ACAF Annual Report 2023/24 - Introduction

Introduction

Overview 

The Advisory Committee on Animal Feedingstuffs (ACAF) provide independent scientific advice to the Food Standards Agency (FSA) and ministers on the risks in relation to animal feed, with particular regard to human health. The advice and support given by the Committee is crucial in helping the FSA fulfil their mission of “food we can trust”. This means that food is safe, food is what is says it is, and food is healthier and more sustainable.  

The ACAF is a Scientific Advisory Committee (SAC) that provides expert advice to the FSA/Food Standards Scotland (FSS) as part of the risk assessment process. The main role of the ACAF is to assess regulated product applications of feed additives, feed for particular nutritional uses (PARNUTs) and feed detoxification processes. These products require authorisation before they can legally be sold in the United Kingdom (UK).  

Since the UK left the European Union (EU), the FSA have taken on responsibility for assessing food and feed safety in the UK. This includes all applications for regulated products, which are handled through the Regulated Products Service (RPS).   

One of the major challenges for the ACAF over the past year has been the ongoing reform of the Regulated Products Service (RPS). This has led to changes in the ways of working for the Committee, with more changes expected over the coming year. 

The current approach to authorising regulated products is based on the EU model, but certain aspects of this approach are disproportionately resource intensive to the level of risk. There are a large number of applications in the system, and consequently the time taken to authorise can be unacceptably long. 

Reform of the service is needed to facilitate innovation and enterprise, but without compromising the high standards held by the FSA. Public health, consumer interests, being open and transparent and basing decisions on science and evidence all remain key priorities of the FSA. 

In January, the FSA Board was presented with two initial reform measures. One of these was a proposed legislation change to eliminate the need for periodic renewal of authorisations. All feed additive authorisations must currently be renewed every 10 years. Renewal of authorisations makes up a significant caseload of the RPS; 47% of feed additive applications are renewals. Consequently, renewals take up a large amount of the Committee’s time, yet the products have a history of safe use. The proposed reform would free up the resources of the Committee to focus on applications for new or novel feed additives.  

As part of the continuous reform of the RPS, there has been a move towards more FSA/FSS-led risk assessments, particularly for more routine applications. There has been greater use of Other Regulator’s Opinions (OROs), such as those of the European Food Safety Authority (EFSA), and this is proposed to increase further in the future. Risk assessments for novel applications that pose more complex toxicological and/or scientific challenges are still Committee led. This means that the type of applications seen by the Committee are evolving and likely to continue to change as the RPS continues to reform.   

This report outlines the work that has been done by the Committee over the 2023/24 Financial Year (FY). 

Role and responsibilities of the Committee 

The role of the ACAF is to advise the FSA and ministers on the risks in relation to animal feed, with particular regard to human health. Their main responsibility is to carry out the risk assessment for applications of feed additives, feed for particular nutritional uses and feed detoxification processes. 

The Committee comprises an independent chair and fifteen independent members. The Committee is made up of a range of experts, covering relevant scientific disciplines, and knowledge of the feed sector who provide insight, advice and the technical knowledge needed to evaluate the safety of animal feedstuffs applications.  

More information about the roles and responsibilities of the Committee can be found in the ACAF Terms of Reference. 

ACAF Code of Practice 

All Members of the Committee adhere to the ACAF Code of Practice. Members act in the public interest and observe the highest standards of impartiality, integrity and objectivity. All Members uphold the public service values expected of them, following the ethical standards outlined in The Seven Principles of Public Life.  

All interests, both personal and non-personal, must be declared.  Members do not misuse the information gained in their activities for personal or political gain, or to promote their personal interests or those of other connected persons, firms, businesses or other organisations. 

Members are aware of their roles and responsibilities and are held to account for the decisions that they make. They have a collective responsibility to ensure that the Committee operates effectively.  

More information can be found in the ACAF Code of Practice. 

Good Practice Guidelines for Scientific Advisory Committees 

All Scientific Advisory Committees that advise the FSA and for which the FSA is the sole lead or sponsor department must follow the Good Practice Guidelines for Science Advisory Committees.  

