Human food facility to make pet food

Hello!

We are a human food processing facility and plan to begin producing pet treats using our existing human-grade ingredients. I have no prior experience in animal food production, so I’d appreciate your guidance.

Aside from FDA and state registration, are there additional requirements we need to meet?

Specifically:

Do we need to follow a separate Hazard Analysis and Risk-Based Preventive Controls plan for animal food under 21 CFR Part 507, or Can we update our existing food safety plan under 21 CFR Part 117 to include pet treats?

Also- Do I need to obtain HACCP training and PCQI training for animal food? 

Looking forward to your advice on how best to proceed.

For training there are the usual vague requirements that someone responsible for writing the program be experienced or otherwise competent.  I would recommend doing a formal PCQI training though, just to cover some of the wheel-reinventing language differences.

The entire food safety plan likely wont need to be rewritten, but there are some expectations and terminology differences, so I'd recommend having a separate set of documents for the pet/FDA plan for some items.  If your current products and programs are USDA, you don't need to give them extra material to poke around in.