Regulatory Bulletin 328 2015 COMMERCIAL FEEDS IN KENTUCKY Agricultural Experiment Station Regulatory Services on the Web: www.rs.uky.edu Division of Regulatory Services Kentucky Agricultural Experiment Station Nancy Cox, Dean, College of Agriculture, Food and Environment Rick Bennett, Director, Kentucky Agricultural Experiment Station Darrell D. Johnson, Executive Director Regulatory Services G. Alan Harrison, Director Feed/Milk Kristen Green, Feed Registration Specialist Robert Counts, Auditor Inspection Staff Jim True, Coordinator of Field Inspection Staff Mark Barrow Terry Prather John S. Flood Brad Johnston Nathan Keith David Mason Warren Pinkston W. Bart Young Laboratory Staff Frank Sikora, Director of Labs and Soils Sharon Webb, Director of Quality Control Solomon Kariuki, Assistant Manager of Labs Kristin Brock Phil Dickson Meghan Short Gary Coleman Steve Duckett Debra Sipe Jonathan Collett David Harover David Tompkins Bruce Combs Wayne Ingram Rajna Tosheva-Tounova Jennifer Combs Garland McKee Lancao Zhang Administrative Staff Tony Benge, Computer Systems Manager III Kellye Gaither, Senior Systems Analyst Programmer Shannon Shields, Project Specialist I Stephany Chandler, Data Entry Annie Simmons, Data Entry Margaret Thomas, Data Entry Charlene Vest, Data Entry Kay Phillips, Staff Associate This report was compiled and prepared by G. Alan Harrison with the assistance of the Inspection, Laboratory, and Administrative Staffs. The College of Agriculture, Food and Environment is an Equal Opportunity Organization. Introduction Feed Mill Inspections Kentucky’s commercial feed law (KRS Maintaining high quality and safe 250.491-250.631) dates from 1906 and was feeds for animals requires a comprehen- revised in 1996. This feed law provides sive inspection program. This is particu- protection for the state’s livestock, larly important when mills manufacture poultry, and pet owners by regulating medicated feed. Mills may be required to all feed materials offered for sale or for obtain a license from FDA to manufacture mixing into a feed. Products falling under medicated feed depending on the type regulation include all types of pet foods, and concentration of drug. There are livestock minerals, complete animal and eight feed mills in Kentucky with a feed poultry feeds, protein or mineral blocks, mill license (FML) from FDA. All feed mills supplements, feed ingredients, specialty must comply with good manufacturing materials such as drug premixes, vitamin practices which are assessed as part of a and mineral supplements, liquid feeds, pet comprehensive inspection program. The supplements, pet treats, and other special- purpose of these inspections is to ensure ized pet foods. The law does provide for several safe feed practices are followed: (1) exemptions for whole and unprocessed approved drug levels are used, (2) proper grain, raw meat, hay, straw, stover, silage, mixing procedures are followed, (3) feed cobs, husks, and hulls when not pro- ingredients are monitored, (4) good record cessed. keeping is followed, (5) good housekeep- Revisions in laws and regulations have ing protocols are followed, and (6) a recall added additional requirements over the plan is in place. years. These revisions are primarily in The Division participates in an inspec- response to more varied livestock feeding tion program in partnership with FDA practices, changes in feed manufacturing that conducted 79 inspections of feed technology, and an increased number of dealers and manufacturers in 2015. These feed ingredients. These revisions ensure inspections assure that mills are follow- safe and effective use of drugs, and ing FDA guidelines and are in compliance authority to inspect mills for compliance with rules prohibiting the use of ruminant with good manufacturing practices. Any proteins in feeds intended for other rumi- drug and feed additive use must conform nant animals. These rules are in place to to Food & Drug Administration (FDA) prevent the establishment and amplifica- regulations. A major aspect is to prevent tion of Bovine Spongiform Encephalopa- unsafe residues in human food that may thy (BSE). Feed mills receiving prohibited result from misused or contaminated feed. animal protein materials must follow ad- Several provisions are aimed at keeping equate procedures to prevent any chance poisonous and deleterious substances of those materials getting into feeds for from being distributed in feeds. ruminants. Included in the 79 inspections Information in this report is intended conducted by our inspectors in 2015 were to inform the feed purchaser, provide a 28 more intensive inspections for good basis for fair and equitable competition, manufacturing practices at Kentucky mills and assist in assuring the safety of animal producing medicated feed. There are and human food. approximately 160 feed manufacturing facilities located in Kentucky that serve the animal feed and pet food industries. 