You may not know that in addition to producing cotton for the fabrics that we use every day, cotton farmers and ginners produce food. After being separated from fibers in a process called ginning, cotton seeds and cotton plant parts are often used to feed livestock. Cotton seeds may also be further processed into cottonseed oil and cottonseed meal for animal food.
Because products from ginning enter the food supply, concerns have been raised by the cotton industry about the impact on cotton ginners of new requirements under the FDA Food Safety Modernization Act (FSMA). To better understand these concerns, my colleagues and I traveled to northern Alabama last month to visit a cotton farm, ginning operation and a cotton warehouse.
FDA regulates the use of cotton plant material and seeds in animal food.Traditionally, cotton ginning has fallen under the general food adulteration provisions of the Federal Food, Drug, and Cosmetic Act.Now, certain operations are also subject to the FSMA-mandated preventive controls requirements, which applies to manufacturing facilities rather than farms. Most cotton ginning is done by farms, whose ginning operations don't fall under the new requirements. But cotton gins that aren't part of a farm are considered manufacturers subject to the preventive controls requirements, which include a hazard analysis and the implementation of controls to minimize hazards.
The cotton industry argues that this doesn't make sense since all cotton ginners are essentially doing the same work. So why would we impose FSMA requirements only on non-farm operations? We have always said that we will work with industry to find solutions when the FSMA rules produce inconsistencies like this one. We have visited food facilities and farms all over the country and overseas to understand what's working well and what issues may need to be addressed.
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