The rule is a major attempt to hold all facilities that manufacture, process, pack or hold animal feed and pet food to equal processing standards. It encompasses both Good Manufacturing Practices (GMPs) and hazard analysis and risk-based preventive controls.
“With this rule, I think we’ll move the safety of the feed supply forward. That’s not to say that it isn’t safe now, but we’re in a certain reactive mode and we’re trying to get to a preventive mode,” said Dr. Dan McChesney, the director of FDA’s Office of Surveillance and Compliance.
Kirsten Theisen, director of Pet Care Issues for the Humane Society of the United States (HSUS), said the need for the rule grew out of recent events.
“Certainly with the 2007 pet food recall fiasco, we learned that we can’t trust many manufacturers to, completely out of good will, produce high quality food for our pets and other animals,” she said.
One of the big gaps McChesney said the rule will fill is the need for GMPs. They cover various aspects of operations such as good hygiene practices, proper cleaning and maintenance of plants and grounds, pest control, proper use and storage of toxic cleaning compounds, following adequate sanitation principles, and proper labeling of ingredients and finished animal food.
Right now, there are no GMPs for any part of the animal feed manufacturing industry except medicated feed. This rule will expand it to the entire feed industry, but FDA still needs to work out just how that’s going to happen.
The practices laid out in the rule are based on human food GMPs, but all their stringency may not be appropriate for the animal feed industry. That’s why it’s one area in which FDA is particularly interested in comments from the public.
In addition, McChesney said, the industry is very diverse. Pet food that comes into homes has the potential to cause cross-contamination and harm humans, whereas feed for non-companion animals is just dispersed on the ground in front of the animals.
Because some practices may be essential for certain parts of the industry and superfluous for others, some stakeholders have suggested there be different GMPs for different sectors.
Like the preventive controls proposed for human food, those for animal food follow the progression of hazard analysis, preventive controls, monitoring procedures, corrective actions, verification and record-keeping.
Certain controls, including supplier verification, review of complaints, finished product testing and environmental testing, were not incorporated into the proposed rules after consultation with the Office of Management and Budget, but FDA is interested in hearing the public’s take on them.
One point the agency emphasized about the rule is that the hazard analysis takes into account both the threats to animal and human health. Dogs and cats could just be the carriers for Salmonella that ultimately infects their owners.
Some other differences between the animal and human food rules are the definitions of “very small business” and addressing nutrition imbalances in animal food, not by ensuring correct formulations, but by controlling to make sure that what is printed on the label is actually in the food.
Otherwise, McChesney said, there are few other differences as the preventive control requirements are pretty much the same.
Theisen said that HSUS is looking forward to the supply chain for pet food being standardized and more strictly regulated.
“As pets become more valued in our families as members of our families, and more and more pets are in American homes, it’s critically important that we do everything we can to protect their health,” she said.© Food Safety News