought I would make mention of it in today’s letter. Having a grandfather who served in WWII and a father who served in Vietnam, I was taught at an early age to be thankful for the freedom I have and the sacrifices that have been made by others on my behalf. Though my father never wanted to talk about his time their or discuss the subject, my mother let me see the letters he had mailed her on various occasions…by what I read in a few letters I can only imagine. My father simply said there was no reason to discuss the war, he only hoped neither I or my children would ever have to experience anything like it. He was 18 when left and 22 when he came back home, I have to believe a forever changed man. Below I have included a partial list highlighting the estimated number of Americans killed and or wounded while defending our freedoms. Take a moment and think about how your family has or would be impacted if your child didn’t return home. It’s staggering when you think about how families have been torn apart or splintered. It’s even more insane when I see how some individuals and groups chose to disrespect the very freedoms their forefathers gave their lives for:
• 1775-1783 American Revolutionary War – 50,000 Wounded / 25,000 Dead
• 1812-1815 War of 1812 – 20,000 Wounded / 15,000 Dead
• 1846-1848 Mexican-American War – 17,500 Wounded / 13,300 Dead
• 1861-1865 Civil War – 1,300,000 Wounded / 750,000 Dead
• 1898 Spanish-American War – 6,000 Wounded / 2,500 Dead
• 1898-1913 Philippine American War […]

By |2015-05-22T11:20:46-05:00May 22nd, 2015|Articles|0 Comments
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