4 replies to this topic

[meowmeowcat]

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.

 

[G M]

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.

[jfrey123]

Last time I touched a pet food thing was at a spice 3PL who decided to blend and pack some dried ingredients that were intended for dog food, and it was before FSMA.  It was after the huge salmonella issue back in the mid-2000's though, so the company using us was very stringent about our safe handling of the ingredients they provided.

 

Under the newer regs, I'd probably want to make a second plan covering it as pet food instead of human food vs adding a pet treat to your current plan.  You can likely copy your existing HACCP and make the correct references to the pet food code.

[meowmeowcat]

Thank you for your insight! I begin looking at animal food PCQI training. I am unsure if there are any difference compared to human food. 

Last time I touched a pet food thing was at a spice 3PL who decided to blend and pack some dried ingredients that were intended for dog food, and it was before FSMA.  It was after the huge salmonella issue back in the mid-2000's though, so the company using us was very stringent about our safe handling of the ingredients they provided.

 

Under the newer regs, I'd probably want to make a second plan covering it as pet food instead of human food vs adding a pet treat to your current plan.  You can likely copy your existing HACCP and make the correct references to the pet food code.

[TimG]

Thank you for your insight! I begin looking at animal food PCQI training. I am unsure if there are any difference compared to human food. 

There are some, very few. I ran quality in a facility that did USP, food, and feed. I was PCQI trained in food, and my assistant in animal/pet. I can't honestly remember any auditor ever questioning if we had both, only that one of us had PCQI training.

The one difference I recall offhand was because it applied to my facility. Animal feed/pet foods specifically have a section in the PCQI training where they discuss storage of F/G's in open air bulk, and there are risk analysis involved in allowing it.

I skimmed her whole training book, and almost everything else was word for word the same as my human food book.