AAFCO Midyear Meeting Updates: What to Expect During Animal Food Inspections
One of the most anticipated sessions from this year’s Association of American Feed Control Officials (AAFCO) midyear meeting focused on inspection updates for the animal food industry in response to COVID-19.
North Carolina was fortunate to be represented on this panel by George Ferguson, Feed Administrator at the North Carolina Department of Agriculture and Consumer Services (NCDA&CS) (and Prestage Department of Poultry Science alum).
Other session panelists included:
- Eric Nelson, Director of the Division of Compliance in the FDA’s Office of Surveillance and Compliance,
- Vinetta Howard-King, Director of the Office of Human and Animal Food Operations in FDA’s Office of Regulatory Affairs, and
- Dr. Paul Davis, Director of Quality, Animal Food Safety and Education at the American Feed Industry Association (AFIA).
Where are We Now?
There are about 600 N.C. facilities that are subject to the Preventive Controls for Animal Food (PCAF) rule. This is an overwhelming number of facilities to inspect by a few trained investigators at the NCDA&CS. COVID-19 has made things more difficult, since it’s harder now to get into facilities and to train additional personnel on the inspection process.
Just because routine domestic and international surveillance has been postponed in many areas doesn’t mean the FDA and state regulatory agencies aren’t conducting investigations. Like many of us, they’ve had to find creative ways to continue to get the job done.
Ferguson praised many of the facilities in North Carolina his group has worked with during COVID-19, stating that facilities have been flexible and patient while working through these new types of inspections.
What can Facilities Expect During Inspections?
Some of the new inspection tools NCDA&CS is using include pre-inspection announcements, virtual document review, physically distanced on-site walkthroughs and document retrieval, virtual closeout meetings, and increased communication.
Normally, investigators give little to no warning when coming to a facility for an inspection.
Over the last year, investigators have found that giving 5+ days of warning to a facility allows them to have an opportunity to prepare, and limits the risk of spreading COVID-19.
Virtual Document Review
Rather than having an investigator and member of a facility’s team isolated in a room in a facility, NCDA&CS is using virtual conference tools such as Zoom, to review documentation for preventive controls review.
Holding virtual meetings allows more people to join in for training purposes (in listen-only mode) for both the investigator and facility, while remaining physically distant.
Physically Distanced On-Site Walkthroughs and Document Retrieval
After the virtual document review, investigators will still need to conduct a Current Good Manufacturing Practice (CGMP) walkthrough, following social distancing and mask protocols, as recommended by the local government and the Centers for Disease Control (CDC).
Meetings with any facility personnel are done outside, if possible. While the investigator is at the facility, they can also pick up any documentation that was requested during, or as a result of, the virtual document review.
Virtual Closeout Meetings
After the virtual document review and on-site CGMP inspection/document retrieval, facility personnel and investigators will once again meet online for a closeout meeting.
The benefit of having virtual meetings is that investigators in training can sit in on these reviews (in listen-only mode), gaining further knowledge on how to handle these reviews.
More than anything, the panel stressed the importance of communication between investigators and facilities. If you have questions about the inspection or the inspection process, contact your investigator for clarification.
Biosecurity is not a new idea for the animal food industry. Focus on communicating any biosecurity or COVID-19 safety protocols with investigators prior to the on-site inspections.
Get Help with Inspections
We’re here to help!
We have two factsheets to help industry prepare for regulatory inspections:
- [How Animal Food Facilities Can Prepare for Regulatory Inspections]
- [Food Safety Modernization Act Current Good Manufacturing Practices for Food for Animals and COVID-19]
If you have questions about animal food safety or animal food inspections, please contact Marissa Herchler.