Despite the fact the rules are final and the odds are against it, the California Cotton Ginners and Growers Associations are still battling on the issue of applicability and how it applies to cotton gins under the Preventive Controls Rules for Animal Food.  As the rules stand now most cotton gins will be exempt from the Animal Food rule; however, some will be subject to the confusing rules.  Confusing, because the rules state that cotton gins are specifically exempt from the Good Manufacturing Practices (GMPs) required by the rule, but must comply with the risk assessment and supplier control provisions of the rule.  Applicability is based on ownership and in recent correspondence from FDA to CCGGA, FDA stated “We have acknowledged that the safety of animal food (e.g., cotton seed) from ginning on farm and off farm would not be different based on where the activities take place. We have also acknowledged that cotton ginning facilities are likely to determine through their hazard analysis that there are no hazards requiring a preventive control and that therefore they are not required to establish preventive controls and associated management components”.  With these statements in mind, CCGGA has engaged Congress to assist in the effort to put all cotton gins under the same provisions, meaning exemption from the Animal Food Rule.  CCGGA is working closely with the National Cotton Ginners Association and National Cotton Council on this issue.  An important announcement related to this could be made soon, so stay tuned!