It seems that the pet food industry is gearing up to meet the requirements of newly passed Food Safety Modernization Act. Here’s what some in the pet food industry are saying about the required Hazard Analysis and Critical Control Point (HACCP).
“HACCP is a management system in which food safety is addressed through the analysis and control of biological, chemical, and physical hazards from raw material production, procurement and handling, to manufacturing, distribution and consumption of the finished product.”
http://www.fda.gov/food/foodsafety/hazardanalysiscriticalcontrolpointshaccp/default.htm
From PetFoodIndustry.com “Still, passage had seemed nearly inevitable, and all along the bill has generated quite a bit of praise but also criticism. Even proponents are expressing concern about what the nitty-gritty details will look like once regulators start working with it.
This concern spreads to pet food. In fact, many people in our industry have already been voicing real and legitimate apprehension about what the new law will mean for pet food manufacturers, especially smaller companies that don’t have the resources or economy of scale to absorb the higher costs of meeting new regulations.”
In the October, 2010 pet food industry publication Extru-Technician (an extrusion – form of pet food pellet/kibble manufacturing – publication), an article provides manufactures details to setting up their HACCP plan. http://viewer.zmags.com/publication/9dadb978#/9dadb978/1
(bold added)
“7 principles of HACCP”
“Whether you call them steps or principles, the key components should be the same for every HACCP plan:
1. Analyze the process for potential hazards
1. List all potential hazards.
2. Evaluate all potential hazards for severity and likelihood of occurrence.
3. Determine if each hazard needs to be addressed in the HACCP plan.
2. Indentify critical control points (CCPs)
If deemed significant – passing all the criteria specified in step 1 – a hazard must be controlled by a CCP. The point in a process that is the last step at which a control measure can be applied and that is essential to prevent or eliminate a specific food safety hazard or reduce it to an acceptable level is the CCP for that hazard or process.
3. Establish a critical limit for each CCP
What is the operation reference point that guarantees the hazard has been identified and killed or removed from the process? That is a critical limit: the maximum and/or minimum value to which a biological, chemical or physical parameter must be controlled.
4. Establish CCP monitoring procedures
The only way to ensure CCPs are working is to constantly monitor them. Loss of control must be identified as soon as possible. Be sure your procedures include the “four W’s plus H”; who, what, when, where and how to monitor.
5. Develop corrective actions
What do you do if an issue arises – a CCP falls out of control? As mentioned on page 4, petfood safety is not yet regulated in the US; but any rules put into place by the Food and Drug Administration (FDA) will likely follow human food regulations.
6. Establish verification procedures
These are activities other than monitoring that determine the validity of the HACCP plan and verify that the system is operating. The procedures should include short-term and long-term measures, such as audits.
7. Develop recordkeeping procedures
This is fairly straightforward: You need written documentation that the HACCP plan is being carried out. The documentation should include all activities and discussions that have occurred during the first six steps and all ongoing activities and decisions within the HACCP plan.”
“Be proactive
Again, it is important to remember that currently there is no legislation for safety in the petfood processing industry. FDA simply states now that petfood suppliers must produce Salmonella-free products.
If FDA puts petfood rules in place, it will most likely copy the protocols set up for the human food industry. For example, with food, all CCPs must be tested and verified by a thir-party laboratory, outside the production facility. While the samples are being tested by this third party, the product cannot be distributed or sold. Think of the warehousing and logistic challenges that can arise.
It is up to petfood producers to develop their own strategy or system. If they don’t FDA most certainly will.”
Several things from the above that MUST be noted…
For starters, the thought that many pet food manufacturers have not had an existing Hazard Analysis and Critical Control Point plan in place is a bit frightening. From conversations with numerous pet food manufacturers – I know many have long ago established and follow hazard control systems (some from their very beginning). However, the thought that Hazard Analysis has only been optional up until this new legislation is ridiculous.
Next, I cannot count the times that the pet food industry has claimed ‘they are the most regulated food industry’. From the Pet Food Institute website, under Consumers/Regulation of Pet Food…
“Pet food products are among the most highly regulated products in grocery stores.” Yet here, in an industry publication it states “petfood safety is not yet regulated in the US” and “Again, it is important to remember that currently there is no legislation for safety in the petfood processing industry. FDA simply states now that petfood suppliers must produce Salmonella-free products.” While it is shocking to see the truth in print (pet food safety is not regulated in the US), it is nice to see an industry publication to publically admit the truth. And further, give industry some advice on how to produce safer products.
And finally, having the bad attitude about this industry that I have, I have to wonder if industry lobbyists (the Pet Food Institute) will pressure the FDA into delaying or even excluding the pet food industry from the Food Safety Modernization Act requirements. Will the FDA/CVM cave (again) to lobbyists or will the FDA/CVM finally hold the pet food industry to the same safety standards that human food producers must follow?
Wishing you and your pet(s) the best,
Susan Thixton
Pet Food Safety Advocate
Author, Buyer Beware
Co-Author Dinner PAWsible
TruthaboutPetFood.com
PetsumerReport.com
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