SQF question , Your manufacturing waste,..Animal Feed

Does a food manufacturer have to declare, another "Food Sector Category" say #34 , if your by- product is going to a farmer or is used as an ingredient for animal feed?  However we do not make retail, wholesale, feed as part of our business.

I have worked for 2 companies that were under the SQF and or BRC unmbrella and undesirable powdered milk or wheat flour dough went to a company to blend to make animal feed.

I know that in the event ,......if you have a food recall, animal feed, would be included, in the recall.  

Can I get some information on this ?

Jeff :helpplease:

In the UK we are governed by the animal by product legislation, which has 3 categorys of disposal, depending on the status of the animal by product.

I'm not sure exactly, but I know that the new SQF Edition 7.1 has entire modules devoted to animal feed. I am not sure that your company sending an ingredient to another company would mean you need to jump into Module 3: Animal Feed or Module 4: Pet Food, but if they want to be certified then they may so request it of you.

Tadelong Thanks ,...Almost every food manufacturing company has a place to send their food waste , no one wants to send this (waste)  to a land fill.

My question is ; even though we do not directly intend to make animal food ,.... it is an ingredient for someone elses animal feed.

Do we need to comply with animal feed (GSFI) ... SQF,BRC,..... animal feed modules?

I'm to understand , only if the animal feed blender asks for some kind of safe food certification ?

:huh: ,  Don't want some auditor asking ,... wheres your safe animal feed program ? You do generate animal feed don't you ?

Could use some more help and clairification on this. Please.

Jeff

I work at a powdered milk plant that produces animal feed as a byproduct, and I recently witnessed the SQF of another plant within my company that also makes powdered milk with animal feed as a byproduct. That plant makes maybe 5 or so bags of animal feed per day and the auditor was perfectly okay with this - without any need to expand into another module. We explained that animal feed is basically trash to us that we can make a small amount of money on. He was certainly very interested in the process, but the fact that we shipped it without a COA, and with the bags saying not intended for human consumption seemed to satisfy all his questions. Additionally animal feed in both facilities is stored in a separate area from the salable product. I know that attitudes can change from auditor to auditor but it seems that many realize that byproducts are the nature of a manufacturing process and that it came out of the same system and is not sold directly for animal consumption.

I previously worked in a meat facility that was BRC certified. The inedible meat - it had touched the floor or had quality problems or what have you - went to a mink farm. I also know that BRC in that case was okay with that without needing to do anything extra with the "animal feed" we were sending out.

What SarahElwell said rings true with me. If you have any doubts, you should be able to ask your CB.

Setanta

My opionion - as we all know auditors come from different backgrounds and will ask different questions. And yes, some of their questions, or even their conclusions, may not be relevant to our operation.  I believe the better question to ask, rather than "how do I satisfy the auditor," is "can I adequately justify what I'm doing in light of both regulatory and food safety requirements?"

I believe that in this case, with regard to food safety programs,  since the waste product does not go directly to human consumption the responsibility for determining its suitability lies with the purchaser, or the cattle operation.  It is not the seller's responsibility to develop a risk analysis about what happens to the feed once it's sold to the cattleman, and whether that's a risk to humans.

it's very important to note, though, that there are some specific regulations in place regarding animal feed for animals in the human supply chain.  I'm not intimately familiar with them, but the seller should ask the buyer for some guidance on any related requirements that they need to know about, and do a little research.  Also keep in mind that the FSMA will make some changes to these requirements, so you'll want to stay abreast of any new legislation or drafts that come out in that regard.

Dear All,

It appears from the previous posts that the receivers of the “trash” had no necessity to monitor the safety characteristics (eg haccp-related) of their process inputs for animal feed production. I presume this means that they were not audited or certified (or licensed?) for such manufacturing activities. Is this a typical situation in the animal feed business ? Somehow I doubt it.

Usage for animal feed  is obviously not necessarily the end of any human or non-human potential for undesirable safety consequences. It is IMEX typical  that the specific supplier of an end-product  faces the primary investigation / responsibility  for any quality complaints, especially safety-related. But this may well not be the only fallout from  a contamination event.

Rgds / Charles.C

It appears from the previous posts that the receivers of the “trash” had no necessity to monitor the safety characteristics (eg haccp-related) of their process inputs for animal feed production. I presume this means that they were not audited or certified (or licensed?) for such manufacturing activities. Is this a typical situation in the animal feed business ? Somehow I doubt it.

