Food Safety Magazine

Pet Food | October/November 2017

Pet Food and Treat Safety: It’s Time for Facts, Not Fearmongering

By Cathleen Enright, Ph.D.

Pet Food and Treat Safety: It’s Time for Facts, Not Fearmongering

“Pet food recalls are proof there is something wrong in the pet food industry.” This is just one of the falsehoods perpetuated online and across social media that unduly undermines customer confidence in commercial pet food and treats.

As the voice of the U.S. pet food and treat industry, the Pet Food Institute (PFI) is talking about the manufacturing process, the regulatory environment and the companies that feed America’s dogs and cats. It’s important and our responsibility to provide those facts.

A recall, whether for a human food or for a pet food or treat, removes a product from the marketplace and is an integral part of the current U.S. food safety system. For PFI members, it’s also inherent in their food safety plans, which are designed to drive continuous improvement in the safety of ingredients and finished products.

In this regard, the 2007 pet food recalls resulted in a marked change for PFI and its members. Pet food ingredient makers in China added melamine to wheat gluten and rice protein concentrate in an effort to mislead their customers about the ingredient protein levels. Tragedy resulted—an untold number of pets became sick or died. Such intentional adulteration for economic gain was unprecedented in the food industry at the time.

While PFI members had existing safety plans in operation and recalled impacted products even before the cause of illness, a combination of melamine and cyanuric acid, was identified, PFI established a Pet Food Commission of experts in nutrition, veterinary medicine and chemistry to study the findings related to the recalls and make recommendations to the manufacturing, regulatory and veterinary communities. PFI members began to adopt the commission’s recommendations for pet food makers:

•    Update quality assurance programs to incorporate best product safety practices throughout the manufacturing and distribution process, including ingredient sourcing and receiving

•    Reevaluate sampling and testing protocols

•    Strengthen traceability to include lot and date codes on finished products

These actions are now built into our culture of safety and are required under the Food Safety Modernization Act (FSMA).

Safety Is the Priority
PFI members make 98 percent of U.S. dog and cat food and treats. Their preventive, forward-looking food safety systems support pet food safety daily.

Today’s pet food safety programs must be prevention-based and employ practices such as applying advances in technology, adhering to strict testing protocols, practicing zero tolerance for the presence of Salmonella and continuous monitoring throughout the manufacturing process to ensure the safest possible food products are being consumed by the 180 million pet dogs and cats across the country who live in nearly two-thirds of U.S. households.

Pet food shoppers find an array of choices when selecting food, treats or chews: dry (kibble), wet (canned), semimoist, fresh, dehydrated, freeze-dried and raw-infused. For PFI members, the safety and nutrition of these products is the top priority.

This year, PFI is telling the story of how pet food is made to convey the breadth and rigor of pet food safety practices. It starts with reliable suppliers. PFI members ensure that companies supplying their pet food ingredients are regularly inspected. These inspections can include reviews of suppliers’ quality control procedures and their adherence to Good Manufacturing Practices (GMPs), safety principles and processes consistent with Hazard Analyses. Even after suppliers are approved, ingredients are scrutinized upon arrival at a manufacturer’s facility against the manufacturer’s specifications.

Ingredients can arrive at the pet food facility in several ways. Some grains and ingredients are shipped in bulk via rail car, some ingredients arrive bagged (meals, vitamin and mineral premixes) and oils are shipped in tanker trucks or drums. Meat, poultry and fish are usually transported in refrigerated trucks.

Upon arrival, ingredients are assessed for a series of requirements, as appropriate. For example:

•    Confirmation of safe handling during transportation by inspecting the integrity of container seals and cleanliness of the hopper

•    Verification that the tanker truck was cleaned prior to loading, that proper temperature control was maintained, and that an inspection for the unintended presence of materials such as metals was performed

•    Ensuring compliance with nutrient and grading specifications such as protein, moisture and fat content, checking for antioxidant levels and for the presence of bacteria, spoilage, infestation and toxins

Pet food manufacturing facilities are designed with safety in mind, to prevent product contamination and maximize security. Hygienic design may include use of stainless steel manufacturing equipment; installation of handwashing stations and foot baths; positive airflow and mandatory walking patterns; protective coatings on floors and walls to enable sanitization; and security of the facility perimeter, internal areas, equipment and ingredients. Safety continues throughout the manufacturing process. A sample manufacturing process may include:

•   Verification that proper temperature, pressure and pH are maintained

•   Environmental testing in the facility for the presence of bacteria

•   Metal detection and X-ray inspection for metals, plastics and other unwanted materials

•   Verification of correct equipment setup and function

•   Confirmation that the correct product size, shape, color and protein, fat and moisture levels are being produced

•   Sanitization of equipment before the manufacture of a different product begins

Regular testing and inspection continue through packaging and distribution, before the food arrives at the store shelf.

