The American Feed Industry Association today filed comments to the U.S. Food and Drug Administration on the removal of trans fats from America's food system. Although AFIA has no opinion on FDA's proposal to phase out partially hydrogenated oils (PHOs) from the "generally recognized as safe," or GRAS, category for human consumption, the organization expressed concern that FDA does not clearly define that the phase-out process only applies to human food for consumption and not animal food.
"AFIA believes FDA's tentative determination on trans fats is unclear in areas as it does not verify that the language is not valid for food for consumption by animals other than man," said Leah Wilkinson, AFIA director of ingredients, pet food and state affairs. "Based on the information published in the 'Federal Register' notice on Nov. 8, 2013, we believe that is not FDA's intention, but are requesting clarification to prevent future confusion between the agency and the feed industry."
AFIA explained FDA published no information in the "Federal Register" that indicates the agency's concern "beyond food for human consumption." There also was no representative listed from FDA's Center for Veterinary Medicine, only a contact from the Center for Food Safety and Applied Nutrition, which does not handle animal feed issues.
"None of the seven questions on which FDA seeks comment pertains to animal food. Moreover, none of the 46 references cited appears to have any direct relevance to animal food," AFIA commented.
"AFIA believes the clarification we are requesting is warranted because the statutory definition of 'food additive' in the Food, Drug and Cosmetic Act applies with equal force to food for human consumption and consumption of food by animals other than man," said Wilkinson. "At the very least, we would like a letter from FDA to be placed in the rulemaking docket addressing the clarification."
Defined as an ingredient by the Association of American Feed Control Officials since 1989, vegetable oils and PHOs have a long history of safe use as an animal food ingredient for multiple species. In addition, vegetable oils, some of which that are PHOs, provide essential fatty acids in the diets and rations of livestock, poultry, aquaculture and companion animals.