The thing I value most about teaching the FSPCA Preventive Controls for Animal Food course is what I learn from participants. In the most recent class I was privileged to have two students from an international third party certification company. During discussions on Receiving cGMP’s and the Sanitary Transportation of Animal Food, the inevitable questions on what are acceptable clean out protocols for materials previously hauled and what is strictly prohibited. The student referred us here:
International Database Transport for Feed
On this website you can search a description of a material and it will return the required clean out protocol. On the surface this sounds easy! Beware and read on for the proper interpretation of the data. This database is a collaboration of eight internationally recognized certification programs. Sometimes they have different rules within the certification. Here are some examples:
- A search for “Medicated” returns “Medicated Feed”
Minimum Cleaning says “List of differences, please consult important requirements”. This means that there are different rules for different certifications. Click on “Medicated Feed” and the following is returned:
All certifications classify the required cleanout as “A” except one, which requires “C”. We will get to the definition of “A” and “C” in a minute…
- A search for “Fertilizer” returns two choices.
I selected “Organic fertilizer…” and the following was returned:
All certification bodies forbid the hauling of organic fertilizer prior to hauling animal feed and there is no acceptable cleanout protocol.
- I searched “Glass” and then further drilled down to “Glass from a bottle bank intended for recycling, unwashed.” This again provides different protocols for different certifications. Two forbid it and the rest require protocol “D”.
So what is the definition of “A”, “B”, “C” and “D”? There is a document that defines Requirements for transport sequence, cleaning and disinfection.
In a nutshell:
A. Dry cleaning
B. Cleaning with water
C. Cleaning with water and a cleansing agent
D. Disinfection after one of the previous cleaning regimes (A, B or C)
The document further describes these methods. A second document describes the “acceptable proof” of clean out. These stringent requirements are above and beyond the requirement for cGMP’s. A wash out certificate or a statement by the driver that it was done may be all you need.
So what does this mean for FSMA?
FSMA does not require you to be certified by any third party standard. But this can be a useful tool that you reference in setting up your requirements in your Standard Operating procedures (SOP’s). This can be included in your justification for mitigating hazards in receiving contaminated ingredients and shipping finished feeds. Use it as a resource in the development of your SOPs , cGMPs and your Food Safety Plan.