Animal Feed: Environmental Monitoring

Hi All, have a question pertaining to environmental monitoring in animal feed. This does not include pet food; specifically, feed for livestock animals fed on farms.

I've been trying to determine what, if any, environmental testing I need at my facility. From what I've read in the FDA regulations, 21CFR507, an environmental pathogen assessment must be performed per 507.33.C.2 as part of the hazard analysis. If deemed necessary, based on the hazard analysis, then a facility may need to implement an environmental monitoring program. 

I work in a wet blend and dry blend facility that produces feed for cows, so there are some significant risks for harborage sites. 

What I am wondering is if any you out there working in animal feed have implemented an environmental monitoring program. If so, what are you testing for? E. coli? Salmonella?

Thanks for the help!

 

 

c)(1) The hazard analysis must include an evaluation of the hazards identified in paragraph (b) of this section to assess the severity of the illness or injury to humans or animals if the hazard were to occur and the probability that the hazard will occur in the absence of preventive controls.

Environmental pathogens from feed manufacturing aren't typically a hazard to non-companion animals.  It's documented that livestock and poultry are actually natural carriers of a lot of these pathogens. 

So my hazard analysis is:

Hazard likelihood (likelihood that feed would be the source of a pathogenic infection): low.  (backed up with lack of recalls/reports of illnesses in livestock feed) 

Severity of the hazard (likelihood that a pathogenic infection in a livestock/poultry herd would be life-threatening): low.

We are mostly dry/pelleting and do not have an environmental monitoring program.  The majority of recalls are for companion pet food for the simple reason that infected companion animals and contaminated pet food are far more likely to transmit an infection to humans.

@ Ms. Mars - Do you have any resources you could share regarding livestock or non-companion animals carrying those pathogens? 

Without digging out my thesis notes, a quick Google Scholar search....

https://www.frontier...2017.02214/full

https://www.scienced...3X15010307#bib5

https://academic.oup...5/6/960/1608199

Thanks! I was just wondering what types of validation you used and I greatly appreciate your insight here! 

Considering the information provided above, if your likelihood and severity are both low to none, with the supporting documentation and information supporting it, you might be able to request an exemption from an EMP all together. No harm in trying, just send it to your CB tech director and see what happens.

Thanks for the info Ms. Mars!

One other thing I've found is the 'Compliance Policy Guide Sec. 690.800 Salmonella in Food for Animals'. This suggested guidance outlines the different types of Salmonella serotypes that pose a risk to different species. Looking at specific Salmonella serotypes, there may be a high severity associated with specific species. I guess now one can assess the likelihood that the contamination comes from the environment. 

I agree with the recall situation. The ones that I have seen pertaining to livestock have been due to a supplier issue. 

Considering the information provided above, if your likelihood and severity are both low to none, with the supporting documentation and information supporting it, you might be able to request an exemption from an EMP all together. No harm in trying, just send it to your CB tech director and see what happens.

I think OP refers to federal compliance and not a third-party certification.  Language in the regulation implies that EMP is only required if significant risk is identified through the hazard analysis.

Thanks for the info Ms. Mars!

 

One other thing I've found is the 'Compliance Policy Guide Sec. 690.800 Salmonella in Food for Animals'. This suggested guidance outlines the different types of Salmonella serotypes that pose a risk to different species. Looking at specific Salmonella serotypes, there may be a high severity associated with specific species. I guess now one can assess the likelihood that the contamination comes from the environment. 

 

I agree with the recall situation. The ones that I have seen pertaining to livestock have been due to a supplier issue. 

I would say that contamination would most likely come from an ingredient, though.  We regularly test ingredients with animal origin for Salmonella. I guess if you had an ongoing Salmonella issue in your product, an environmental study wouldn't hurt.