When you stare into the eyes of a bull, can you tell if his systems are working properly? Likely not, as a complete veterinary exam is needed to rule out any underlying problems. As a large animal veterinarian, we know that former Rep. Ted Yoho would understand that, but what we are grappling with is why he might take that same simplistic approach to looking at new feed ingredients that can keep American agriculture competitive and combat public health and environmental issues?
In his recent op-ed, Dr. Yoho outlines his objections to including an amendment—the Innovative Feed Enhancement and Economic Development Act (FEED) Act (S. 1842)—in the upcoming reauthorization of the Animal Drug User Fee Amendments Act (ADUFA). Unfortunately, many of his claims do not reflect the current reality of the U.S. regulatory process for new feed ingredients.
S. 1842, supported by government scientists, private sector innovators, representatives of farmers and agribusinesses and senators on both sides of the aisle, is needed to modernize the broken regulatory system that has kept innovative feed ingredients, already safely used in dozens of other countries, from being available to American farmers and ranchers.
To enter the U.S. marketplace, feed ingredients must go through one of three, established, rigorous, yearslong approval processes at the federal and state levels to confirm they’re safe for animals, that they work and that the resulting meat, milk and eggs are safe for American consumers without harming the environment. Some newer feed ingredients being researched and tested will offer farmers safe tools for diminishing the presence of food safety pathogens (e.g., salmonella, E. coli), improving animal productivity (e.g., better feed efficiency) and reducing emissions (e.g., methane), by acting in the animal’s gut.
Sadly, a 25-year-old Food and Drug Administration policy is preventing animal food manufacturers from clearly identifying these non-nutritive, beneficial uses on their product labels, unless they go through the FDA Center for Veterinary Medicine's cumbersome drug approval process, which can take more than 10 years. Without congressional approval, the FDA does not have the authority to bring this policy into the 21st century to regulate these products through the more appropriate Food Additive Petition process.
Dr. Yoho acknowledges that the animal drug industry is experiencing the same issues that the animal food industry is working hard to address: the FDA’s slow, outdated and inefficient regulatory processes. When both of our industries share the same goal of wanting to provide farmers access to more tools to keep their livestock healthy and productive and make their operations more sustainable, shouldn’t we be working together?
The FDA had held several public comment periods with stakeholders across the animal food and health industries and has admitted, after hearing overwhelming concerns from them, that the time is ripe for change. The Innovative FEED Act would amend the Federal Food, Drug and Cosmetic Act to establish a new category of animal food additives to cover ingredients such as those which do not impact animal nutrition, but rather, act in the animal’s gut to provide animal health, food safety or environmental benefits—deemed zootechnical animal food substances.
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We recognize that “zootechnical,” a veterinary medical term, may confuse some, but Dr. Yoho does a disservice to agriculture by using scare tactics that could undermine public trust in the production of nutritious food. The scientific community should be working harder to overcome public perception issues that have the potential to threaten agricultural progress, especially since many of the ingredients—manufactured by animal drug and animal food ingredient companies alike—have gone through years of studies for safety and effectiveness, are backed by on-farm trials and peer-reviewed publications and approved in dozens of countries.
Dr. Yoho also believes trade of American products could be at risk, but frankly, our farmers and ranchers are already losing out to what is projected to become a $56.22 billion industry by 2027, as competitors in Europe, Asia and South America have moved forward with the adoption of these safe ingredients, while the United States sits on the sidelines. Our members first look abroad to commercialize their products, and that is a problem we need to fix.
The message is clear: We need to deliver new animal drugs and feed ingredients to American farmers if we want to remain competitive in a global marketplace and make strides toward the country’s food security and climate goals. Let’s work together, Dr. Yoho, to grab the bull by the horns and give the FDA the tools it needs to modernize, for the betterment of consumers and farmers.
Constance Cullman, president and CEO, American Feed Industry Association
Mike Seyfert, president and CEO, National Grain and Feed Association
Jim Mulhern, president and CEO, National Milk Producers Federation
Chuck Conner, president and CEO, National Council of Farmer Cooperatives.
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