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Promotional Give aways - foreign object?


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#1 pgov

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Posted 01 March 2018 - 10:22 AM

Hi, 

 

My company (pet manufacturing) wants to include tennis balls (will go into a food grade plastic and then into the pouch) + tokens (5cm in size) 

 

My concern is, is this regarded as a foreign object especially as this is dog food and content is generally just poured.

 

what legally should be declared, what should be considered (we are doing a  risk assessment) 

 

Thank you 



#2 jcieslowski

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Posted 04 March 2018 - 03:15 PM

I don't work in pet food so I certainly don't have anything like an official answer.  I personally feel 'ok' about the tennis ball, but definitely not about the tokens.   The FDA does have defect action levels for foreign object that are expected to be in food:

 
a. The product contains a hard or sharp foreign object that measures 7 mm to 25 mm, in length.
and
b. The product is ready-to-eat, or according to instructions or other guidance or requirements, it requires only minimal preparation steps, e.g., heating, that would not eliminate, invalidate, or neutralize the hazard prior to consumption.
Samples found to contain foreign objects that meet criteria a. and b., above should be considered adulterated within the meaning of 21 U.S.C. 342(a)(1).
The following represent the criteria for recommending legal action to CFSAN Office of *Compliance, Division of Enforcement* (HFS-605).
c. The product contains a hard or sharp foreign object that measures 7 mm to 25 mm in length, and the product requires additional preparation or processing that may have an effect on the presence of the foreign objects in the finished food. For example, additional sifting of a product may or may not remove foreign objects, depending on the measurements of the objects and the mesh aperture of the sifter. In these situations, the preparation or processing of the food must be described in the recommendation submitted by the appropriate *office within the Human and Animal Food Program*.
or
d. The product contains a hard or sharp foreign object less than 7 mm in length and if a special-risk group, as defined in the background section, is among the intended consumers of the product.
or
e. The product contains a hard or sharp foreign object over 25 mm in length.
 
 
Not much, but could be a start.  


#3 FurFarmandFork

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Posted 05 March 2018 - 12:22 AM

Very much has to do with the laws of the country you're selling in.

 

If you end up selling under FDA jusrisdiction, they have some guidance on "trinkets" in confectioneries that they extend to other foods.

 

https://www.fda.gov/...3SLYWLiBcEigw==


Austin Bouck
Owner/Consultant at Fur, Farm, and Fork.
Consulting for companies needing effective, lean food safety systems and solutions.

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