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Supply Chain Applied Controls for Animal Feed


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#1 bmart

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Posted 19 June 2018 - 07:01 PM

Hi All,

 

Have a question in regards to supply chain applied controls for animal feed and hope to get some input from the community. We are a dry blending facility and sometimes we use a dry dairy protein in our product, for instance dry skim milk. 

 

Now we will just blend this raw material with other raw materials from other suppliers. This will then be bagged and shipped to customers. We do not heat treat this product nor do our customers.

 

To me, there is a big risk associated with Salmonella contamination from the dry milk product (i.e. sever illness can occur, likelihood is high). The high risk assessment is mainly due to the fact that we are not controlling the hazard in the facility by heat treatment.

 

In my opinion we should have supply chain applied controls for this product because of the high risk and since we do not control it.My question is does this seem reasonable or is it an over reaction? Also, does anybody have an example of a process and raw material where a supply chain control is implemented? I can't find a lot of examples online of raw materials where people implement a supply chain applied control. 

 

Thanks for the help



#2 Scampi

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Posted 20 June 2018 - 01:10 PM

You will know better than I, but a quick search of cattle getting ill from salmonella speaks specifically to their own feces and bird excrement in and around the cattle

 

How would a supply chain control help this when there still wouldn't be a kill step?

 

http://www.thecattle...ontrol-in-feed/

 

This article may be of some assistance


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#3 bmart

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Posted 20 June 2018 - 02:49 PM

Thanks for the link, that was an interesting read. There is a lot of evidence, including in the link, that says that salmonella comes from animal feed. Additionally, we are concerned with the humans being exposed to the Salmonella when they are mixing the feed which is another reason why we believe that there is a large risk associated with Salmonella in the feed.

 

My understanding of the Supply-chain control is that the point of it is to be in place when there is no kill step at your facility.

 

We are completely reliant on the raw material supplier that they are controlling the hazard because we do not control it. The supply-chain program will then be our verification step (3rd party audit request or 2nd party audit) for the control of the hazard (salmonella).



#4 Scampi

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Posted 20 June 2018 - 03:16 PM

Ok, but I'm still confused how the hazard will be mitigated without a kill step?

 

So does that mean you will not accept anything above a none detected for salmonella?  It just sounds like no one is controlling the hazard so you don't have a supply chain applied control otherwise, please do correct me if i'm wrong on this one

 

http://www.feedhaccp...ramFSMA2016.pdf


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#5 bmart

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Posted 20 June 2018 - 03:47 PM

I'll try to provide a more thorough example:

 

We receive a dried milk product from a supplier/manufacturer of this product.

 

They produce the product by receiving raw milk, pasteurizing it, then drying it. At the pasteurization (kill) step in this process they, the supplier/manufacturer, is controlling the pathogen hazard associated with the product. 

 

The product we receive from the the producer then gets dry blended at our facility, bagged, then sent to our customers. So we are reliant that our supplier/manufacturer is controlling the hazard because we do nothing to the material aside from blend it with other powders and package it.

 

As I write this I just realized that as long as we have a thorough Vendor Approval process we probably don't need a supply-chain program. As long as we believe that our approved vendor is adhering to a food safety program, etc.

 

Yes, we will not accept anything above a none detected for salmonella. I think the new FSMA policies are saying that maybe the CofA stating that none detected of salmonella is not enough, i'm not quite sure.

 

I'm still trying to figure all this out myself so any suggestions are appreciated.

 

I have found an example of a supply chain program from the FSPCA for pecans. The hazard requiring a supply chain applied control is for pathogens, salmonella. The PC applied by the supplier is roast pecans to inactivate vegetative pathogens. This is verified by a 3rd party audit and a copy of this sent is requested on an annual basis.



#6 Scampi

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Posted 20 June 2018 - 03:55 PM

I understand completely now, no in human food, that would just be part of that suppliers approval and I would not accept a lot that was above "none detected" and have a record of each incoming lot!

 

Voila, you've solved your own issue!!!


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#7 Ryan H.

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Posted 23 August 2018 - 01:01 PM

bmart: I believe you have everything you need, however just be sure to collect all of the documentation from your supplier and add the supply-chain PC to your hazard analysis. 


All the best, 

 

Ryan Heavner 





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