Do you know for sure?

Do you know for sure that your sequencing and flush procedures for medications work? How do you prove it? Many tell me… “it must work because I have never had a problem”… Is that still good enough?

Now that FSMA is here… it is not enough…

So how do you prove it? Elanco can help help… Rumensin has a micro tracer technology built into the product and Elanco provides the test kits for free. There are two types of kits…

1.) Mason Jar Kit – Give a simple YES or NO answer to the question “is there Rumensin in my feed?”. It’s easy to conduct and can be used to prove your sequencing and Flush procedure works!

2.) Rotary Test Kit – Goes a step further and will tell you how much Rumensin is in a feed. It is slightly more complicated to conduct but if you need the answer to how much is there this is a quick way to get the answer without waiting for the lab report.

If you are interested in learning more about this technology, email me at barbsimeon@co-opfeed.com and I will refer to the appropriate Elanco rep to help you out…

AFIA posts about… FDA CPGs withdrawal…

FDA Withdraws CPGs Related to the Use of Rendered Products in Feed, Pet Food

AFIA published the following information on Tuesday April 30, 2019. It is re-posted with approval…

In response to a citizen petition, the Food and Drug Administration withdrew three compliance policy guides (CGP) today that dictate how certain animal-derived food materials can be used in animal food. The FDA said the action will “clarify” for animal food manufacturers the agency’s regulatory policies and expectations for the use of materials from dead or downer animals.

Since the CPGs were issued 40 years ago, FDA said its “knowledge of, experience with, and focus on preventing safety problems with animal food has increased.” Referencing the Food Safety Modernization Act, which placed sweeping new authorities and requirements on both the human and animal food industries, and its resulting 21 CFR Part 507 (the “Current Good Manufacturing Practice, Hazard Analysis, and Risk-Based Preventive Controls for Food for Animals”), animal food manufacturers, including renderers, are now required to do more than ever before to identify hazards, develop risk-based preventive controls and test and monitor their safe manufacturing protocols in their animal food safety plans.

Given the breadth and depth of FSMA, the FDA stated in its letter that the CPG on Rendered Animal Feed Ingredients (CPG Sec. 675.400) and the one on Canned Pet Food (CGP 690.300) are no longer necessary:

“We have determined that the CPGs that we have withdrawn are outdated because they do not inform animal food manufacturers of the part 507 regulation, a new, integral part of the animal food safety framework. Furthermore, they are incomplete because they highlight only one type of hazard (biological) that has been associated with tissues of animal origin. … since the two withdrawn CPGs were originally released, we have issued regulations and other more extensive guidance and draft guidance that are directly relevant to animal food safety.”

In addition, on the CPG on Uncooked Meat for Animal Food (CPG Sec. 690.500), the FDA said it “simply restates the adulteration provision” of the Federal Food, Drug and Cosmetic Act’s section 402(a)(5) and its ability to “take action on uncooked animal food products derived from ‘diseased animals or animals that died otherwise by slaughter’.”

The FDA reiterated that the use of rendered ingredients in many pet foods, including canned pet food, can provide a safe source of fat and protein. The American Feed Industry Association agrees that the rendering process is sophisticated and regulated to ensure that only quality animal food products are ever used, in accordance with all state and federal laws and regulations, and is one way the industry can be more sustainable.

The FDA’s actions today should not impact animal food manufacturers’ ability to produce safe feed and pet food for animals. The FDA still maintains the same authority it has had to take action against animal food products or manufacturers that could pose a threat to human or animal health.

What does this mean for you?

  • If you are an animal food manufacturing facility that uses rendered ingredients from dead or downer animals, you must ensure that any hazards these ingredients could pose are accounted for in your hazard analysis and animal food safety plans as part of 21 CFR Part 507.
  • If you do not use rendered ingredients from these animal sources, it is still a good policy to know your suppliers and validate your supply stream to ensure you are properly managing hazards and accounting for them in your animal food safety plans.

Status of FDA Inspections during partial government shutdown

I subscribe to a free publication “FSN – Food Safety News” to keep as up to date as possible with Food Safety issues, incidents and recalls. This article appeared this morning…

FDA food investigations running at less than 50 percent of normal

By Dan Flynn on January 22, 2019

The Food and Drug Administration has “more than 200 food investigators” on the job “not counting support staff and supervisors” out of about 550 total professionals “when the agency is fully operational,” according to Commissioner Scott Gottlieb.

In a “tweet” Monday, the FDA commissioner said he was responding to questions about staffing levels for FDA’s Office of Human and Animal  Food Operations. It was one of the most detailed statements about food safety staffing that Gottlieb has made since the partial government shutdown began on Dec. 22.

Click here to read the entire article…

Training

Preventive Controls for Animal Food
Penn State Extension will be offering a Preventive Controls for Animal Food workshop at the Penn State Extension Mercer County Office in
Mercer, PA on January 29-31.

Upon completion of the entire 2.5 day course, attendees will met the
requirements to be considered as a preventive controls qualified
individual. Current good manufacturing practices, conducting a hazard
analysis, and preventive controls for animal foods will be covered
during the workshop. The audience for this workshop includes
facilities that process, manufacture, pack, or hold animal feed or pet
food.

Register online with any major credit card (MasterCard, Visa, Discover or American Express) at http://extension.psu.edu/animal-pc.
Registration deadline is January 22.

AFIA Reminds Members of Expectations for HA/PC Inspections, Clarifies Investigator Process with FDA

Most of the feed mills that subscribe to my posts are small facilities and not currently subject to inspections of Feed safety Plans.  This article published by AFIA reminds large facilities what to inspect when FDA knocks to do a Feed Safety Plan inspection. It has valuable information you need to consider as you continue to prepare your Feed safety Plan. In the coming months you may get a CGMP inspection. Remember while the FDA is not inspecting small facility feed safety plans you are required to have one in place. I have bolder the part that i have been preaching for almost 3 years now. Please read this important information…

Continue reading “AFIA Reminds Members of Expectations for HA/PC Inspections, Clarifies Investigator Process with FDA”

FSMA Compliance is NOW!

It is hard to believe that 3 years has past since the rules for FSMA were finalized. But today is Monday, September 17, 2018 and this date is significant!

  • All food facilities must be in compliance with CGMP’s. If you or someone you know is planning on filing for an exemption based on the size of the facility it is important to understand that there is no exemption from CGMP’s.
  • Small business must have or be actively engaged in performing a Hazard Analysis to identify Known and Reasonably Foreseeable Hazards. They than must make a determination if they require a preventive control to mitigate those hazards to an acceptable hazard.

Continue reading “FSMA Compliance is NOW!”

Free Sanitary Transportation of Animal Food Training

More free videos for training on the Sanitary Transportation of Animal Feed have been posted to the Free Training Video page.

#4 – Sanitary Transportation of Animal Feed – Target Audience is Transportation Companies hauling grains and animal food.  

If your third party carriers are reluctant to haul grains and feed due to the regulation that went into effect in April this 9 minute video will tell them what they need to know. Please feel free to send them to this site for this important training.

Continue reading “Free Sanitary Transportation of Animal Food Training”