The guidelines contain twenty-nine principles of good practice, although not all principles are relevant to every committee. The Committee have reviewed their application of these principles over the period of this report (Appendix II) and will continue to do so annually, in line with the Guidelines.  

Compliance with the Guidelines is also covered in the annual self-appraisal by Members (Appendix II) and annual feedback meetings between each SAC Chair and the FSA Chief Scientist. 

Ways of Working 

In 2022, the Animal Food and Food Additives Joint Expert Group (AFFAJEG) was reformed into the original parent Committee, the ACAF. This led to a change in the function and remit of the AFFFAJEG to allow full risk assessment advice to be given.  

The Committee’s primary focus is on risk assessment of regulated product applications. The ACAF are fully supported in their work by a Secretariat, supplied by the FSA/FSS. For all ACAF-led assessments, the Secretariat perform an in-depth completeness check of the technical dossier against the applicable regulations and any associated guidance documents. The Secretariat can flag any areas of concern for the Committee, but the ACAF has full access to the entire technical dossier.  

The Committee request further information from the applicant if required to evaluate the application.  

Once the ACAF have assessed the application, they prepare their conclusions with regards to identity and characterisation of the additive, safety for consumers, the target animal(s) and the environment, safety for users and efficacy (where applicable).  These are summarised in the form of a Committee’s Advice document. The FSA/FSS consider the recommendations in the Committee’s Advice document to formulate a Safety Assessment. The Safety Assessment aids Risk Managers in the risk management phase of the risk analysis process.  

More information can be found in the ACAF Ways of Working. 

Areas of work 

The majority of applications considered by the ACAF are for animal feed additives. Assimilated Regulation (EC) 1831/2003 and assimilated Commission Regulation (EC) No 429/2008 outline the authorisation procedure for these substances, and describe the requirements that must be met, respectively. The Committee consider applications against the legislation and relevant EFSA Guidance.  

In the period of this report, the Committee considered thirty-five applications for authorisation of animal feed additives under assimilated Regulation (EC) 1831/2003. Members also reviewed and finalised the Committee’s Advice documents for an additional six applications that were assessed in the 2022/23 FY. The FSA/FSS published 23 Safety Assessments based on the recommendations of the ACAF during this time. For more information refer to Section 3: The Committee’s work in 2023/24.  

The Committee also consider applications to update the list of intended uses of feed intended for particular nutritional purposes (PARNUTs), as laid out in assimilated Regulation (EU) 2020/354. 

Feed intended for PARNUTs may only be marketed in Great Britain (GB) if its intended use is included in the list of intended uses, or it meets the essential nutritional characteristics for the respective particular nutritional purpose included in that list. If not, an application must be submitted to amend the legislation. Applicants can request to add an intended use of a PARNUT to the list or add/change the conditions associated with a particular intended use of a PARNUT.  

Unlike with feed additives, there is no formal guidance available for PARNUT applications. When considering applications, the Committee evaluate whether the proposed change is likely to have any adverse effects on animal or human health, the environment or animal welfare. Members also assess whether the proposed intended use fulfils the particular intended nutritional purpose.  

During the 2023/24 FY, the Committee considered two applications for modification of the PARNUT legislation, assimilated Regulation (EU) 2020/354. Members also reviewed and finalised the Committee’s Advice document for one application that was assessed in the 2022/23 FY. Two Safety Assessments were published by the FSA/FSS, based on the recommendations of the ACAF. Details on the applications considered can be found in Section 3: The Committee’s work in 2023/24.  

The third type of applications that fall under the Committee’s remit are for feed detoxification processes. There is no specific guidance available for applications for feed detoxification. However, any dossier should demonstrate that the detoxification process meets the acceptability criteria established in assimilated Regulation 2015/786.  

In the period of this report, the Committee did not consider any applications for feed detoxifications processes.  

In addition to assessing regulated product applications, the Committee also take part in activities to improve their knowledge and expertise. Members participated in an “efficacy workshop”, designed to give Members an overview of how efficacy testing is performed and interpreted.