FDA Clarifies Hay Regs for Farms

NCBA has been working to address concerns about implementing the Bioterrorism Act of 2002 as it relates to hay transport and sale.  Earlier this spring, NCBA sent a letter to FDA Commissioner Andrew von Eschenbach regarding NCBA members’concerns and opposing the potential recordkeeping requirements for processing and selling hay.

As it relates to livestock producers feeding or processing hay, FDA will not require recordkeeping of eligible “farms” which either harvest/process hay for feeding on their own operation or for those farms which sell hay to another eligible farm. Hay that is transported by vehicles licensed to eligible farms will not require recordkeeping either.

In many states, this regulation is already set to be implemented.  To ensure the regulation is being implemented as directed by FDA, NCBA is asking for input from state affiliates.

FDA released a guidance document Sept. 26 that provides further details about this regulation.  It was published in the Federal Register last week and is now open for public comment.

As FDA has already finalized its rule, the comment period on this guidance document is open-ended.  The full document is available at http://www.cfsan.fda.gov/~dms/recguid4.html 

NCBA encourages affiliates and stakeholders to review the FDA guidance document and contact Jenni Beck at jbeck@beef.org if you feel your state is not implementing this rule correctly.   NCBA will submit comments based on your feedback.  This is an important opportunity for states that are experiencing problems to speak up in an official way.