The Safe Animal Feed Education (SAFE) program has devoted resources to educate industry members on proper labeling practices for commercial livestock feed. Resources include an invitation to email safe@cdfa.ca.gov to receive educational label consultation by a SAFE staff member, as well as publication of the California Commercial Feed Labeling Guide, Label Review Checklist, and Medicated Feed Label Guide. However, there will always be questions and nuances regarding feed labeling. On a quarterly basis, SAFE will share tips to address various label questions and bring awareness to proper labeling practices. This quarter, we will clarify adequate directions for use on feed labels.
It is the responsibility of the feed manufacturer to ensure all labeling and feeding directions will promote safe and approved use of the product by the end-user. Food and Agricultural Code (FAC) Section 14992(f) states [The label shall contain] “adequate directions, warnings and caution statements that may be necessary for the safe use of any feed.” Further, California Code of Regulations, Title 3 (3 CCR) Section 2690 requires that directions are capable of being followed and likely to be followed in usual feeding practices. This means that feeding and/or mixing directions, when necessary, must be realistic, accurate, and easy to follow.
Directions for use are necessary when the commercial feed is intended to supply particular dietary needs or for supplementing or fortifying the usual diet or ration with any vitamin, mineral, or other dietary nutrient or compound. Directions for use are also necessary when the feed contains a feed additive such as drugs, special purpose additives, and non-nutritive additives, and as specified in 3 CCR Section 2697(d)(2) regarding commercial feed containing added selenium over 0.3 ppm selenium, 3 CCR Section 2701(d) regarding medicated feeds, and 3 CCR Section 2707(d-e) regarding commercial feeds containing non-protein nitrogen.
Consider the following tips to develop commercial feed directions for use that are adequate for the safe and approved use of any commercial feed:
- Feed manufacturers should include thorough instructions based on the intended level of use such as, for example, pounds per head per day, milligrams per pound of bodyweight per day, or mixing instructions for inclusion in a total mixed ration.
- Directions for feeds containing drugs, selenium, non-protein nitrogen, insect growth regulators, and any other regulated feed additives must result in the safe and effective dosage as stated in the federal approval and/or additive label.
- If the commercial feed is a complete feed that is nutritionally adequate, then adequate directions for use may simply state “feed as sole ration.”
- It is not acceptable to solely state “feed according to your nutritionist instructions.”
- Feeds that are intended to be provided free-choice, such as loose minerals, should state it is intended as free-choice feed and include the intended consumption rate per head per day.
- A simple mixture of grains or by-products may not have a specific intended level of use which may make it necessary to clarify that the feed is NOT intended to provide a balanced diet or source of vitamins/minerals, such as stating “not formulated as a sole ration,” or “feed along with hay/pasture and salt,” etc.
- Ingredients or feed additives such as vitamins, minerals, preservatives, flavoring agents, and technical additives may require specific directions for further manufacturing and/or use.
- It may be acceptable to omit directions for use on certain commercial feed ingredients, such as whole grains.
Questions regarding labeling and directions for use can be sent to safe@cdfa.ca.gov.