Food Waste as Animal Feed - What kind of label?
I work at a food manufacturing plant that produces a lot of food waste. We used to send our food waste as animal feed, but with the new regulations (117.95), we are unable to do so without labeling the containers with the ingredients. The problem is that our waste is a mixture of many different items that builds up over time, and labeling it accurately is not impossible. Does anyone know if it's okay to use a label that has all of the possible ingredients listed on it to cover everything? Or, what is the next best thing? We have been sending tons of food waste to the trash weekly due to this, which I really dislike, but I also don't want to break the law. Thank you
The requirement states: "(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."
I think that an auditor would be hard pressed to say that you DON'T meet this requirement if you put a label on each bin that said something like:
FOOD BY-PRODUCT
FOR ANIMAL FEED
CONTAINS: CHICKEN, PORK, BEEF
If this is meat related, why not ask your USDA inspector if they feel this satisfies the requirement.
The farm that gets our animal feed cannot take anything with meat, but we would send them everything else: mostly pasta products, cheeses, and rice. It was always a random mixture of things too, which is why it couldn't be labeled specifically with the ingredients in ascending order like regular products. My thought was to put a standard label on everything that says "May Contain: (list everything)..."
Do you currently deal with any animal feed items?
No. We sold potato starch for processing by other human food manufactures. It was literally a 4 x 4 label pre-printed with the words "POTATO STARCH" and then the operator would write in the weight with a black marker and write a BATCH NUMBER under it (Julian Date - 025 would be today, for example)
I think your standard label will suffice and would do that until someone challenges you on it to do something else.
Section 101.4 has some precedent for using the phrase "may contain one or more of the following" for various ingredients. Depending on just HOW varied your ingredient statement may be (it can't be ten paragraphs listing literally anything :) ), I would think this may be appropriate. Unfortunately it's probably going to come down to the individual opinions of the auditor.
It also looks like FDA defers to AAFCO for determining how feed ingredients should be named on labeling: https://www.fda.gov/...l/ucm074687.htm
Furthermore, human food by-products for use as animal food must be accurately identified during holding. (507.28(a)(3)). We recognize that a variety of systems are used by establishments to identify food within the plant, including labeling, computer systems, paper records, chalkboards, and other methods. Plant personnel should be able to accurately identify the human food by-products for use as animal food so that they are not contaminated, commingled, substituted, or incorrectly distributed in a manner that adulterates the animal food. C. Labeling (§ 507.28(b)) When the human food by-products for use as animal food are distributed, labeling that identifies the product by the common or usual name must be affixed to or accompany it. (§ 507.28(b)). Labeling could be included on the invoice or bill of lading, for example. Our Compliance Policy Guide Sec. 665.100 discusses common or usual names for animal food ingredients, including the use of the ingredient definitions in the AAFCO Official Publication. 6 There are also industry and other regulatory resources that may assist facilities in determining the common or usual name of the animal food,
Unfortunately it's behind a paywall, so you could look there but I'm not going to pay for you :)
You need to include every POSSIBLE ingredient and also label it "not for human consumption" the issue is that residues are being found in animals that previously didn't exist......this is an integral step in the food chain
I would make a standard label.......it's up to the production folks to track shrink during production
Do you have an agreement with the farmer as to what can and cannot be included?