AFIA submits comments to FAO on sustainability guidelines

Group wants to make document applicable to North American agriculture

The American Feed Industry Association (AFIA) recently submitted comments to the Food and Agriculture Organization of the United Nations on the Livestock Environmental Assessment Performance (LEAP) draft guidelines regarding the animal feed supply chain.

AFIA was pleased the guidelines seemed well constructed, including their breadth and depth. The report, developed for a more harmonized approach to Life Cycle Assessments (LCA) in the animal feed industry, takes into account the various production sectors involved. The draft also defines the methods necessary to produce consistent LCAs across the animal feed industry.

“We worked with our membership to review and draft comments because we want to make this document applicable to North American agriculture,” said Richard Sellers, AFIA senior vice president of legislative and regulatory affairs.  

The organization requested FAO report reasonable ranges of uncertainty in LCAs, commenting AFIA members feel these ranges should likely be large. “Explicitly stating data sources and sensitivity analyses results should be included as elements of the LCA report will help ensure higher credibility of the guidelines,” stated the comments. “Additional clarity on time-related representativeness of data collection (page 45, lines 11 and 12) would also be helpful.”

AFIA also commented FAO should clarify how the LEAP guidelines relate to the Product Environmental Footprint guide-the reference document that currently receives the greatest attention and drives significant market share-and requested clarity in accounting for co-products.

“We suggest in our comments that FAO give credit for human food co-product that is used in animal food, as it transfers otherwise needed nutrition and those nutrients would go to waste if not recycled by the animal food industry,” said Sellers.

In addition to LEAP, AFIA continues to work on a number of sustainability projects including the Specialty Feed Ingredients Sustainability project and the Global Network for the Development of Nutrition-related Strategies for Mitigation of Methane and Nitrous Oxide Emissions from Ruminant Livestock project. Both of these projects are envisioned to be included in LEAP in the near future.