AFIA also took exception to a FDA proposal that carriers of bulk products provide information to the shipper on three previous loads.
While this may be standard practice in some segments of the food industry, AFIA said, it is not current practice across the entire food and animal food industry. Wilkinson recommended this section be changed to require identification of one previous load, which is more practical and would fit within a facility's food safety plan procedure more appropriately.
The organization also made note of the temperature control measures and hand washing facility requirements originally proposed are not appropriate across the animal food industry and would induce unnecessary cost on the industry without improving the safety of animal food products. AFIA urged these requirements to be removed for animal food.
"At the very least, FDA should revise the language in the final rule to make it clear that continuous temperature monitoring is not required for animal food," the comments stated. "Currently, temperature control shipments in the animal food industry do not involve the use of continuous time/temperature recording devices for most temperature-controlled shipments as the risk level for animal food safety does not require this practice."