In 2024, the California Department of Agriculture’s (CDFA) Commercial Feed Regulatory Program (CFRP) continued work to ensure feed safety, food safety, and quality of commercial feed in California. Inspectors and staff met goals and embraced changes throughout the last year.
Inspection and Sampling
In 2024, CFRP shifted focus to conducting “California Feed Safety Inspections” at commercial feed licensed locations every 2-5 years, depending on priority determined by licensee operations. These comprehensive inspections cover the Preventive Controls for Animal Food rule, Current Good Manufacturing Practices (CGMP), other applicable federal regulations such as medicated feed CGMPs, bovine spongiform encephalopathy (BSE) rule, and veterinary feed directive (VFD) rule, as well as compliance with all California commercial feed laws and regulations.
CFRP conducted 200 inspections at commercial feed licensed locations, including 31 comprehensive California Feed Safety Inspections and 25 inspections under contract with the U.S. Food and Drug Administration (FDA). All inspections at commercial feed licensed locations included verifying firm information and activities, and sampling. CFRP obtained 656 feed samples, and the overall sample violation rate was 26.9%, including assay and label violations. CFRP completed 128 violation follow ups, 78 regulatory note follow ups, and responded to 12 feed complaints.
CFRP conducted 324 inspections at retail feed establishments, which included verifying compliance with restricted livestock drug regulations and VFD distributor requirements, if applicable, and verifying license status of the manufacturers of retail commercial feed.
CFRP underwent an audit with the FDA Office of Regulatory Affairs (ORA) to assess CFRP’s implementation of the updated 2023 Animal Food Regulatory Program Standards (AFRPS). CFRP maintained full implementation of all 11 standards with no corrections needed.
Licensing and Tonnage Auditing
In 2024, CFRP performed detailed audits of quarterly tonnage reported to CFRP. Five (5) firms were selected at random, resulting in findings of unpaid inspection tonnage tax and unlicensed firms distributing feed in California. CFRP is in the process of bringing firms into compliance.
Laws and Regulations
Effective October 1, 2024, amendments were made to the California Code of Regulations, Title 3 (3 CCR), which clarify the responsibilities of compliance and subsequent consequences related to reporting tonnage type, taxes, payments, licensure, subsampling, and violations, including severity of types of violations and fees associated with those violations. View details of the amendments in the Notice to Industry.
Effective November 12, 2024, emergency regulations were implemented to align 3 CCR, Division 4, Chapter 2, Subchapter 2 with national standards for labeling of commercial feed and recognized official names of feed ingredients. The emergency regulations were approved by the Office of Administrative Law and will remain in effect until May 13, 2025. During this time, the Department will work to permanently adopt these changes through the regular rulemaking process, including a 45-day public comment period during which interested persons may submit comments regarding the regulations. View details of the emergency regulations in the Notice to Industry.
Senate Bill 1367 was approved to extend the CDFA secretary’s authority to designate a specified amount of the revenues from inspection tonnage tax to provide funding for research and education (Safe Animal Feed Education Program) from January 1, 2025, to January 1, 2031.
Safe Animal Feed Education (SAFE)
In 2024 SAFE focused on improving visibility of outreach and educational resources by utilizing the CFRP Run of the Mill Blog to archive all program updates, resources, notices, and quarterly feed update newsletters by category. SAFE enhanced collaboration with the California Grain and Feed Association (CGFA) by providing program updates and resources for distribution in the CGFA membership newsletter.
SAFE hosted its 8th Preventive Controls Qualified Individual (PCQI) for Animal Food training in July 2024, with 22 attendees completing the course. SAFE continues to support the industry in implementing requirements of the Food Safety Modernization Act and completed several food safety plan educational reviews upon request.
SAFE hosted a webinar with FDA providing education on the processes involved in bringing new and innovative feed ingredients to the market.
SAFE released the following new educational resources in 2024:
- Spanish Versions of ExtraView How to Videos
- Guidance on Mixer Efficiency Testing
- Quarterly Tips for Commercial Feed Labeling
- Quarterly Tips for Commercial Feed Labeling: Feeding Directions
Products under FDA Enforcement Discretion
CDFA’s Feed Inspection Advisory Board and its Technical Advisory Subcommittee met October 3, 2024, to discuss labeling and use of products with enforcement discretion from FDA, and specifically, Elanco’s product Bovaer® 10. They reviewed and supported CFRP’s five-step process to evaluate products/ingredients under FDA enforcement discretion for safe and effective labeling and use in California. Regarding Bovaer® 10, they reviewed information provided to CDFA’s Milk and Dairy Food Safety Branch and CFRP including the FDA Center for Veterinary Medicine enforcement discretion letter to Elanco for 3-NOP.
After conducting a review of submitted information and materials, CDFA has no current objection to the sale or use of Bovaer® 10 in California, provided it adheres to California-specific labeling requirements, it is used in accordance with its labeling, and that CDFA and FDA continue to have no questions or public health concerns regarding its safety.
CFRP released a Notice to Industry and letter to Elanco regarding the labeling and use of Bovaer®10 in commercial feed in California.
National Involvement
CFRP staff attended the annual AFRPS Face-to-Face Meeting as required per the terms of CFRP’s cooperative agreement with FDA and accepted an award in recognition of CFRP’s successful implementation of the 2023 AFRPS.
Throughout the year, CFRP staff remained engaged with the Association of American Feed Control Officials (AAFCO) by attending the Annual Meeting, Midyear Meeting, and Feed Administrators Seminar, and serving on several committees and workgroups.
Events and Meetings
CFRP staff attended the second annual State of the Science Summit: Reducing Methane from Animal Agriculture at the University of California, Davis (UC Davis), which featured informational presentations and panel discussions with leading experts in methane mitigation and animal science from around the world.
SAFE Senior Specialist KC Gutenberger attended the California Chapter American Registry of Professional Animal Scientists (ARPAS) conference and participated on the “California Methane Mitigation, Policies and Carbon Credits” panel.
Program Manager Rachelle Kennedy participated in the “Farmed Seaweed Science Needs in California” workshop hosted by California Ocean Trust.
CFRP staff attended the California Animal Nutrition Conference hosted by the California Grain and Feed Association.
Personnel Updates
Chris Hansen retired as Special Investigator for the Commercial Feed Regulatory Program with 29 years of service.
Jenna Leal was appointed as the new Environmental Program Manager II (Branch Chief) of the Feed, Fertilizer, and Livestock Drugs Regulatory Services (FFLDRS) Branch.
Rachelle Kennedy was appointed as the new Environmental Program Manager I of the Commercial Feed, Livestock Drugs, Safe Animal Feed Education (SAFE), and Antimicrobial Use and Stewardship (AUS) programs.