Under U.S. Food and Drug Administration (FDA) regulations, commercial grain elevators are facilities that are solely engaged in the storage of raw agricultural commodities. For that reason, they are exempt from some, or all, of the Food Safety Modernization Act (FSMA) regulations. However, under FDA’s current interpretation, any grain elevator that is co-located with a feed mill loses its exempt status and falls under the full FSMA regulatory requirements, such as Current Good Manufacturing Practices (CGMPs) for animal food production.
This FDA interpretation is set forth in an October 2017 guidance document which states that, “If any part of a facility is engaged in an activity subject to the CGMP or preventive controls requirements, then the entire facility is subject to CGMPs, the preventive control requirements, or both.”
Kansas Grain and Feed Association (KGFA) is working with National Grain and Feed Association to seek an interpretation of the FSMA regulations to ensure that a grain elevator will not lose its exempt status if it is co-located with an animal feed mill.
If you have received an FDA inspection of your feed mill and co-located grain elevator, and your entire facility was made subject to the FSMA regulations under the current FDA interpretation of “co-location,” please contact KGFA staff via email (firstname.lastname@example.org) or via phone (785-234-0461) so we can provide a report of these incidents.