FSMA and the pet food industry

Requirements within the Food Safety Modernization Act (FSMA) are intended to establish good manufacturing practices for all animal feed, while also establishing hazard analyses and risk-based preventive controls for the pet food industry.

The facilities covered by FSMA include most facilities that manufacture, process, pack or hold animal food, including those in the U.S. and those in other countries that export pet food into the U.S. The only exceptions are for small businesses (“small” is still being defined) and for businesses where the average over the last three years of food sales is less than $500,000 per year, and sales to other exempted users exceed sales to non-exempt users.

Because the legislation is complex, what follows are answers to frequently asked questions concerning the impact of FSMA on the pet food industry.

These questions and answers were adapted with permission from the American Feed Industry Association.

Q: What animal food products are covered in FSMA?

A:  All pet food, co-products from human food, ingredients and livestock feed.

Q: What are the differences between human food current good manufacturing practices (cGMPS) and animal food cGMPs?

A: For the animal food cGMPS, allergens have been removed. The context is the same, with some changes in definition.

Q: True or false, must a hazard analysis consider hazards that may occur naturally, or may be unintentionally introduced?

A: True.

Q: What does the proposed rule define as forms of a “chemical hazard”?

A: Forms of a chemical hazard include pesticides, drug residues, natural toxins, decomposition, unapproved food additives (e.g., pea protein), color additives, and nutrient imbalances.

Q: What does the proposed rule state that is necessary to meet personnel hygiene requirements?

A: Sick employees cannot handle feed/pet food, employees must maintain adequate cleanliness, and must use hand washing facilities before entering production.

Q: How is training conducted to qualify a person in FSMA compliance?

A: Training can be through a course FDA is putting together, or through job experience in developing and implementing a food safety program.

Q: What does the proposed rule state that is necessary in a food safety plan?

A: The rule states a food safety plan must include hazard analysis, preventive controls, a recall plan, procedures and frequency of monitoring preventive controls, corrective action procedures, and verification procedures and frequency.

Q: Are small businesses exempt from cGMP requirements?

A: No.

Q: When will the FSMA requirements for the pet food industry go into effect?

A: The requirements are effective 60 days after publication of the Final Rule; the Final Rule must be issued by June 30, 2015. The pet food industry’s compliance dates depend on the size of the facility: for large facilities, the compliance date is 12 months after publication of the Final Rule; for small facilities, it is two years after publication; and for very small facilities, it is three years after publication.