The 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 the authority of §94.72, Wis. Stats. and ch. ATCP 42, Wis. Adm. Code.
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 2012, the department issued 1,313 commercial feed licenses to firms that distribute, manufacture, process and/or label animal feed and feed ingredients in or into Wisconsin. Of these firms, there were 662 licensed facilities in the state. This represents a slight increase in the number of licenses issued during the previous year. These firms distributed a collective 4.7 million tons of commercial animal feed and feed products, also an increase from 2011.
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. However, last year showed a marked increase in tonnage, with licenses issued remaining steady. 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 feed industry seems to be doing more with what they have which may be in response to Dairy 30x20 initiative. Without a real increase in the number of manufacturers, there was a significant rise in output.
A feed export certificate of free sale or license card, indicating a feed license status, is sometimes required by the importing country 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 2012, the department made an online application available for feed export certificates of free sale. The department issued 251 feed export certificates, an increase from the 200 certificates that were issued in 2011. The program has been steadily increasing the number of feed export certificates issued each year, and program staff work collaboratively with industry and the Division of Agricultural Development to ensure manufacturers have the documents they need to successfully export products.
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 good manufacturing practices. 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 2012, 54 GMP inspections were conducted, 20 facilities were issued written warnings (up from 10 in 2011), 15 were issued verbal warnings (up from 12 in 2011) in response to inspection findings. The majority of violations were related to the distribution of adulterated/misbranded feeds, due to: 1) a lack of adequate inventory records (50% of all inspected facilities), 2) incomplete or inadequate medicated feed labels (30% of all inspected facilities) or 3) incomplete or inadequate labeling (19% of all inspected facilities). In total, 72% of all feed inspection reports noted violations of state feed regulations. The number of inspections, however, decreased, as the department experienced significant turnover in field staff trained to complete inspections. The compliance section is more fully staffed for 2013 and the program is increasing training to ensure an adequate number of GMP inspections are completed and regulations are being followed to keep feed safe.
Industry Compliance Assistance
As needed, field and office staff assisted industry feed manufacturers and labelers to better understand state and federal feed regulations. In 2012, the feed program website underwent major updates, including the addition of industry guidance documents and other tools to assist feed manufacturers, labelers and distributors in ensuring their manufacturing practices and manufactured products are in compliance.
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 2012. 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 2012, staff completed 168 contract inspections, about the same number as were performed in 2011. No violations or issues of concerns were noted in either inspection type.
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 University of Wisconsin 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 2012, nine complaints resulted in full feed investigations. Of these investigations, three are ongoing, three resulted in the issuance of a warning notice, one resulted in the issuance of a product holding order and two lacked sufficient evidence to demonstrate an adulterated feed source.
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 when significant non-food producing animal deaths occur. In 2012, two toxic response cases were initiated. Only one of these cases was shown to be attributed to an adulterated feed.
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
Increased Efficiency and Value of Inspection and Sampling Programs: DATCP would like to better utilize inspectional findings and sampling results to prioritize future inspection and sampling plans. In 2013, DATCP will be evaluating its feed sampling program using a Six Sigma process to ensure that an adequate number of samples are collected from a broader base of products. Similarly, the feed inspection program will be implementing a “risk-based” inspection plan to ensure that “higher-risk” facilities are inspected more often than “lower-risk” facilities. This will ensure a better utilization of resources and be more protective of businesses and feed consumers.
For more information about any of the bureau programs you may email the department.
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