2 replies to this topic

[Jinnosuke]

I work for a bakery that produces Pancakes and Waffles. The process typically has several misshaped or broken product that we are currently storing and giving to a local farmer for use as animal feed.

 

Under CFR Title 21 507.28 it mentions protecting against adulteration by trash, contaminants and I'm having a bit of confusion around products that had fallen on the floor.

 

For human food we do not ship any product that has come into contact with the floor.

Should this policy extend to food that we would send to our local farmer as well? I couldn't find specifics in the code detailing this and we'd like to not fill landfills if we don't have to discard the product.

 

 

My general thinking is that food for animal consumption should follow the same safety precautions that we have in place for human food.

 

See code below:

https://www.ecfr.gov...#se21.6.507_128

[mohamed ahmed yusuf]

Dear Jinnosuke,

As i read from the link that you attached , all their concern is about:

1. Microbial load .

2. Adulteration.

When you have a case of falling down food on the floor , what is the possibility of having increased microbial load or Adulteration ? i think the answer will be none of these will happen. 

but cause floor could be somehow have dust or it is a walking area you don't give these food to people and turn it to animal.

In my opinion , mentioning the reason of turning food from people intake to animal intake which is (fall on the floor) will be enough.

also another solution try to put a limit for the food that fall on the floor , try to fix that error or the leakage that make this mishandling happened.

[QA-Tech]

I think your original thinking is correct, animal food should follow the same basic safety measures as human food and food falling onto the floor would be considered adulterated. However, in the guidance document for 507.28 section VII, it states that:

 

"Human food that has been rejected for human food safety reasons should be evaluated by establishment management to determine whether it is appropriate to divert to animal food" 

 

In order to send any adulterated product to the farm, you would need to prove that it will not pose a food safety risk to the animals. 

 

I would do some reading through the guidance documents:

 

 

https://www.fda.gov/downloads/AnimalVeterinary/GuidanceComplianceEnforcement/GuidanceforIndustry/UCM499201.pdf

 

https://www.fda.gov/...l/ucm074694.htm

 

 

https://www.fda.gov/...y/UCM499201.pdf