[Vision2020] Feed formulation and government regulatiion

[lfalen]

Thanks to Saundra for her keeping us informed on the recalls.
 I worked in the Feed Industry for many years, so thought I would share a few thing with you. I at one time formulated pet foods for Manna Pro and Arizona Feeds (now Eagle Milling). I was in charge of all feed registrations and regulatory matters. We were regulated by The FDA, EPA and OSHA. EPA and OSHA were more difficult to work with and some of their regulations asinine. For the most part (some exceptions) FDA did a good job. FDA prints a list of product that they have found adulterated in The FDA Veterinarian, which can be found on line. This includes products for human consumption. Fish product such as Tuna are frequently listed.

All feeds have to list there ingredients. This can be done in two ways. By individual ingredients or group terms and have do be in descending order by the amont in which they are included. Examples of group terms are: Grain product--corn, barley oats, etc",  Processed grain By-product- wheat millrun, corn gluten meal, wheat gluten meal, rice bran, etc.. What can be included in group listing vary by state. This makes it real interesting when one is writing feed labels for products to be sold in all states.
                                                                
In the case of American Nutrition, if they were using group terms,  wheat gluten meal could have been included as Processed Grain By-products. Most pet foods however do not use group terms. Least costing is also a common practice that is used to take advantage of changing ingredient prices. When I formulated feeds, I placed rather narrow ranges on what could be allowed, specifying minimums and maximums. This sometime got me into trouble with administers wanting to keep cost down instead of maximizing quality. If an ingredient was used that was not specified, it would be unethical.
I encounter a problem like this when I worked for Coast Trading in Spokane ( no longer in business). I had formulated a feed lot ration using blue grass seed screening( a grain). the Plant Manager changed my formulation before it went to the mixer personnel. He replaced blue grass seed screening with  blue grass ( a hay product). This was a lot cheeper in price and also a lot lower in energy. I reported this to the Management in Portland. They said "we haven't been sued yet have we" I said "no"
They said " then what is the problem".  I said " If you are going to back him, then you don't need me". I quit on the spot.


Roger