2011 Bureau of Agrichemical Management Annual Report

​​​Feed Program

Program Highlights FeedThe purpose of the feed program is to assure the public and manufacturers that animal feed and feed ingredients meet label guarantees, are unadulterated, and are safe and effective for use. This is accomplished by feed mill and transporter inspections and surveillance sampling under authority of §94.72, Wis. Stats. and ch. ATCP 42, Wis. Adm. Code.

Program Activities

The feed program work includes issuing licenses and feed export certificates of free sale, collecting and auditing tonnage fees, reviewing labels for compliance with the feed law, product sampling, performing field investigations, and conducting education, training and information outreach activities with industry and consumers.

During 2011, the department issued 1,291 commercial feed licenses to firms that distribute, manufacture, process and/or label animal feed and feed ingredients in or into Wisconsin. This represents a slight decrease in the number of licenses issued during the previous year. These firms distributed a collective 3.9 million tons of commercial animal feed and feed products, also a slight decrease from 2010.

The feed industry, over the past few years, has remained fairly steady in both the number of feed licensees and the amount of tonnage collectively manufactured by these licensees. This can be seen in Chart 1 and Chart 2 which show an overview of the feed program licensing and tonnage activities over the last six years. 

The structure of the feed industry appears to be slowly consolidating facilities and smaller operations are being phased out. Companies that operate more than one manufacturing facility seem to be shifting resources and manufacturing activities to one centralized manufacturing location. This centralized facility then sends out finished product to the smaller mills (within the company) that act primarily as retail facilities.

A feed export certificate of free sale or license card, indicating a feed license status, is sometimes required when feed products are exported internationally.  The department provides notarized license cards or notarized certificates of free sale for feed products, including livestock feeds, pet foods, feed additives and feed ingredients. During 2011, the department issued 200 feed export certificates and made an online application available for feed export certificates of free sale.

Compliance Activities and Special Projects

The feed program continues to monitor compliance through Good Manufacturing Practice (GMP) inspections, supported by feed product sampling. GMP inspections are a detailed review of the systems and practices utilized by feed manufacturing and processing firms. Adequate manufacturing systems and practices are essential in maintaining the safety and effectiveness of both medicated and non-medicated feeds, feed ingredients and pet foods. The inspection process evaluates a firm’s facilities and equipment, as well as their receipt, use and distribution of feeds and feed ingredients. It also documents the firm’s manufacturing practices to ensure that only safe and wholesome feeds are being manufactured. During GMP inspections, samples of feeds and feed ingredients are collected for analysis. These samples are analyzed to determine if the feed products meet label guarantees. They may also be analyzed to detect the presence of contaminants, heavy metals, pesticides, microbiological contaminants and other toxic materials.

In 2011, 73 GMP inspections were conducted, with 22 inspections identifying significant violations; 70% of the inspected facilities were in full compliance with our regulations during the inspections. The significant violations included improper labeling and failure to establish and maintain procedures for identifying, storing and controlling inventories of medicated feed ingredients. Feed samples are collected as part of the program’s inspections. A total of 67 feed samples were also collected. Violations, such as failing to meet labeled guarantees, were noted in 13 samples for an 81% labeling compliance rate. This past year we also developed a map showing all​ commercial feed licensed facilities, medicated feed mills and BSE inspection sites in Wisconsin.

Five Most Common Violations FeedIndustry Compliance Assistance: As needed, field and office staff assisted industry feed manufacturers and labelers to better understand state and federal feed regulations. Topics addressed in meetings or through individualized assistance included how to remedy common areas of violation such as how to properly label feed products and how to establish and maintain procedures to identify, store and control inventories of medicated feed ingredients. Program staff will monitor future inspections and industry inquiries to see if there is a need for further industry training or outreach focusing on certain areas.

FDA Inspection Contract: Mills that use certain types of medications and antibiotics in feed products are required to hold a medicated feed license with the Food and Drug Administration (FDA). The FDA contracts with DATCP to inspect these mills. Staff inspected eight of these mills in 2011. FDA also contracted with the department to inspect feed manufacturers for compliance with 21 CFR 589.2000, which prohibits animal proteins from use in ruminant feeds. This federal regulation is commonly known as the Bovine Spongiform Encephalopathy (BSE) feed ban. In 2011, staff completed 168 contract inspections, about the same as were performed in 2010. No violations or issues of concerns were noted.

Feed Investigations: Field staff also followed up on feed complaints and initiated investigations based on initial information collected during inspections. Complaints can originate from the Wisconsin Veterinary Diagnostic Laboratory (WVDL), the Division of Animal Health (within DATCP) or from UW and County Extension Agents, but typically they come from private practice veterinarians and consumers. Generally, feed complaints are related to animal illness or death, potentially related to feed or feed products. In 2011, nine complaints resulted in full feed investigations. Of these investigations, three are ongoing, one resulted in the issuance of a warning notice, one resulted in the issuance of a letter of concern and four lacked sufficient evidence to demonstrate an adulterated feed source.

Toxic Response: The commercial feed specialist serves as DATCP’s coordinator for toxic response investigations. These cases involve illness or death of primarily food producing animals from unknown causes. Toxic response cases may also result if significant non-food producing animal deaths occur. In 2011, one toxic response was initiated due to a large number of dairy cattle deaths on a single farm in northwestern Wisconsin. These deaths were believed to have been caused by the cattle’s consumption of high levels of copper, zinc and selenium. The event occurred several months before DATCP was notified, therefore little evidence remained for us to collect, including none of the suspect feed. Because of this, we were unable to prove that an adulterated feed source was the cause of death in these animals. There were no Toxic Responses initiated in the two years prior.

Homeland Security & Safe Food/Safe Feed: Feed program staff worked with other department personnel to develop, test and implement response plans to protect the state’s animal industries from potential bio-terrorist attacks, radiological releases, natural disasters and foreign animal disease outbreaks. This includes involvement with the multi-state partnership for Security in Agriculture, Association of American Feed Control Officials.

Direction for the Coming Year

FDA Food Safety Modernization Act: In January 2011, the federal Food Safety Modernization Act (FSMA) was signed into law. The purpose of FSMA is to prevent food-borne illness outbreaks. The FSMA includes new FDA authorities, new FDA responsibilities and activities, new food import requirements and an ambitious schedule for increased facility inspections. The passage of this federal law will have a significant impact on the Wisconsin feed industry, as it will require feed manufacturing, processing, and packaging facilities to have procedures in place related to hazard analysis and preventative controls and maintain more extensive records of feed and feed ingredients. An increase in the frequency of facility inspections by FDA and, possibly DATCP, will promote compliance with these new regulations. DATCP will assist its industry partners, through outreach and compliance assistance, in ensuring that they meet these new requirements.

Increased Accessibility of Outreach Materials and Resources for Feed Manufacturers: DATCP wishes to maintain a respectful and helpful relationship with its industry partners so they are able to maintain compliance with state and federal regulations. In 2012, DATCP will be making resources such as guidance documents, feed calculators and a medicated feed labeling program for feed manufacturers more accessible via the DATCP website.

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For more information about any of the bureau programs you may email the department.

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