On February 9, 2023, FDA’s Center for Veterinary Medicine (CVM) held a virtual meeting on FDA’s role in the Association of American Feed Control Officials (AAFCO) feed ingredient definition process. Specifically, the goal of the meeting was to look at how to improve FDA’s role in the ingredient definition process and how FDA could gather stakeholder input on the safety of each pending ingredient definition.

The event began with presentations from several CVM speakers, including Tracey Forfa, CVM’s acting director, as well as Austin Therrell, AAFCO’s executive director, and was followed by presentations from various stakeholders.

Presentations from FDA discussed the memorandum of understanding (MOU) between FDA and AAFCO (MOU 22507-7001) which formalizes the procedural steps in FDA’s safety review of animal feed ingredients and provides a mechanism for resolving disputes or removing definitions. FDA highlighted that the MOU does not define FDA’s relationship with AAFCO, determine when FDA will engage with AAFCO, or transfer FDA’s authority to AAFCO. On the latter point, FDA was careful to note that enforcement of animal food laws resides only with FDA and state authorities and that all animal feed ingredients are held to the same standard (“a reasonable certainty in the minds of competent scientists that the substance is not harmful under the intended conditions of use”), but that cooperation with AAFCO facilitates regulatory uniformity.

FDA noted stakeholders concerns regarding its slow AAFCO ingredient definition review process and indicated that while food additive petitions and GRAS Notifications remained a priority, it had added 12 additional reviewers to its staff in 2020 (almost doubling the staff), which is now allowing it to complete AAFCO ingredient reviews in a timelier manner. FDA also indicated that it was trying to increase the transparency of the process and was considering which information to include online (e.g., a page tracking all pending ingredient definitions) as well as options to allow for stakeholder input. 

FDA is accepting comments to docket FDA-2022-N-3122 on regulations.gov until March 4^th. Specific questions on which FDA is seeking input can be found on the meeting’s webpage.