Hemp farmers might soon have a new market to tap into, with federal approval: animal feed.
Last week, the University of Tennessee Institute of Agriculture at the University of Tennessee Knoxville hosted the 2021 Hemp Products and Animal Health Conference, which covered a variety of hemp and cannabidiol-related topics, from government policy to animal health and product quality. The event was partially funded through a small conference grant from the Food and Drug Administration.
One of those sessions was led by Charlotte Conway, Deputy Director in the FDA’s Division of Animal Feeds, who covered the regulatory processes that producers need to navigate to put substances like hemp in animal feed.
The 2018 Farm Bill legalized low-THC cannabis, or hemp, and set off a wide swath of regulatory gray areas, including whether and how hemp could be consumed by animals. (Read Cannabis Wire’s deep-dive into the complexities of hemp in animal feed.)
“Hemp has been, accidentally, a special focus of mine over the last few years,” Conway said. “This is something that I’ve spent a lot of hours talking to people about, and I’m getting very hopeful that we’re headed down the road to seeing some hemp-derived ingredients approved for use in animal food.”
Broadly, animal food is regulated by the FDA and is separated into two buckets: food that “food producing species, such as aquaculture and livestock” consume — in other words, animals that will become human food — and “companion animals,” like dogs or cats.
Under the FDA’s umbrella, the Center for Veterinary Medicine is the body that regulates food and drugs for animals. Further, the Division of Animal Feeds regulates any type of substance, including hemp, that might be added to animal food.
Conway laid out the two main pathways for putting an additive, which in this case would be hemp, into animal feed: a food additive petition, or the conclusion that the additive is “exempt” from various requirements related to the Federal Food, Drug, and Cosmetic Act because it is “generally recognized as safe,” or GRAS.
Though, the approval of hemp in animal feed is complicated by the fact that the FDA has approved a CBD-based pharmaceutical: GW Pharmaceuticals’ Epidiolex. Conway flagged that substances that have been “studied as drugs and/or are a controlled substance” are “not acceptable for addition to animal food.” This same factor has played into the FDA’s slow rollout of rules for human consumption of CBD products, as Cannabis Wire has extensively covered.
Therefore, Conway continued, “At this time, there are no approved food additives for any substances derived from cannabis, including hemp, and FDA is not aware of any basis to conclude any substances are GRAS for use in animal foods.”
This is due to a dearth of “available safety data” related to “animal use of cannabis products,” Conway noted during her presentation. And while there’s been a proliferation of “treats” and other products marketed to animal owners that contain hemp and CBD, there are “none legally.”
“One of our big, big data gaps is the potential for residues to accumulate in food producing animals,” Conway said. “Based on some of the metabolic data that is available in lab animal species, this is an area of interest, and hopefully there are going to be a number of ingredients that can be derived from hemp that would have de minimis cannabinoid levels.”
And, with further data, regulators could “address that safety concern,” but that’s not where things end.
“There are certainly other parts of the plant where it’s likely that there is the potential for residues that could raise human food safety concerns,” Conway said.
What about those CBD supplements that are marketed for, say, aging labradors with arthritis?
“Products marketed as supplements for animals with CBD, because of the types of claims, would likely be considered unapproved drugs,” Conway said. “And there certainly is potential for enforcement action for these illegally marketed products.”
So, broadly, where do things stand today when it comes to hemp and animal feed? Conway said that there are numerous university studies underway, and that the FDA has “talked to producers” and commercial labs about their analytical methods.
“We’ve certainly been engaging with a number of folks on the use of hemp or hemp-derived ingredients in animal food through those regulatory processes,” Conway said. “I hope that all of this means that there will be some hemp-derived ingredients that are reviewed as safe for use in animal food soon.”
