Legal Briefs

Process Controls are Coming; Are You Ready?

By Gina Valeri Director of Legislative Affairs & General Council, APPMA

Gina Valeri
Director of Legislative Affairs & General Council, APPMA

Many animal feed manufacturers mistakenly believe that process control systems are reserved for the human food sector because they are intended to protect humans and the environment. However, regulators are discussing ways of mandating process controls, particularly in the pet food category because they believe that hazards associated with pet foods have the potential of harming not only humans and the environment but animals too. In fact, officials from the Centers for Disease Control and the US Food and Drug Administration (FDA) cite the fact that pet food is brought into the home, often the kitchen where food is prepared, and often children come into direct contact with it, as reasons that mandate process controls in the manufacturing, distribution and handling of these products.

Manufacturers have a wide range of process controls to choose from including current Good Manufacturing Procedures (cGMPs) to participation in an independentlyaudited Hazard Analysis and Critical Control Point program (HACCP), the gold standard in the human food industry. Those manufacturers who have not yet implemented such measures should consider doing so soon because there are several regulatory groups that are moving forward with plans to make varying levels of quality control mandatory for the entire animal feed industry including pet food, treats, and supplements.

Moreover, with the recent reports of food borne diseases in both humans and pets being traced to pet food and treats, regulators are more compelled to implement standards to reduce these incidents. As late as June, FDA worked with a pet treat distributor in a recall requiring the entire shipped inventory of the company to be recalled after five people fell ill due to Salmonella infection.

While no rules have been put in place to date, FDA and the Association of American Feed Control Officials have been working in tandem on quality control regulations to promote feed safety. FDA's Animal Feed Safety System has been open to public discussion through two meetings in the last year and a half. In April, FDA invited industry and other stakeholders to discuss a proposed risk management component to the program. In addition, one of the key topics at the upcoming AAFCO meeting is process control regulations at the state level. If you wish to learn more about quality control measures currently being used in the food industry, access the APPMA Website on the Products & the Law page and click on "Feed Manufacturing Process Controls."

If you would like more information, please contact Gina Valeri, APPMA’s Director of Legislative Affairs & General Counsel by e-mail at gina@appma.org or by phone at 203.532.3600.