Examples of these measures include:

•    Verification that the proper mix of product is dispensed into the proper package, at the correct weight

•    Verification of the correct barcodes and date codes for product traceability

•    Review of integrity of containers, equipment and packaging

•    Verification of the package/container seal integrity

•    Environmental bacteria testing

•    Testing the product to confirm the guaranteed analysis

•    pH testing

•    Checking for the presence of unwanted moisture or condensation

•    Reviewing quality factors, such as product consistency

•    Confirmation that the proper shipping conditions will be maintained
 

Registration Process for Pet Food Makers

Manufacturers must submit for review and acceptance by state regulators a product label for each pet food or treat product they want to sell in the state. Product label review includes:

•    Review of label format to ensure required information is present, such as the brand name, intended species, quantity of product, guaranteed analysis (GA, see details below), ingredient statement, nutritional adequacy statement (also below) and feeding directions. Many of these pieces of information have state-specific language requirements.

•    Examination for allowable ingredients—ingredients approved by the Association of American Feed Control Officials or Generally Recognized as Safe—through FDA or self-affirmation, or ingredients that have received a food additive petition.

•    A GA of specific measurable levels, usually a minimum and maximum, for crude protein, crude fat, crude fiber, moisture, ash and other mineral supplements.

•    A nutritional adequacy statement (i.e., complete and balanced); only those products that provide total nutrition can be labeled as such. Manufacturers can be asked to substantiate this statement by providing a comparison with nutrient profiles.

•    Provision of calorie content.

•    Assurance that use of certain terms is not misleading (e.g., “light,” “lean,” “low-fat” or comparisons between products on the market). There are regulations in place that define such terms.

•    Name and address of the manufacturer/distributor.

•    Review of product claims. There are guidelines in place that must be followed to make product claims such as “tartar control formula” or “natural.”

Recall Plans Are Essential
Under FSMA, all food companies are required to have a recall plan as part of their overall food safety plan. Should a test result fall out of specification, such as indications of an improper balance of ingredients or presence of an unwanted compound compared with the product label, PFI members take corrective action. If a recall is appropriate and the product is in the marketplace, PFI members work internally and with regulators to remove the product from the shelf as quickly as possible.

The vast majority of pet food product recalls are preventive; they are initiated by the manufacturer after it has identified an issue. Companies will also conduct a recall if the U.S. Food and Drug Administration (FDA), which also tests pet food and treat products, alerts them about a concern. In all cases, recalled pet food products have been recalled voluntarily by the manufacturer. A list of all FDA-regulated human food and animal feed/pet food recalls is available online.[1] By my count, 26 dog or cat food/treat recalls were conducted in 2016.

PFI reminds shoppers who have purchased a product that is recalled to review the label code and contact the product manufacturer. In addition, they should take the food or treat back to the place of purchase.

With FDA’s new statutory authority under FSMA, the agency can now issue mandatory recalls for food and drug products. As indicated above, the agency has never had to use this authority for a pet food product.

Pet Food Is Regulated at Federal and State Levels
Many pet owners are surprised to learn that pet food is among the most highly regulated of all U.S. food products. While pet food makers and their suppliers have always been required to market safe products under the Federal Food, Drug, and Cosmetic Act of 1938, FSMA resulted in the most comprehensive changes to U.S. food safety regulation in more than 70 years. FSMA and its implementing regulations promulgated by FDA shifted the emphasis on food safety from correction to prevention of foodborne illness. Significantly, this requires practices and documentation for:

•    Current GMPs (CGMPs), which entered into force for pet food and treat makers in September 2016. Under FSMA, pet food and treat makers must implement CGMPs, which are up-to-date steps that help ensure foods are produced in safe environments. FSMA codifies many of the safety practices already utilized by PFI members and requires all pet food makers to proactively address potential food safety concerns.

•    Hazard Analysis and Risk-Based Preventive Controls (HARPC): PFI members are also preparing for the September 2017 compliance deadline for implementation of the HARPC provisions of FSMA. These require each pet food maker to identify known or reasonably foreseeable hazards (physical, chemical and biological) associated with the foods they produce and then evaluate the risks associated with these hazards and implement controls as appropriate to mitigate them. 

•    Development and implementation of a food safety plan detailing the steps they are taking to ensure product safety, from sourcing ingredients to carrying out a product recall if ever needed.

•    Compliance with foreign suppliers and sanitary transportation requirements for both finished pet food/treats and ingredients.

