Feed Inspector’s Manual Fifth Edition Published by Association of American Feed Control Officials Inspection and Sampling Committee 2014 TABLE OF CONTENTS Chapter One - Introduction ............................................................................................................ 1 Chapter Two - Safety ...................................................................................................................... 3 Chapter Three - Sampling............................................................................................................... 12 Chapter Four - Label Review........................................................................................................ 35 Chapter Five - Feed Investigations ............................................................................................... 73 Chapter Six - GMP Inspections ................................................................................................. 76 Chapter Seven - Feed Ingredients ................................................................................................... 96 Chapter Eight - VFD's.................................................................................................................... 99 Chapter Nine - BSE .................................................................................................................... 103 - FDA Compliance Guide 67 ............................................................................... 106 - FDA Compliance Guide 68 ................................................................................ 114 - FDA Compliance Guide 69 ................................................................................ 121 - FDA Compliance Guide 70 ................................................................................ 126 Chapter Ten - Enforcement ....................................................................................................... 131 Chapter Eleven - Drug Carryover .................................................................................................. 138 Chapter Twelve - Feed Manufacturing Techniques ........................................................................ 142 Chapter Thirteen - Toxins ................................................................................................................. 147 Chapter Fourteen - Feed Glossary ..................................................................................................... 163 Appendix A - Conversion Tables .............................................................................................. 205 Appendix B - Independent Feed Laboratories .......................................................................... 217 This manual is the compilation of many hours of work and effort by many people. Several states have shared their own manuals and resources for this project to reach completion. AAFCO, and especially the committee, wish to thank all those who have helped in updating and publishing this second edition. LIMITATIONS OF USE No one manual could be the end all resource for performing inspections in the field. If one were able to be produced, it would be so large, that back support would be needed to even lift it! This manual is designed to be used as a resource by field inspectors both in the field and when preparing for inspections and regulatory work. It still must be taken only as a guide. States may have varying laws, rules, and regulations that will not be addressed by this manual. This manual was designed with the AAFCO Model Bill and rules, not one particular state’s program. Therefore, you must be sure how this manual and your state’s laws, rules, policies, and programs agree or disagree. OFFICIAL AAFCO POLICY This manual is not intended to be or replace Official AAFCO Policy. Many of the items in this manual will be consistent with wording in the AAFCO Official Publication and many will not. The only Official Policy adopted by AAFCO is contained in the Official Publication. If anything in this manual disagrees with policies outlined in that publication, the Official Publication should take precedence. SPECIAL THANKS TO: • The entire Inspection and Sampling Committee • Our Industry Liaisons • The Communication Committee for publishing the Manual • Kansas State University • AFIA • FDA Other Valuable Resources AAFCO Official Publication AAFCO/AAPFCO Professional Inspector Manual Feed Additive Compendium AFIA Red Book CFR 21 Parts 500 to 599 FDA Eureka Compact Disk FDA Bovine Spongiform Encephalopathy Interactive CD Policies & Procedures INTRODUCTION Chapter 1 THIS MANUAL This manual is a compilation of many sources. The Inspection and Sampling Committee of AAFCO gratefully acknowledges the hard work and contributions from many states and others in preparing this manual. While it cannot be an end all to inspection, it is a valuable resource and should be referenced whenever possible. INTENT This manual is designed to provide inspectors with a comprehensive explanation of the regulatory and enforcement functions of a feed inspection program. While industry is ultimately responsible for the quality of the products they manufacture, your angecy and the U.S. Food & Drug Administration (FDA) are responsible for safeguarding the human food supply, animal and plant health and to facilitate national and international trade. INSPECTOR’S MISSION To assure that feed manufacturing facilities produce unadulterated and properly labeled feed products; To provide effective and uniform administration of the laws and rules within the agency’s jurisdiction; To promote compliance by the regulated industry through education. OBJECTIVES The objectives of a feed regulatory program are many. First and foremost is to protect the human food supply. Products must be manufactured properly, free of adulterants or contaminants, and labeled properly so that they may be used effectively and safely. Labeling is critical so that the consumer can safely, effectively and efficiently use the feed. Inspections must be performed that are representative of the activities performed by the mill and samples must be collected properly to represent the feeds that were manufactured. Education is a vital part of all regulatory programs. An inspector must also be trained to respond to consumer complaints and toxic response situations. PROGRAM EMPHASIS An effective program must reflect current concerns with the safety of animal products entering the human diet, while continuing to protect the producer and their livestock. Recognition that quality ingredients make quality feed has focused more attention on feed components and less on complete feed. Current activities are designed to support the goal that the livestock producer receives a quality product to prevent contaminant problems in milk, eggs and meat purchased by the consumer. The prime focus is on uniformity and product safety (i.e. drug, chemical and biological residues/contaminants). Programs are designed to monitor compliance with established standards through planned inspections and sampling activities to minimize potential hazards. Even in unconventional feed ingredient/feed additive areas such as pulp and paper waste, single cell proteins, poultry waste, and facilitating agents, evaluations are primarily concerned with chemical contaminants, mycotoxins and drug residues which may affect animal and human health. Directed investigations are carried out when livestock illness, death or loss of performance may be attributable to the feed, or when contaminants occurring in meat, milk and eggs may be linked to 1 Policies & Procedures INTRODUCTION Chapter 1 feed. (In addition, investigations are carried out when other government agencies detect problems such as salmonella contamination, mycotoxins or drug residues in foods, which might be feed related.) THE INSPECTOR’S ROLE As an inspector, you are a member of a regulatory team. The administrative function, the laboratory, and the work you perform, all tie to together to assure compliance with the law. As such, you are the agency’s front line representative. The way you prepare yourself and conduct yourself will either aid or hinder your mission. Inspectors are professionals. Please refer to the AAFCO Professional Agricultural Inspector’s Manual to address the professional skills necessary for efficient and effective inspection. 2 Policies & Procedures SAFETY Chapter 2 Elevators, mills, and warehouses may be potentially hazardous work environments. The sampling and inspection of commercial feed involves working in many potential hazardous situations. Since an Inspector works alone much of the time, you must assure your personal safety. Safety equipment must be on hand and used to insure maximum protection under any conditions. Be aware of the potential dangers and possible peculiarities of each establishment. A feed inspector should exercise care and use common sense at all times. Accidents may be caused by physical hazards, such as faulty equipment, or by human factors, such as complacency or haste. Accidents can be prevented by eliminating these causes and safety depends on the willingness of everyone to conform to safe practices. In addition to your established safety procedures, follow safety requirements of the facility, if more stringent. Ignorance of safety instructions is no excuse for their violation. Remember, your personal safety is more important than any sample! If you do not know the safe way to do your job, ask your supervisor for instructions!