5 Food Safety drug purpose, and any required warning, Food (feed) safety has moved to caution, or special feeding instructions. the forefront of public concern. Animal Misleading and unsubstantiated informa- food that is free of contaminants is an all tion or claims are prohibited. Currently, important concern of feed manufacturers over 23,500 different commercial feeds and regulatory officials due to potential and pet foods are currently registered for impacts any type of contamination would distribution by over 1200 companies. have on the Kentucky livestock indus- A feed label is the fundamental com- try, and thus impact human food. Feed munication with the consumer; it provides industry personnel have become more purpose of the feed, directions for use, involved with ingredient assessment and nutrient information, ingredient content, monitoring, defining ingredient storage and special comments or warnings. Pro- conditions, maintaining clean storage and viding labeling assistance and guidance manufacturing facilities, increased record to product registrants and manufactur- keeping, and having plans in place to ers has been beneficial in attaining high remove contaminated feed from distribu- quality feeds and promoting food safety. tion in case of an emergency situation. A full-time registration specialist reviews Occurrences with animal or pet food product labels for compliance with ap- that need attention may include abnormal plicable laws and regulations. The field feed color or odor, presence of a foreign inspectors assist manufacturers with label- material, animals refusing the feed, and ing, resulting in more uniform and infor- sickness or death of animals. An investiga- mative labels. Additionally, spreadsheets tion is warranted when any of these occur. are available to assist in establishing label Regulatory Services works in conjunction guarantees and for estimating nutritional with the University of Kentucky Veterinary suitability of custom mixed feeds and Diagnostic Laboratory, extension agents, even pet treats. These services strengthen local veterinarians, feed dealers, and feed an excellent working relationship with the manufacturers, and take samples of feed feed industry in Kentucky. when these incidences occur. Our contin- Financial Support ued emphasis on frequent inspections, The feed regulatory program is support- regular sampling, laboratory analysis, ed by inspection fees of the commercial label reviews, and inspections support ef- feeds sold in Kentucky, registration fees for forts to maintain food safety and minimize small package items, and General Assem- any adverse impact. bly appropriated funds. An inspection fee Feed Registration and Labeling of 35 cents per ton is paid on commercial Manufacturers are required to register feeds in packages of larger than 10 pounds. all feeds before distribution to ensure Distiller’s wet grains, other distillers prod- that correct label information is provided ucts of more than 75 percent moisture, to the purchaser. Each year, we conduct whey and brewers wet grains distributed more than 7,000 label reviews for products without further processing pay a fee of 5 for animals or pets. Guaranteed analysis, cents per ton. Products sold exclusively ingredient listings, and feeding directions in packages of 10 pounds or less pay an for the intended animals or pets are scruti- annual registration fee of $50 per product. nized. Particular attention is given to medi- In 2015, the feed program collected a total cated feed labels with regards to approved of $1,264,131 in inspection fees, registration drug usage and dosage, statement of fees and late payment penalties. 6 Table 1. Number of feed ingredient samples in 2015. Official Samples with Other Type Guarantees Samples Total Alfalfa Products 4 0 4 Animal Products 14 0 14 Brewery Products 0 0 0 Corn Products 83 49 132 Cottonseed Products 5 0 5 Distillers Products 56 7 63 Soybean Products 97 35 132 Wheat Products 13 5 18 Other Grains 21 1 22 Minerals 12 0 12 Vitamins 1 2 3 Urea & Other NPN 0 0 0 Other 18 14 32 AAFCO samples 0 48 48 Total 324 161 485 Table 2. Number of commercial feed samples in 2015. Official Samples with Other Species/Type Guarantees Samples Total Poultry Feed 231 4 235 Beef Feed 415 9 424 Dairy Feed 67 2 69 Swine Feed 116 3 119 Sheep Feed 23 0 23 Goat Feed 34 2 36 Equine Feed 219 10 229 Rabbit Feed 25 0 25 Fish Feed 8 0 8 Deer Products 32 0 32 Milk Replacer 14 0 14 Mineral/Vitamin/Other 197 2 199 Wild Bird Food 26 0 26 Total 1,407 32 1,439 Table 3. Number of pet and specialty feed samples in 2015. Official Samples with Other Type