The proposed rule is one of many pieces of the Food Safety Modernization Act puzzle, which is considered the largest overall rule of the US feed industry since the 1950s.

Food Safety Modernization Act (FSMA) requires the Food and Drug Administration (FDA) to create regulations for shippers, carriers by auto transit or railway vehicles, and receivers to use sanitary transportation practices to ensure food-including animal food-being transported does not become contaminated.

The goal of the sanitary transportation rule is to ensure that transportation practices do not create food safety risks.

And although AFIA openly agrees with FDA in certain areas, such as allowing "the industry to continue to use bulk transport equipment in accordance with best practices without limiting industry, by rule, to hauling non-food exclusive of or preceding any food items," the organisation listed numerous points of difference in their nine pages of comments for FDA to review.

In the rule, FDA proposed exemptions for farms and shelf stable products. AFIA suggested those exemptions be broadened to include intra-company shipments (when the company maintains control of the product), short haul transports (as defined by the US Department of Transportation) and finished product or raw agricultural commodities transported from facilities to farms in dedicated vehicles.

"Covering these types of shipments under this regulation would place an undue burden on farms and feed facilities when any minimal risk via transportation is appropriately handled with internal standard operating procedures and dedicated vehicles," said Ms Leah Wilkinson, AFIA director of ingredients, pet food and state affairs.

Similar to AFIA's comments on other FSMA-related rules, AFIA commented that FDA should lower the recommendation on the definition of "non-covered business" to engage businesses with transportation operations with less than $10,000 in total annual sales.

AFIA commented the organisation "believes that no firm, regardless of annual sales volume, should be exempt if they are engaged in transportation operations of food" and that everyone has a responsibility to produce safe food.

FDA is proposing carriers of bulk products provide information to the shipper on three previous loads as FDA understood that is current industry practice.

"AFIA commented, that while this may be standard practice in some segments of the food industry, it is not current practice across the entire food and animal food industry," explained Ms Wilkinson.

"Our organisation recommends this section be changed to require identification of one previous load, which is more practical and would fit within a facility's food safety plan procedure more appropriately."

The organisation also made note of the temperature control measures and hand washing facility requirements originally proposed are not appropriate across the animal food industry and would induce unnecessary cost on the industry without improving the safety of animal food products.

AFIA urged these requirements to be removed for animal food.

"At the very least, FDA should revise the language in the final rule to make it clear that continuous temperature monitoring is not required for animal food," the comments stated.

"Currently, temperature control shipments in the animal food industry do not involve the use of continuous time/temperature recording devices for most temperature-controlled shipments as the risk level for animal food safety does not require this practice."

The comments on the proposed sanitary transportation rule were drafted by AFIA members who volunteered as part of a work group to review the rule. FDA, under a court ordered deadline, must issue the final rule on this topic by 31 March, 2016.