Keeping Up: Herchler Addresses AAFCO Food Safety Modernization Conversation Workshop
The Association of American Feed Control Officials (AAFCO) held a Food Safety Modernization Conversation Workshop before their 2019 annual meeting in Louisville, KY. The workshop brought universities, industry, trade associations and regulatory bodies together to talk about expectations for the implementation of the Food Safety Modernization Act (FSMA) and available resources.
Marissa Herchler, Area Specialized Agent for Animal Food Safety at NC State University started the day: she gave a presentation highlighting resources for industry from NC State University and Kansas State University. Herchler addressed a variety of topics including frequently asked questions, food safety plan reviews, common food safety mistakes, Food Safety Preventive Controls Alliance (FSPCA) training at universities, qualified individual training at universities, and rising animal food safety issues.
Many of these topics were echoed by trade associations and regulatory bodies throughout the day. Some highlights include:
- It’s common to see multiple inspectors over multiple days during Current Good Manufacturing Practice (CGMP) or hazard analysis inspections. This isn’t a reflection on individual facilities. Inspectors are taking this opportunity to learn from one another to prepare for future inspections and make sure their teams are inspecting facilities consistently. This also gives the inspectors the chance to talk through their understanding of the regulation together before taking action. The FDA and state regulatory authorities stressed the importance of educating before regulating because this is such a new regulation for this industry.
- Qualified individual (QI) training should be provided for all individuals working in a facility, including seasonal and temporary employees. If individuals have duties that could potentially affect the safety of the animal food produced, they should receive training on basic principles of animal food hygiene and safety. In addition to the basic hygiene and safety training, QIs should also receive facility-specific information or training related to their job duties. QI training is made available by universities and trade associations. NC State is in the final stages of development of their QI training.
- It’s important to be able to explain decisions made in the development of the food safety plan. Even if a facility has an off-site Preventive Controls Qualified Individual (PCQI), the employees of each facility should be able to have a discussion about the food safety plan and the implementation of the plan in the facility. A good way to get employees familiar with the expectations of the food safety plan is to have meetings to discuss the decisions made and how these decisions impact day-to-day operations.
- A food safety plan should be specific to each individual facility. When developing a food safety plan, many facilities are using the copy-and-paste method. If there’s information about a species that’s not being fed from a facility in their food safety plan, or practices for employees that are not being done, it will become very obvious to regulators the facility did not appropriately develop the plan. Outside resources can certainly be used, but they should be relatable to specific facilities.
- There are differences between prerequisite programs, current good manufacturing practice and preventive controls. Many facilities have determined they have preventive controls in their plan, but don’t have any management practices for the preventive controls. Prerequisite programs can be used to mitigate hazards, but should be documented in standard operating procedures (SOPs) and referenced as a justification for not having a preventive control, if a facility chooses.
- FSPCA training is available from a number of universities. NC State offers the Preventive Controls for Animal Food course approximately two times a year, based on industry demand. Anyone interested in taking the course through NC State should contact Marissa Herchler for more information.
- PCQIs should be mindful of hazards or potential hazards associated with ingredients received or food produced in their facility. The FDA recall page, the Reportable Food Registry, trade associations and university websites are all good places to get information about emerging animal food safety issues.
Some of the rising animal food issues discussed at the AAFCO meeting include:
- Dilated cardiomyopathy (DCM) in dogs potentially connected to grain-free diets
- Pentobarbital in fats
- Pathogens in pet food
- Excessive vitamin D
- The potential for foreign animal diseases in pet food diverted to swine feed
- Aflatoxin contamination in livestock feed
This is not a list of hazards that are appropriate for every facility. It is up to each PCQI or food safety team to determine the list of hazards that are known or reasonably foreseeable in each facility.
General findings from FDA CGMP inspections involve pest management, general housekeeping and qualified individual training documentation.
Although inspections were pushed back during the beginning of the compliance period, many regulatory authorities have completed FSMA inspector training and inspections are going to become more frequent beginning this fall.
Starting in October 2019, there are 330 routine or for-cause inspections expected to take place during the rest of the 2020 fiscal year. Be prepared: ensure pests are managed within and around facilities, consider emerging issues when identifying and evaluating hazards, and most importantly: Do what you say and say what you do in your food safety plans and prerequisite programs, and document it.