In at least the case of the animal feed here it would typically go to a farmer who purchases it and mixes it into a feed formula himself. At least in this part of the country it is quite common for farmers, feed lot owners, etc. to make their own blend in house. In this case they would not be audited, they probably have no clue what HACCP is, and their feed bears no certification. Most of this "animal feed" is not going to go to Purina, for example, to be mixed into dog food or what have you. 

it's very important to note, though, that there are some specific regulations in place regarding animal feed for animals in the human supply chain.  I'm not intimately familiar with them, but the seller should ask the buyer for some guidance on any related requirements that they need to know about, and do a little research.  Also keep in mind that the FSMA will make some changes to these requirements, so you'll want to stay abreast of any new legislation or drafts that come out in that regard.

Many of the regulations detail that you cannot feed specific animal parts back to those animals, i.e. you cannot feed ground up spinal cord/brain back to a cow. These rules concerning animals in animals' food stem from the BSE prevention movements. I know that in pigs you can change their diet as you wish - you could put them on a diet solely consisting of corn silage and the animal would be okay, but the meat would be of really poor quality (soft bellies - junky bacon)  and so the grower would be discouraged from doing this due to the selling price that they would get for the animal. The other regulations with feed typically surround additives like antibiotics (and observing withdrawal periods), hormones, etc. A feed mixture ingredient is usually just tested for composition and then incorporated to meet their targets for the total blend concerning protein, fat, carbohydrate, vitamin, etc., content. 

I hope that helps to clear up the idea of what "animal feed" goes into and what kind of scrutiny the mixture that is made with it befalls.

Dear SarahElwell,
 

 

In this case they would not be audited, they probably have no clue what HACCP is, and their feed bears no certification. Most of this "animal feed" is not going to go to Purina, for example, to be mixed into dog food or what have you.

Interesting post, thks.  Perhaps unintended but your post(s) somewhat gave me the overall impression of a free-for-all.

It seems there very few legislatory restrictions on the use of waste materials for animal feed in USA. Or is it that they exist but are practically unenforceable ?

I recall another thread here (not USA) concerning the use of waste frying oil as an ingredient for animal feed. During my involvement with that thread I looked around the net a bit for info. Some of the ingredient-related articles on this topic were disturbing, to put it mildly.

So what determines whether waste material goes to Mr XYZ or a household name Brand ? Type of waste, "Quality" of waste, Breeding ? 

Rgds / Charles.C

PS -  apologies to OP, getting a bit :off_topic:

I think that there may need to be a level of differentiation made here.

Is what you are sending this group turned into actual animal feed or is it fed to animals.

If it is an ingredient in animal feed (like the bags you buy at Walmart) then I agree that while you may not NEED to legally be certified to send it to the feed manufacturer they may request you become certified.

If it is being used as food for animals (a farms pigs or whatever) then I'm not sure it matters at all.

If it's being used for "Animal Feed" (one you buy for an animal at a store in a bag) can it harm the food sector?  If it is a dried ingredient that has a low water activity then the risk of bacterial adulteration is low.  Your probably looking more at physical contamination right? (I've worked in Pasta but not dried milk... I've worked in dairy too but not dried dairy).  If they control their own physical hazards then I think you should be ok.  

If it's being used to feed his own pigs then I guess it's on him if he doesn't care.  His pigs may die from salmonella... his fault.  (This is mostly a guess I don't know if there is transference form pig to plate if the pig is sick... But that's why we are told to cook our food right?)

Dear All,

To answer my own legislative query and add a little context, this link in USA perhaps -

http://www.fda.gov/A...eds/default.htm

Whether this is relevant to, or even includes specific responsibilities upon, the supplier i wouldn't know ? Perhaps a little "waste" for thought for the OP ?

I haven't delved into the SQF standard to check but IMEX all FS standards put legislatory requirements at the head of their compliance list.

I can easily believe that uncontrolled waste disposal is occurring. Unfortunately, that does not represent a FS justification to my mind.?

Surely the Big Picture is that we are talking about a Food Chain / Web here, Ecology 101 ? :smile:

@MerleW 

If it's being used for "Animal Feed" (one you buy for an animal at a store in a bag) can it harm the food sector?  If it is a dried ingredient that has a low water activity then the risk of bacterial adulteration is low.

Unfortunately, this is somewhat of a misconception. It is necessary to differentiate between survival and growth.

For example -

Salmonella survival in broiler feed.pdf   822.89KB   11 downloads

Survival Pathogens in Low aw environments , Campden.pdf   130.7KB   10 downloads

Rgds / Charles.C