NTF Urges FDA Recognize Existing Feed Mill Safeguards of Common Ownership

April 1, 2014
Washington, DC

The National Turkey Federation (NTF) urged the Food and Drug Administration to recognize proven, existing safeguards inherent where there is common ownership of turkeys and the feed mills supplying them and to exempt those mills from a new FDA regulation. 

In comments submitted Monday to FDA’s proposed rule on preventive controls in animal feed, NTF said a mill’s exclusive supply arrangement to feed the turkeys of common ownership provides an economic incentive greater than any regulation to produce the safest, highest quality feed.

“The core intent of the rule appears to be to protect the end users of animal food by requiring extensive, written preventive controls to be in place at feed mills,” NTF wrote in its comments. "This additional level of regulation may be appropriate when the manufacturer of the feed is fully and completely independent of the purchaser of the feed.  However, it is not needed in the overwhelming majority of instances where turkey feed is being milled because the manufacturer of the feed has a significant economic investment in the birds being fed.” 

NTF states that FDA’s proposed rule has not recognized that the vertically integrated production model in the turkey industry guarantees the processors that own both turkeys and feed mills will be fed under strict veterinary care to produce the healthiest birds for market.  NTF also indicated that this common economic interest also extends to marketing contracts where the processor is obligated to purchase turkeys from growers when they reach market weight.

NTF states that the Food Safety Modernization Act provides FDA clear authority to broaden exemptions for feed mills to recognize turkey production and other vertically integrated production models.  The rule, as proposed, grants a much narrower exemption that ultimately exempts most of one animal production industry while forcing the rest to operate under the new rule.  In a vertically integrated system, creating the preventive control plans required by the rule would be costly, duplicative of other safeguards already in place and, because of the common ownership interest, have no measurable impact on the safety of the feed.

NTF’s comments detail the common ownership interest in the healthy production of turkeys that is assured through:

  •          Feed safety analysis
  •          Veterinary supervision of feed ingredients
  •          USDA Food Safety Inspection Service testing that has maintained 100 percent compliance for more than a decade against violating antibiotic residues in turkey meat
  •          Industry safety controls that require certificates of analysis for nutrients and other ingredients to ensure feed is safe and provides important nutrition for turkeys with the highest quality meat at market

NTF’s comments conclude, “Thus the feed mill has an economic incentive to produce feed of the highest quality and safety. The economic penalty for failing to do so is far greater than any regulatory penalty FDA could devise.  Requiring an additional regulatory burden for these mills requires a significant investment of time and money by the mill yet will do nothing to enhance the quality or safety of the feed being produced.”