Hemp Byproducts in Horse Feed
It is our position that sufficient scientific research to support the safety and utility of hemp in animal feed must be completed prior to any Federal or state approval. We understand the importance of supporting the hemp industry, and yet we also believe it is simply too soon to know whether hemp is safe and effective for horses as marketed. Our goal is for more research to ensure the safety and well-being of the public, our animals and our industry. Scientific research is needed.
Interest in the use of hemp in commercial animal feed has accelerated since the passage of the 2018 Agricultural Improvement Act (“Farm Bill”). While the Farm Bill expanded the legal production of hemp in the United States, the use of hemp in animal feed remains under the jurisdiction of the U.S. Food and Drug Administration (FDA) and state regulatory programs for commercial animal feed. However, many state leaders and lawmakers are being asked to circumvent Federal and state oversight by considering legislation that will allow the use of hemp in animal feed in their respective states before the completion of the critical scientific research to affirm the safety of hemp — and before the necessary review by the FDA. Safety mechanisms and procedures are critical. Every day, Americans purchase food for their horses with the reasonable expectation that it is safe, and that the nutritional benefits claimed on the label are supported. While consumers have this expectation, most are unaware of the scientific research and regulatory reviews that are in place to affirm the safety of animal feed ingredients.
Currently, no hemp ingredients have been approved through the established animal feed ingredient review pathways. It would be imprudent to bypass these established procedures needed to protect both human and animal health and unilaterally legislate approval of animal feed ingredients at the state level. Concerns should be addressed. We are concerned that state leaders and the general public may not be fully aware that any new ingredient intended for animal feed must go through a scientific and legal review process to ensure safety and utility. Therefore, we wish to highlight three specific concerns regarding the inclusion of hemp in animal feed prior to the necessary research and regulatory review.
First, we have concerns about the health and safety of our horses. Although research is underway, it is limited and not conclusive. Some parts of the hemp plant have the potential to serve as sources of nutrition in many animal diets. However, it is not yet clear whether animals fed hemp-based diets will perform similarly to animals fed traditional diets that farmers and ranchers depend on today. Even hemp that is compliant with existing regulations for production contains ∆9-THC (<0.3%) and other cannabinoids. There is not a conclusive understanding of the long-term impacts of these compounds on the health of animals and results of existing research raise safety concerns. To achieve approval for use in animal feed, scientific evidence supporting long-term safety and utility is needed before commercial use.
Additionally, there are concerns about legal implications for horse owners and feed manufacturers. Even if a state legalizes hemp for use in animal feed, the use of the ingredient is not yet approved at the Federal level. Animal feed containing hemp that crosses state lines is subject to Federal regulation and could be considered adulterated under the law. The pursuit of review through established processes will effectively address all state and Federal regulatory requirements, granting access to local, national, and global markets. Without Federal review, the access for producers and manufacturers to interstate and global markets can be negatively impacted.
Recommended actions are doable and achievable. Instead of initiating statutory or administrative approval of hemp in animal feed at the state level, we recommend that state leaders and proponents of hemp in feed work through the defined regulatory pathways used for every animal feed ingredient. We urge state leaders to support research through universities or private labs so that the safety and utility of hemp can be fully understood before it is allowed for commercial purposes.