Food by-product for animal feed

We sell grape pomace to brokers. Some of this pomace goes to the animal feed market and some becomes compost. Our facility is FSSC certified. The pomace is only listed in our process maps as waste. (I was told it only went to compost). Do we need to comply with FSMA preventive controls for animal food?

I believe so.  Tractability will most likely be the greatest challenge.  Waste doesn't need to be, animal feed would need to be.  

I'm not very familiar with this animal rule, as we're exempt from it (farm), but these might help get you started: https://www.fda.gov/.../93897/download and https://www.fda.gov/...Animal-Food.pdf.

 

In the guidance, they indicate that as long as you are meeting the PC rule, you should be fine, seeing as you sell the product to someone else who is then using it for animal feed.  You might need to account for it in your hazard analysis and ensure that it is being treated correctly while in your hands (as it were), but it appears that your buyer(s) have the primary responsibility, not you.  

 

The Transportation rule applies to animal food as well.  That much I remember from my training.

 

Hopefully someone more familiar with this rule will add/correct as needed.

 

Good luck,

Todd

Yes.

If you are not processing the animal food but only holding the scraps until they are picked up by someone else, then you just need to comply with your normal GMPs and make sure that the animal feed materials are kept in clean and properly marked containers. They should also be kept cold if necessary to prevent bacterial growth.