Date: Jan 26, 2018
The Generally Recognized as Safe (GRAS) Working Group has prioritized three projects as follows: (1) identify and pursue state acceptable alternatives to Food and Drug Administration Center for Veterinary Medicine (CVM) review of independent GRAS conclusions; (2) provide industry, consumers and regulators information about the FDA law and regulations applicable to GRAS substances; and (3) identify and pursue solutions to CVM review resources above and beyond GRAS notifications. In short, the State Feed Control Officials continue to take issue with the quality of certain self-determined GRAS positions and are finding it difficult to come up with a path that will preserve the self-determined GRAS concept without further support to evaluate these GRAS positions. We will continue to carefully monitor this situation as there has been indications that AAFCO is close to deciding that they will not accept any self-GRAS positions.
New Work Groups
Hollis Glenn, the Division Director of the Inspection & Consumer Services Division at the Colorado Department of Agriculture, provided an update on the use of hemp in animal food. In short, a stakeholder group has been working on how to best get hemp approved for use in animal food. They are currently working on a food additive petition submission to the CVM that will cover hemp seed and hemp seed byproducts. Of interest, at the end of this update there were questions as to how hemp ingredients were currently being used in animal products. One response was that they were being used in dietary supplements for animals, which are "not regulated." AAFCO and FDA were quick to correct that, technically there is no dietary supplement category for animals. AAFCO also stated that they have the authority to remove such products from the marketplace and they implied that they may use this authority in the future.
Discussion topics that have been postponed for a later meeting include: (1) whether the tentative ingredient definition process needs to apply to every ingredient; (2) the Standard of Identity Template; (3) the status of high profile ingredients; and (4) discussing common human foods in pet food. There is very little information in the public domain regarding these discussion topics.
© 2019 Keller and Heckman LLP. All rights reserved