The Association traveled back to Washington, DC this week to meet with FDA officials and Congressional representatives on the primary issue of how Food Safety Modernization Act (FSMA) regulations on animal feed will apply to cotton gins.  Representing the Association in those meetings were Priscilla Rodriguez, WAPA Director of Food Safety, and Roger Isom, CCGGA/WAPA President/CEO.  As has been stated in the past, there are a couple of issues that remain with the applicability of the Preventive Controls Rule for Animal Feed for cotton gins, based on ownership.  FDA has acknowledged there is no difference in risk based on where the cotton is ginned; however, they refer back to the ownership of the cotton when determining applicability, which is of major concern.  Most gins would be exempt based on ownership, but some would fall under the Preventive Controls Rule for Animal Food.  FDA has acknowledged the issue and committed to future rulemaking to address the definition of a farm in order to address ownership issues; however, it is has been several months since they made the announcement at the National Cotton Council Annual Meeting in Fort Worth.  Most recently, Dr. James Gorny, FDA, announced at WAPA’s 2018 Annual Meeting that he expected something out in the spring of 2019.  In this week’s meeting with FDA, it appears to be more likely to be in the summer of 2019 or later.  FDA is concerned with unintended consequences and wants to make sure they don’t cause other problems in trying to solve this particular one.  The Association is concerned with inconsistent applicability of the regulations to operations that are exactly the same except for ownership.  The Association then spent a day in the Capitol meeting with several congressional offices to discuss the issue, including meeting with Congressman David Valadao and Devin Nunes on the matter.  Stay tuned!