More information on FSMA requirements related to pet food and treats can be found through FDA.[2]

All commercial pet food facilities in the U.S. must register with FDA and are regularly audited by agency inspectors. PFI has worked from rulemaking through implementation to ensure our members are well aware of their FSMA obligations. Our efforts will continue through the compliance and enforcement phase, and PFI is continuing to engage our members, federal and state regulators, and other stakeholders to make sure FSMA expectations are clearly understood by pet food and treat makers, as well as by FDA and state officials conducting FSMA compliance and surveillance.

PFI members are also focused on promoting food safety among all pet food and treat makers, whether or not they are members of PFI, and ensuring FSMA compliance across the industry. PFI has written open letters[3] to pet food makers about their rights and obligations under FSMA, which have been published in pet food trade magazines and provided to exhibitors at major industry events.

In addition to FDA regulations, pet food makers must adhere to federal rules and regulations set by the Federal Trade Commission, which regulates pet food labeling and advertising claims, and the U.S. Department of Agriculture, which regulates meat quality and determines which animals can be used in human and pet food.

Most states also regulate pet food under their animal feed laws and require pet food makers to register each product before it may be sold within state borders. This product registration process involves state evaluations of products and labels to ensure compliance with applicable state requirements (see “Registration Process for Pet Food Makers”).

The state registration process can also provide regional regulators with an awareness of all products sold in their state. In the case of a product recall, this can help state regulators better discern where and which product SKUs are affected and respond accordingly.

An easy way for states to keep their feed laws current is to adopt all the model regulations established by the Association of American Feed Control Officials (AAFCO), the organization of state regulatory officials that develops model bills and regulations for animal feed (including pet food) regarding, for example, CGMPs, ingredient definitions and requirements for pet food labels and product claims. This adoption would certainly help harmonize pet food regulations across the country, bringing more uniformity, certainty and transparency to the pet food and treat safety system. The AAFCO CGMPs have been in place for many years, and the association is currently adopting the federal CGMPs required under FSMA. AAFCO also provides language that enables states to adopt FSMA regulations in their entirety.

State regulators routinely inspect pet food manufacturing facilities to verify that CGMPs are being followed, appropriate documentation is in place and a food safety plan is written and followed. Within the past month, state and federal regulators began inspecting pet food faciities to ensure full compliance with FSMA requirements.

Pet Food Ingredients
Most people aren’t aware that beyond the safety practices and requirements described above, a pet food ingredient cannot be used in pet food until it has been accepted by FDA and adopted by AAFCO. In this regard, an ingredient must meet safety criteria for its intended use to be considered acceptable for use in a pet food recipe.

There are four ways for an ingredient to be acceptable for use:
1.    Ingredients may be approved by AAFCO’s Ingredient Definitions Committee to be listed in their Official Publication.

2.    An ingredient may have gone through the process to receive a food additive petition from FDA, which would be listed on the FDA website.[4]

3.    The FDA website also has a list of ingredients that are Generally Recognized as Safe (GRAS). Processes exist for companies to self-affirm GRAS.[5]

4.    In addition, ingredients that were in use prior to 1958 and have not caused any issues are considered safe and legal for use.

Peace of Mind
For PFI and our members, pets are part of the family. We understand the careful thought pet lovers put into what they feed, and how they care for, their dogs and cats. As pet food makers, our members know they are responsible for providing the sole source of nutrition for most of America’s pets—they take the responsibility of producing safe, healthy pet food seriously.

With all the love pet parents give their dogs and cats, they deserve peace of mind. PFI is focused on sharing the facts to help us all feel confident filling that food bowl.    

Cathleen Enright, Ph.D., is the president and CEO of PFI, whose members make 98 percent of all U.S. pet food and treat products. She is the past executive vice president of the food and agriculture section in the Biotechnology Industry Organization. She also led the federal government affairs office of the Western Growers produce association. She earned a Ph.D. in biochemistry from the State University of New York.

References
1. www.fda.gov/animalveterinary/safetyhealth/recallswithdrawals/.
2. www.fda.gov/downloads/Food/GuidanceRegulation/FSMA/UCM461884.pdf.
3. www.petfoodinstitute.org/wp-content/uploads/20170323-Letter-to-US-Pet-Food-and-Treat-Makers.pdf.
4. www.fda.gov/Food/GuidanceRegulation/GuidanceDocumentsRegulatoryInformation/IngredientsAdditivesGRASPackaging/ucm253328.htm.
5. www.fda.gov/food/ingredientspackaginglabeling/gras/.

Categories: Facilities: GMPs; Food Types: Ingredients; Regulatory: FSMA