How will FSMA impact pet and animal food?
More than half of all American households have a pet dog or cat. With an estimated 71.6m dogs and 73.6m cats in the United States alone it is no surprise the pet food industry is booming. Over 8 million metric tons of food and treats are shifted nationally each year to the value of $21.4bn.
Pet food and animal feed manufacturing is undergoing large changes with the introduction of FSMA rules for food for animals. These regulations come with a cost attached. According to the FDA’s estimates, complying with the FSMA regulations regarding animal feed will cost the industry roughly $130,000,000 annually.
Compliance with the new FSMA regulations will cost the pet food industry roughly $130 million
Self-government is not enough
Before I get down into the weeds here, it might help the reader to know that I got my feet wet in the food industry at a dog food cannery many years ago. I learned a lot about making pet food both at a practical level in the factory, and then at the corporate level I was exposed to the regulatory side of things.
What I learned was that aside from a CFR standard that the canneries were held to, the pet food industry itself was largely ‘self-governed’. Human nature being what it is, some smaller companies took advantage of the lack of federal (and even state) oversight and reaped profits at the expense of food safety. Fast forward to the melamine recall, and it really was a ‘no brainer’ for responsible pet food companies to call for action.
Just about everybody is aware of the 2007 melamine scandal that caused renal failure in pets and resulted in widespread panic and extensive recalls of pet food. This particular incident brought to light that there was a void in federal regulations for the food safety of pet and animal feed.
Manufacturing companies, stakeholders, consumers, and -of course- Congress joined forces and pushed for regulatory standards that would promote accountability within the industry. The FDA is attempting to fill that gap with the FSMA Preventive Controls for Animal Feed rule, though many pet and animal feed manufacturers now consider it to be a bit of an over reach to say the least.
Animal food key requirements in FSMA
The requirements for animal food manufacturing are now held to the same standard as those of human food production. With this new prevention based system the FDA expects to see reductions in the risk of serious illness and death to animals as hazards are controlled.
The requirements for animal food manufacturing are now held to the same standard as those of human food production.
The Key Requirements, as pointed out by the FDA, for the new legislation are:
- Current Good Manufacturing Practices (CGMP’s) are established for animal food production
- Covered facilities must establish and implement a food safety system that includes an analysis of hazards and risk-based preventive controls. The rule sets requirements for a written food safety plan that includes: Hazard Analysis, Preventive Controls, Oversight and Management of preventive controls (Monitoring, Verification, Recall Plan). This is no different from the HARPC requirements impacting human food manufacturers.
- Supply-chain program is more flexible, with separate compliance dates established.
- The definition of a ‘farm’ is clarified in the Preventive Controls for Human Food final rule to cover two types of farm operations. Operations meeting the definition of ‘farm’ are not subject to the preventive controls rule. The two types of farms are Primary Production Farms and Secondary Activities Farms
- Feed mills associated with farms (vertically integrated operations) are not covered.
You can read full summaries of each requirement on the FDA’s page about preventive controls for food for animals.
How is my business going to cope?
Unless you are a canned pet food manufacturer and already subject to LACF (Low Acidic Canned Food) regulations chances are you’re going to need to comply with FSMA.
The higher standards that companies must now meet means that compliance is going to be a much more timely and cost focused procedure than it ever has been before. Without a doubt, the repercussions of compliance to the FSMA Preventative Controls for Animal Food rule are going to have significant effects throughout the entire supply chain and increase costs for everyone.
Not only might businesses need to re-conceptualize their production processes and facilities, they will have an extraordinary mountain of paperwork under which to do it. The added costs, time pressures, and volume of understanding required to comply effectively increase the stakes for each business.
FSMA has put a greater pressure on pet food manufacturers than there has been before.
The Preventive Controls start for large businesses this September
The Preventive Controls start for large businesses this September – smaller businesses still have another year or two to make the necessary changes. We are, however, only six months away from this deadline and yet so many businesses already are failing to adapt. It has never been more important for a business to stay ahead of the curve and it is impossible to do that manually.
How is Safefood 360° meeting the FSMA requirements for Pet Food?
The new regulations will have two impacts on the pet food industry
- Compliance with FSMA will cost a significant amount of money and energy
- FSMA will hold animal food to the same high standards as human food
We’ve tracked the Food Safety Modernization Act since its beginning. We’re already implementing Preventive Controls as part of our HACCP / HARPC system and are training clients regularly in how to apply it to their business. Similarly, we’ve benchmarked our Supplier Control solution for the new FSMA requirements. There will also be released a readymade template for your Food Defense plan and we’ve uploaded pet food related FSMA checklists to the system as well. So if you’re manufacturing pet food and need to comply with FSMA we’ve got your back.
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