The 21st century has brought sweeping changes in food safety laws. Reforms in food production and storage methods were created to help reduce foodborne illnesses.
The Food Safety Modernization Act (FSMA)
The most significant safety reform in the last 70 years was The Food Safety Modernization Act (FSMA), signed into law in January of 2011. With this law and FDA’s subsequent guidelines, the focus of food production has shifted from simply reacting to foodborne illnesses to preventing them. Companies are more aware of toxins and their effect on the global food chain because of FMSA, which outlines Human and Animal Food Safety Plans to identify hazards at every stage of production.
FSMA also brought reform to the supply chain for animal feed. The FDA created a clear set of rules based upon the FSMA in order to increase preventative measures and better control each process within the animal feed supply chain.
Animal feed facilities must meet the following three requirements:
- Maintain Current Good Manufacturing Practices (CGMP)
- Implement a food safety system
- Establish a supply-chain program for addressing hazards
1. Current Good Manufacturing Practices (CGMP)
According to the FDA, Current Good Manufacturing Practice (CGMP) is “necessary to prevent animal food from containing filthy, putrid, or decomposed substances, being otherwise unfit for food, or being prepared, packed, or held under unsanitary conditions whereby it may have become contaminated with filth, or whereby it may have been rendered injurious to health” (Preamble, II: Legal Authority).
CGMP compliance addresses the following components for safe animal food production: personnel, grounds, sanitation, water supply and plumbing, equipment and utensils, plant operations, holding and distribution (for animal feed and for human by-products for use as animal food).
2. Food Safety System
A properly established food safety system must include four key factors:
- Hazard Analysis
- Preventive Controls
- Oversight and Management of Preventive Controls
- Recall Plan
Hazard analysis is the foundational step to a food safety system. This will determine whether the facility’s product presents a known or reasonably foreseeable hazard. Any known hazards, whether naturally occurring, unintentionally introduced (debris) or intentionally introduced for process efficiency or economic gain should be part of this analysis. The analysis should also consider the end-uses of the feed product, as that will alter the degree and type of remediation depending upon the hazard present.
If a hazard is identified, the facility must implement a plan to address each hazard with a preventive control. These controls account for a method to eliminate hazards, ensure unadulterated food and follow a process for correction if a contamination is discovered. Preventive measures should include both process controls and sanitation controls.
An integral part of preventive controls is the actual implementation and management of those controls. The integrity of the entire food safety system will be compromised without methods for monitoring, correcting and verifying the controls within the process.
3. Supply-Chain Program
A hazard analysis should also include an analysis of raw materials and ingredients obtained outside of the animal feed facility from other suppliers. This plan for analysis, hazard identification and preventive control measures is called a supply-chain program. However, if suppliers also have an existing food safety system, involving hazard analysis and preventive controls, the manufacturer does not need to produce their own analysis of the product hazards.
The Foundation: The Hazard Analysis
The foundation to the entire food safety system starts with a proper hazard analysis. Many animal feed facilities that require large silos for storage struggle to establish a trusted method for maintenance, temperature control, cleaning and safety of their stored feed.
Mole∙Master has extensive experience within the grain and feed industry and comprehensive knowledge of mass storage issues in all climates, bin materials and facility conditions. Contact our expert technicians at Mole∙Master for a thorough hazard analysis of your animal feed facility,. Our technicians can not only identify potential hazards, but also quickly and efficiently mitigate issues through our silo and bin cleaning services, getting you back in operation and compliance as soon as possible.