Can we have animal feed in a food manufacturer?

Hello everyone!

So my company does Human food (herbs, spices, candies...etc)

They want to repack Canary seeds (adding a disclosure "not for human consumption") so it is Animal feed technically. 

The question: CAN WE? Can we have animal feed in a Human food facility?

I remember working at a bakery that did Dog treats....

I am not sure. The previous manager before me said no not allowed because it is animal food and not human and should not be done here and I see why.

Anyone guide me on it from a regulatory standpoint?

We are SQF. 

Thanks!

I am seeing that Canary seeds can be used for human consumption but in the past people have fallen ill from eating them so I believe that is why they will be disclosed as not for human consumption. 

You can do that - but need to open up another food sector category, adding to your scope, etc.

Having been in a number of dog food, bird food, etc factories there will be a bit of preventative messures for sam, ec, etc./ cross contamination.

Your CB may require an on-site inspection and review of document changes and additionals.

Yes, absolutely. I do it now. What you need to focus on is contamination of one from the other. And that is going to vary by products.

I'm lucky in that our FCC grade is produced exactly like the feed grade, so the chance one can contaminate the other is extremely low (we still run the products in order of USP, FCC, Feed just because all the earlier in a run the more 'pure' it is).

You can do that - but need to open up another food sector category, adding to your scope, etc.

 

Having been in a number of dog food, bird food, etc factories there will be a bit of preventative messures for sam, ec, etc./ cross contamination.

 

Your CB may require an on-site inspection and review of document changes and additionals.

Besides adding an additional category, that's it I suppose? 

Of-course other additional methods of Preventive controls and adding it to my HACCP plan.

Does anyone have a document showing it is allowed to be used with human food to show senior management? Like regulatory or something

I don't think there is an actual "you can store them in the same facility" statement but it sets a precedent discussing how manufacturers who are already following FSMA for human food have options. https://www.fda.gov/...ols-animal-food

You will also need to have a PCQI for animal food, as per FSMA regulations (the animal food regulations also address hazards such as excessive levels of different nutrients that impact the health of the target animal consumer). You can use the same human food sanitation controls for your canary seed operation, or if you have sufficient segregation you can apply the animal food sanitation controls to that area.