Preventive controls plan for human and animal
We are a vegetable processor, raw to IQF. In our processing we have product waste, just like all companies. The waste product is donated to a local farmer for cattle and hogs. Does this mean we would have to have PC Plan for both - Human and Animal??
Thanks
Terri
Hi, tshupe;
Short end of the discussion is yes.
§ 117.95 - Holding and distribution of human food by-products for use as animal food.
(a) Human food by-products held for distribution as animal food without additional manufacturing or processing by the human food processor, as identified in § 507.12 of this chapter, must be held under conditions that will protect against contamination, including the following:
(1) Containers and equipment used to convey or hold human food by-products for use as animal food before distribution must be designed, constructed of appropriate material, cleaned as necessary, and maintained to protect against the contamination of human food by-products for use as animal food;
(2) Human food by-products for use as animal food held for distribution must be held in a way to protect against contamination from sources such as trash; and
(3) During holding, human food by-products for use as animal food must be accurately identified.
(b) Labeling that identifies the by-product by the common or usual name must be affixed to or accompany human food by-products for use as animal food when distributed.
© Shipping containers (e.g., totes, drums, and tubs) and bulk vehicles used to distribute human food by-products for use as animal food must be examined prior to use to protect against contamination of the human food by-products for use as animal food from the container or vehicle when the facility is responsible for transporting the human food by-products for use as animal food itself or arranges with a third party to transport the human food by-products for use as animal food.
[80 FR 56337, Sept. 17, 2015]
Not a separate plan needed just make sure to capture any controls (Process, Supplier, Allergen, Sanitation) required for that stream of the process. I wouldn't do a new plan, just make sure that stream to animal food is in our current plan.
I was just at an FSPCA course and asked that very question since we have, at times, our finished product going to animal food. The instructor told me, and it lines up with the regulation, to treat it like human food, but you don't need a separate plan. You just need to recognize the hazards and control them like anything else.
Our finished product (dried fruit) has exited a kill step and then ends up as animal feed (dry product from the floor, quality issues such as clumping). If we meet the two conditions in 507.12 because we are subject to human food regulations and we do not further manufacture or process the by-product are we only subjected to the 507.28 holding and distribution rule? I guess I am unclear about what is considered a by product. Our product on the floor could have debris or micro.