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Colorado Department of Agriculture reveals its Hemp in Animal Feed Study

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Colorado is once again leading the country in creating new opportunities in the Hemp Industry. With the unanimous passage of Senate Bill 109, sponsored by Senator Kerry Donovan and Rep. Jeni Arndt the legislature approved a study on the inclusion of Hemp in Animal Feed.  Led by the Colorado Department of Agriculture and a stakeholder group that included livestock producers, veterinarians, higher education institutions and legal professionals the report was released at the beginning of the year and the complete study can be found here.

The study identified six conclusions:

1: Prioritize federal approval Since animal feed ingredients are subject to regulation by both the U.S. Food and Drug Administration (FDA) and state governing agencies, stakeholders noted that a submission effort should focus on gaining federal approval, rather than approval by states individually. However, there are resources and general support from private industry and academic institutions in Colorado that can contribute to a submission effort, including conducting additional research that will most likely be needed for a comprehensive submission to the FDA.

2: Focus on whole hemp seed and hempseed by-products An ingredient submission should focus on parts of the plant that have the best chance of receiving federal approval, namely whole hemp seed and hempseed by-products: i.e., hempseed cake and hempseed oil. Other parts of the plant, such as the stalk, flower, root, and leaf could be the focus of a future ingredient submissions if research supports their safety and utility for livestock production and companion animals.

3: Conduct research on economic viability Economic research on the viability of any new crop is essential. Stakeholders felt there is a lack of domestic economic data specific to hemp seed and hempseed by-products in animal feed. Additional U.S.-based economic studies on hemp by-products for use in animal feed would help address questions regarding the practicality of producing and manufacturing hempseed products for animal feed as well as provide a competitive analysis of existing feed options currently used.

4: Target submission of a Food Additive Petition (FAP) While there are multiple pathways for a proposed ingredient to become approved for animal feed, stakeholders felt that any submission effort should focus on submitting a Food Additive Petition (FAP) to the Center of Veterinary Medicine at the FDA (FDA-CVM) due to the safety concerns surrounding hemp.

5: Include an experienced consultant in the collaborative effort Considering the growing interest in hemp by-products in animal feed for both livestock and companion animals, any submission effort should strive to be a collaborative effort that includes a broad number of participants from private, public and academic organizations. While collaboration is a key conclusion from group discussions, stakeholders recommended that a submission effort is coordinated through a consultant with experience in developing and submitting FAPs to the FDA-CVM.

6: Execute a S.A.F.E petition process Execution of a submission effort will require a “S.A.F.E.” petition to be successful, where petitioners should:

  • S – Start early discussions with the FDA-CVM
  • A – Assemble and assess existing research
  • F – Fill in any gaps with additional research
  • E – Execute a targeted petition that identifies specific species and intended uses

A “food additive” is defined by the Food and Drug Administration as “any substance that—directly or indirectly—becomes a component or otherwise affects the characteristics of any food. This definition includes any substance used in the production, processing, treatment, packaging, transportation or storage of food.” Although Hemp has been in food for decades (if not a centuries) there has been no official application submitted to the USDA to include hemp in either human food or animal feeds. The USDA and FDA have asked the Hemp Industry to provide them with guidance and is poised to approve Hemp Food. It is time for the industry to come forward and engage with the FDA and USDA to meet the assessments required in the approval process.  This will not be accomplished without due diligence and investment from the Hemp Industry.

The first step will be to complete the Food Additive petition. A new coalition being driven by the Colorado Hemp Industries Association has stepped forward to lead this effort with the collaboration of Hemp Farmers, Livestock producers, and the National Animal Supplements Council. The petition promises to be time consuming with a need for additional research and a qualified consultant to complete the application. But, the potential benefit to Hemp farmers and processors across the United States is will hemp into mainstream food production for the first time and begin to recognize the true market potential of Hemp.

Additional Online Resources:

The Food Additive Petition is managed by the United States Department of Agriculture for more information on Food Additives visit:

https://www.fsis.usda.gov/wps/portal/fsis/topics/food-safety-education/get-answers/food-safety-fact-sheets/food-labeling/additives-in-meat-and-poultry-products/additives-in-meat-and-poultry-products

 

“Colorado bill directs CDA to study the use of hemp in animal feed”:

https://www.thefencepost.com/news/colorado-bill-directs-cda-to-study-the-use-of-hemp-in-animal-feed/

 

“CDA FAQs on Industrial Hemp as Commercial Feed”:

https://www.colorado.gov/pacific/aginspection/faqs-industrial-hemp-commercial-feed:

 

“Summary of the “Industrial Hemp in Commercial Fed Stakeholder Review”:

https://www.colorado.gov/pacific/sites/default/files/HempFeed%20Website%20Update.pdf

 

“A Stakeholder Review of the Feasibility of Industrial Hemp By-Products as Animal Feed Ingredients”:

https://www.colorado.gov/pacific/sites/default/files/CDA%20Report%20on%20Hemp%20in%20Animal%20Feed%2012-29-2017.pdf

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