Quality assurance – Awareness by making all on the farm aware of what’s in the feed and water
Contract growers and all farm animal caretakers should be aware of every time there is a pharmacologic in the feed or water.
In a presentation, Michigan Pork Producers Symposium, 2011, entitled Feed Quality Assurance: Should Standard Operating Procedures (SOP) for on-farm feed manufacturing be developed and implemented?” I made the statement that “contract growers and all farm animal caretakers should be aware of every time there is a pharmacologic in the feed and (or) water”. I was convinced then, and with the growing trend in FDA led and industry accountability, I am further convinced of it importance.
Since 2011, we’ve learned more about residues, impacts upon humans, and antibiotic resistance. The Food Safety Modernization Act’s (FSMA, 2011) preventive control provisions for animal feed were released by the Food and Drug Administration (FDA) in September of 2015, establishing the requirements for current good manufacturing practice, hazard analysis, and risk-based preventive controls for feed. The FDA manages safety of animal feed under its Animal Feed Safety System (AFSS) and states that “the AFSS includes regulations and guidance pertaining to the…
- distribution and
…of all feed at all stages of production and use, whether at commercial or non-commercial feed manufacturing establishments, farms where animals are raised, or homes where pet animals are kept.” Within this system, the FDA regulates the Veterinary Feed Directive which went into full effect on January 1, 2017. We’ve updated the Michigan Commercial Feed Law (P.A. 120 of 1975, as amended 2015). Lastly, we’ve engaged in the Common Swine Industry Audit verifying “that a pork production site is in compliance with established standards for swine care and pre-harvest pork safety” (National Pork Board, 2018). Without a doubt, accountability by government, by food distributors, by packers, by our fellow citizens, and by countries importing our pork, is being increasingly passed onto the farmer.
Under the We Care Principles and within the Common Swine Industry Audit (CSIA), best management practices (BMP) are developed to protect everyone in the pork food chain and providing pork that is safe and nutritious, including through awareness and observation at ground zero, the farmers and on-farm stockpersons.
So how is it implied in federal and state regulations and guidance that all animal caretakers be aware of pharmaceuticals provided to pigs on the farm?
To reiterate, FDA-AFSS’s stated purpose is to regulate and guide the manufacture, labeling, storage, distribution and use of all feed at all stages of production - it is not doing so. Clearly, commercial feed plants are subject to the FSMA Preventive Controls for Animal Food rule. FDA has responsibility for enforcement of the FSMA Preventive Controls for Animal Food rule. Use of Current Good Management Practices (CGMPs) are for commercial feed mills under this rule (FDA - CFR 21CFR225.1). Every feed delivery to the farm or farms (including those under contract) must be delivered with the correct paperwork (lot number, ingredient description, drug concentrations, directions for feeding, and caution statements). Record keeping must be adequate to facilitate the recall of specific batches of medicated feed that have been distributed and retained on the premises for one year following the date of last distribution. While commercial manufacturers of medicated feed must follow Current Good Management Practices (FDA - CFR 21CFR225.1), feed mills that are part of individual farms and integrated farming systems are currently not subject to the FSMA Preventive Controls for Animal Food rule. These farms and have been excluded from the enforcement of the FSMA Preventive Controls for Animal Food rule for now. However, FDA mentions that it does have plans to include them, at least with Guidance information in the future. At a state level, the amended Michigan Commercial Feed Law (2015) has similar content regarding CGMPs in commercial feed manufacturing and distribution. The state law also does not pertain to individual farms and integrated farming systems.
Farms are required by law (21 CFR part 558 subpart B) to use medicated feed in accordance with its approved uses by following product labeling regarding intended animals, indications for use, all precautions and instructions on how to handle, store, and use the feed, and limitations for use and withdrawal times. Nonbinding recommendations are provided by the FDA in their Guidance for Industry #203 entitled “Ensuring Safety of Animal Feed Maintained and Fed On-Farm.” Released in March of 2015, the guidance is given to help persons who feed animals develop and implement on-farm practices to ensure the safety of animal feed. In this document ‘persons who feed animals’ are encouraged to store, distribute, and use feed, to observe biosecurity measures to prevent or significantly minimize the introduction of contaminants, and to read and follow labeling for use, storage, and disposal of all pesticides, fertilizers, and other agricultural chemicals.
These laws and recommendations suggest that it may be prudent to think in terms of an effective residue avoidance program for the entire pork production system. It may be wise to make sure those records are kept at each production site where pigs are fed. It seems that there would be wisdom in informing the animal caretakers about food and water treatments for pigs so that they can help minimize the unintended cross-contamination.
Stronger support for making notification of contract growers and all farm employees that care for pigs about feed and water treatments is apparent in the questions asked in the Common Swine Industry Audit (2018). These question imply that all animal caretakers should be aware of animal treatments, protocols for treatment, and records of treatment. Although the term contract grower is not stated explicitly, their responsibilities for caring for the animals is undeniable. Below are the most relative questions:
- Can caretakers articulate their method for tracking what treatments have been administered and how long each animal has been receiving treatment?
- Are caretakers able to articulate the training they received specific to their daily duties?
- Does the site have documentation of annual caretaker training specific to their daily duties?
- Does the site have a written SOP for feeding and watering protocols?
- Does the site have a written SOP for caretaker training?
- Does the site have a written SOP for treatment management?
- Are medication and treatment records retained for 12 months?
One final reason supporting greater awareness of pharmaceutical and chemical use on the farm is that it will provide direct protection of all people that work with the animals. The Occupational Safety and Health Administration requires that workers must be provided protection and that would include protection from feed dust which may contain antimicrobials.
My encouragement is that standard operating procedures for on-farm notification of pharmaceutical and chemical use should be developed and implemented throughout the pork production operation including all sites and all animal caretakers in the multiple-site system. I would suspect that there are few farms that have these standard operating procedures. Each farm will have to write specific statements describing “how to do each step”. The implementation of directive and specific standard operating procedures will enhance food safety, increase consumer confidence in pork, protect employees, and enhance the long-term profitability of the pork production enterprise.