10 replies to this topic

[rmak]

Hello,

 

I work in a California food processing facility. We are exploring using human grade ingredients to product pet treats. I am not sure if this is allowed to do so. My higher ups are pushing me to look into regulation and not giving me enough time... I am reaching out to see if anyone can provide insights on this topic. 

[MOHAMMED ZAMEERUDDIN]

The process area & machines should be completely separate from Human food process area & machines. If this separation is assured then same premises can be used for manufacturing both the products.

[Alexis M]

We did this once. We were a beverage and sauce facility and ended up making some type of Liquid CBD for dog joints and let me just say it was a NIGHTMARE to clean all the equipment. The stuff just coated our liquefier and lines so we never made it again after that. I am not sure as to what went into being able to do it as I was not quality at the time but I do know we used all human grade ingredients and that's why it was considered acceptable to produce in our food equipment.  Next day we were back to producing food in the same equipment after a quick ATP swab 

Edited by Alexis M, 25 October 2023 - 10:54 AM.

[rmak]

The process area & machines should be completely separate from Human food process area & machines. If this separation is assured then same premises can be used for manufacturing both the products.

Hello Mohammed Zameeruddin,

 

What if we are using human grade ingredients and label as human grade dog treats? Our goal is to use our current ingredients, process and machines to produce an item that suitable for human and pet. 

[rmak]

We did this once. We were a beverage and sauce facility and ended up making some type of Liquid CBD for dog joints and let me just say it was a NIGHTMARE to clean all the equipment. The stuff just coated our liquefier and lines so we never made it again after that. I am not sure as to what went into being able to do it as I was not quality at the time but I do know we used all human grade ingredients and that's why it was considered acceptable to produce in our food equipment.  Next day we were back to producing food in the same equipment after a quick ATP swab 

Hello Alexis,

 

Thank you for your feedback! I think CBD itself is a thick material, it probably requires a special way for sanitation. 

[Scampi]

Hello Alexis,

 

Thank you for your feedback! I think CBD itself is a thick material, it probably requires a special way for sanitation. 

CBD requires an alcohol flush and/or extremely hot water flush

 

To your question---if the pet food uses EXCLUSIVLY human grade ingredients only AND the production is done on a separate day with a sanitation shift between, there should be no reason you cannot do this PROVIDED the hazards are IDENTICAL, so you need to perform a separate RA and formulate a new HACCP plan for pet feed production

[G M]

Hello,

 

I work in a California food processing facility. We are exploring using human grade ingredients to product pet treats. I am not sure if this is allowed to do so. My higher ups are pushing me to look into regulation and not giving me enough time... I am reaching out to see if anyone can provide insights on this topic. 

 

Probably.  You don't mention which agency has jurisdiction over either product, but it is allowed by USDA:

 

https://www.fsis.usd...rectives/6300.1

 

It is likely to come down to segregation and sanitation.

[Miss Frankie]

We make pet treats at our facility with no problem. 
Our main product is smoked salmon for humans. We keep hold onto small pieces that doesn't meet size requirements, or there wasn't quite enough of something to make a full package. That gets packaged for pet treats.  (My dogs LOVE it)

So, while it is considered pet food, it's basically leftovers so our process doesn't really change.

[jfrey123]

I've done pet food in my spice/dehydrated vegetable plant way back at my first QA job.  It was a dried mix of some vegetables with diced apple being the only different ingredient.  We had COA's from the ingredient suppliers that the ingredients were essentially human grade, and it wasn't a far enough deviation from our standard HACCP plan to need a new plan.  Admittedly, as this was a third party tolling operation (we owned none of the raw ingredients and were processing/packaging on behalf of contracted customers), our HACCP plan was more focused on the equipment instead of the ingredients as a whole.

 

But I'm chiming in to echo the others above:  you can do it so long as either your current RA fits the profile of the ingredients, or a new HACCP plan covers the process.  It's been awhile since I was involved in this, but I do remember some requirements being a bit more stringent for pathogen control.  This was circa 2015 for me, but after some of the pet food salmonella issues in the mid 2000's, there was quite a bit of scrutiny on ingredients at that time.  We would joke that our pet food contracts had better paperwork than our spice customers because of this lol.

[mgourley]

We make (among other things) cookies for both humans and canines.

The dog cookies are just basically human cookies with reduced sugar and some use carob chips instead of chocolate chips.

 

Zero issues with BRCGS or the FDA, as long as you are not adding vitamins or other "enhancements".

 

You will have to have a PCQI for animal food and more than likely conduct finished product micro testing.

 

Marshall

[MOHAMMED ZAMEERUDDIN]

If human grade ingredients then no issue. You can manufacture on same production line.