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Animal food, renderers added to critical infrastructure list

DHS updates language in critical infrastructure guidance to include previous gray area for those in animal feed sector.

When the U.S. Department of Homeland Security released the first version of its critical infrastructure guidance in mid-March, there were some concerns for the animal feed industry as it pertains to certain segments that may not have been included.

Jenny Murphy, deputy director for foods in the Office of Surveillance and Compliance at the Food & Drug Administration’s Center for Veterinary Medicine (CVM), said in an updated guidance released March 28 that in working with several stakeholders, FDA was able to direct DHS to address many concerns, including what is needed for livestock food, pet food, renderers, food packaging, transporting, pet food stores and feed and grain stores.

The American Feed Industry Assn. (AFIA) said it provided feedback to DHS before the agency released this list to define the aspects of the animal food industry. One area that DHS did not make clear in the guidance is the role of retail stores -- aside from grocery stores -- that sell animal feed and pet food. The critical role of the rendering industry was also not included.

AFIA vice president of public policy and education Leah Wilkinson noted, “AFIA shared our concerns with the Food & Drug Administration and DHS and was pleased when updated guidance clarified the essential role that animal feed and pet food manufacturers, retailers, suppliers, shippers and others throughout the animal food supply chain play in keeping America’s livestock, poultry and companion animals fed. So far, states have used this federal guidance or provided a similar list in their stay-at-home orders, and our members are staying in close communication with their state and local officials to ensure their products can continue making it to their customers.”

Based upon feedback, DHS released an updated guidance document that makes these corrections. The specific areas defining critical food and agriculture workers is below (new text is underlined):

  • Workers supporting groceries, pharmacies, convenience stores and other retail establishments that sell human food, animal/pet food and beverage products;
  • Restaurant carry-out and quick-serve food operations – carry-out and delivery food employees;
  • Food manufacturer employees and their supplier employees – to include those employed in food processing facilities (e.g., packers, meat processing, cheese plants, milk plants, produce, etc.); livestock, poultry and seafood slaughter facilities; pet and animal feed processing facilities; human food facilities producing byproducts for animal food; beverage production facilities, and the production of food packaging;
  • Farm workers to include those employed in animal food, feed and ingredient production, packaging and distribution; manufacturing, packaging and the distribution of veterinary drugs; truck delivery and transport, and farm and fishery labor needed to produce the U.S. food supply domestically;
  • Farm workers and support service workers to include those who field crops; commodity inspection; fuel ethanol facilities; storage facilities, and other agricultural inputs;
  • Employees and firms supporting food, feed and beverage distribution, including warehouse workers, vendor-managed inventory controllers and blockchain managers;
  • Workers supporting the sanitation of all food manufacturing processes and operations from wholesale to retail;
  • Company cafeterias – in-plant cafeterias used to feed employees;
  • Workers in food testing labs in private industries and in institutions of higher education;
  • Workers essential for assistance programs and government payments;
  • Employees of companies engaged in the production, storage, transport and distribution of chemicals, medicines, vaccines and other substances used by the food and agriculture industry, including pesticides, herbicides, fertilizers, minerals, enrichments and other agricultural production aids;
  • Animal agriculture workers to include those employed in veterinary health; manufacturing and the distribution of animal medical materials, animal vaccines, animal drugs, feed ingredients, feed and bedding, etc.; transportation of live animals, animal medical materials; transportation of deceased animals for disposal; raising of animals for food; animal production operations; slaughter and packing plants; renderers, and associated regulatory and government workforce;
  • Workers who support the manufacture and distribution of forest products, including, but not limited to timber, paper and other wood products, and
  • Employees engaged in the manufacture and maintenance of equipment and other infrastructure necessary to agricultural production and distribution.

Murphy said the DHS list in its entirety is not meant to be binding but, rather, as a tool for local and state governments to build their own list.

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