FDA answers questions on use of crops harvested from flooded fields

FDA issues update with questions and answers related to using crops harvested from flooded fields, especially after hurricanes.

The Food & Drug Administration's Center for Veterinary Medicine (CVM), which regulates animal feed, issued an update Sept. 8 with questions and answers related to using crops harvested from flooded fields.

Can I use the crops that have been harvested from fields flooded by a hurricane for animal feed?

In general, crops harvested from flooded fields are not considered acceptable for use in animal feed.

Why are crops from flooded fields generally unacceptable?

It is reasonably likely that flood water contain sewage, pathogenic organisms, pesticides, chemical wastes or other toxic substances. Even more serious is the mold growth which may occur in wet foods. Certain molds produce mycotoxins that are toxic or carcinogenic to certain animals, including humans, and if present in animal feed, can result in the presence of unsafe residues in foods produced from the animal.

Is there anything I do to salvage crops harvested from flooded fields?

To be considered for use in animal feed, flood damaged crops would need to go through some kind of cleaning and heat treatment or drying process. In addition, at a minimum, the material would need to be tested for the following: 

a. Mycotoxins to include at least aflatoxin, fumonisin, vomitoxin, zearalonone, and ochratoxin. Mycotoxins should not be present above guidance levels found on FDA's website.

b. Heavy metals, with emphasis on cadmium, mercury and lead. Maximum acceptable levels for these metals in complete animal feeds are available in the National Academy of Science/National Research Council "Mineral Tolerance of Domestic Animals".

c. Presence of certain pathogenic bacteria and their toxins, especially salmonella, Escherichia coli O157:H7 and Clostridium perfringens and botulinum. Heat treatment should have been sufficient to destroy pathogenic organisms.

d. Pesticide screen, with particular emphasis on organophosphate and chlorinated hydrocarbon pesticides. Information on multi-residue pesticide test screens and permitted pesticide levels on food and feed is available on FDA's website.

e. Presence of PCBs (polychlorinated biphenyls) consistent with the levels found in Title 21, Code of Federal Regulations, Part 500.45.

I want to salvage adulterated food to acceptable animal food. What do I need to do?

You must send a written request to your closest FDA District Office to recondition or divert adulterated human or animal food to acceptable animal food.

What information do I need to provide to the FDA District Office?

CPG 675.200 (see references) provides a step-by-step process for proposing to recondition or divert adulterated human or animal foods to acceptable animal food use.

1. Provide your name, address, phone number and email.

2. Provide the name and owner of the subject products (may be the same as item #1).

3. Describe the precise physical location of the subject products.

4. List all identified information of the product, including unit, serial, catalog, order number and quantity.

5. Explain the reason the product is considered adulterated or misbranded for its original intended use.

6. List all adulterants: biological, chemical or physical hazard (e.g., salmonella, aflatoxin, pesticide PAH from fire, etc.).

7. Hazard analysis documentation: provide a detailed analysis of the adulteration, including a detailed description of the source or cause.

a. List the determined levels of adulterants for each lot.

b. Provide all laboratory analytical data and methodology used to determine levels of adulterants.

c. List the names and addresses of all proposed consignees (buyer or end user), if any.

d. List proposed labeling (new or revised labeling for reconditioning product).

e. Describe in detail the reconditioning procedures to be used (briefly explain or provide an attachment):

* As appropriate, describe critical treatment parameters or diversion steps to bring the product into compliance.

* Intended use of reconditioned commodity: provide the specific target animal species for the reconditioned animal food, indicate whether the target animal is a food or non-food-producing animal.

* Final disposition or preventive control. If the reconditioning is not successful or portions are not reconditioned, please provide: date, location, process for the destruction and a statement verifying that the destruction does not violate any local, state or federal environmental laws.

f. Describe or attach a copy of written instructions to accompany product, including any special instructions for handling, transferring and required correspondence between agencies, etc.

g. Provide all information available related to the potential safety concern and hazards of the adulterant for the intended animal use and, when intended for food animals, for the consumption of animal products that may enter the human food chain.

If I follow the criteria described above, will I then be able to use these crops for animal food?

Possibly, but you must notify the (state) department of agriculture of any attempt to clean, process, test and sell or use these crops in animal feed. CVM will be available for consultation, if needed.

Also, you may be required to conduct additional testing of specific industrial or environmental contaminants as information on the industries and facilities located near crops in affected areas becomes available.

You may also have to follow FDA's Compliance Policy Guide 675.100 and 675.200 for the use of these flood-damaged crops in animal feed.

References:

CPG 675.200 Diversion of Adulterated Food to Acceptable Animal Feed Use

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