Pets are People Too Sheila K. Hamlett Food Safety Director KLN Family Brands shamlett@klnfamilybrands.com
History of pet food safety regulations Why we needed FSMA for pet food How FSMA affected pet food companies
Definitions • Pet – Animals normally maintained within a household, including but not limited to cats, dogs, mice, rats, gerbils, hamsters, guinea pigs, rabbits, ferrets, hedgehogs, sugar gliders, parrots, turtles, lizards, snakes and tropical fish • Pet Food – kibble, canned/pouched, raw, supplements, treats, whole carcass
History of pet food safety regulations
1938 Food, Drug and Cosmetic Act Animal food is considered adulterated if it • contains any poisonous or deleterious substance which may render it injurious to health • consists in whole or in part of any filthy, putrid, or decomposed substance, or if it is otherwise unfit for food
1938 Food, Drug and Cosmetic Act Animal food is considered adulterated if it • has been prepared, packed, or held under insanitary conditions whereby it may have become contaminated with filth, or whereby it may have been rendered injurious to health
Good Manufacturing Practices • 1969 – GMPs were first developed by the FDA and became part of 21 CFR 128 but were specific to human food • 1976 – GMPs were created for Medicated Feeds (21 CFR 225). Medicated feeds were considered drugs and not food. • 1977 – GMPs were moved to 21 CFR 110, still specific to human food
Good Manufacturing Practices • 1986 – Additional GMPs developed for specific product types. – Quality control procedures for nutrient content of infant formula (21 CFR 106) – Acidified foods (21 CFR 114) – Bottled drinking water (21 CFR 129) – Thermally processed low‐acid canned foods in hermetically sealed containers (21 CFR 113)
The Food Safety Modernization Act is the most sweeping reform of our food safety laws in more than 70 years
Food Safety Modernization Act • 2011 – FSMA signed into law • 2018 – Final compliance date for Current Good Manufacturing Practice and Hazard Analysis and Risk‐Based Preventive Controls for Food for Animals
Additional Regulations • Generally Recognized as Safe (GRAS) ingredients • Food Additives • Labeling • Numerous Guidance Policies
Additional Regulations • 2013 ‐ Sec. 690.800 Salmonella in Food for Animals – Zero tolerance for Salmonella in pet food – More strict than policies on Salmonella in human food both before and after FSMA – Many pet food recalls initiated over possible contamination because Salmonella was in the factory, even though it was not found in food
Why we needed FSMA for pet food
History of Pets Humans domesticated dogs between 13,000 to 30,000 years ago Cats domesticated themselves about 9000 years ago
History of Pets Dogs were used as “tools” for herding, hunting, guarding livestock and property and personal protection. Both cats and dogs were used for vermin control. Companionship was secondary.
The Role of Pets Changed When the Food, Drug and Cosmetic Act was passed, pets were still largely considered “just animals” that had to earn their keep. They were kept outside and fed primarily table scraps (or hunted/scavenged). As people had more disposable income and more leisure time and didn’t need to rely on pets to survive, keeping pets for companionship only became more common.
August 29, 2005 Hurricane Katrina Nearly half of all people who stayed behind did so because they were not able to evacuate with their pets. Many of those people died. 250,000 pets abandoned. 150,000 died.
Was change to regulation necessary? Physical Contamination – not really an issue Chemical Contamination – 2007, Melamine contamination of wheat gluten used in pet food. 14 confirmed deaths, but hundreds were reported. Micro Contamination – Dogs, cats and other pets aren’t usually affected by pathogens but they can be asymptomatic carriers
Human Salmonellosis from Pet Food • 2007 – 62 people from 18 states infected by Salmonella in dry dog food. No deaths but 32% of illnesses resulted in bloody diarrhea and 25% were hospitalized. • 2010 – frozen feeder rodents caused an outbreak of Salmonella and traced to a single US supplier. Two hundred people in the UK and 34 in the US were sickened.
Human Salmonellosis from Pet Food • 2012 – 49 people from 20 states and Canada infected by Salmonella in dry dog food. Ten percent had to be hospitalized. • 2018 – Two children in Minnesota became ill from raw pet food, resulting in one of the children being treated for osteomyelitis.
Yes, FSMA was needed The role of pets had changed from utility to family and had relocated from the barn to the bedroom. Changes were needed in how pet food was made in order to protect against contamination that could harm both pets and people.
How FSMA affected pet food companies
GMPs are now required Adding GMPs was a huge culture change. The need for handwashing and hairnets was difficult for some employees, particularly those who had been working in the industry for decades.
GMPs are now required Sanitation beyond sweeping the floor, taking out the trash and removing some product buildup had not been a priority. Many pet food facilities were built well before anyone thought about preventing pathogens. Often pet food facilities were converted feed mills.
Meeting the GMPs Employees have had to change their thinking and behaviors. Training, training, training. Many companies have had to upgrade equipment, remodel facilities, or rebuild altogether in order to meet the requirements.
Food Safety Plans There had previously been no requirements for pet food to follow a HACCP based system for food safety. Same requirements as for Human Food with a few exceptions – Chemical hazards need to consider nutritional hazards – Allergen Preventive Controls are not a requirement
Food Safety Plan Compliance Another part of the culture change for employees. More training and documentation requirements. Pre‐approval of certain suppliers.
Challenges Remain The food safety culture needs to change, not only within the Pet Food industry but also with ingredient suppliers. Older facilities can have resident Salmonella in the environment that can be difficult to impossible to eradicate.
Challenges Remain Raw Pet Food Trend – Raw is risky Numerous recalls for raw pet food because there is zero tolerance for Salmonella. No kill step with high risk ingredients. HPP and Irradiation available but not supported by customers.
Like human food, pet food laws had remained the same for more than 70 years. The role of pets had changed dramatically and laws needed to be changed in order to protect both pets and people. Pet food companies needed to adapt to the change. Challenges still exist.
Pets are People Too Sheila K. Hamlett Food Safety Director KLN Family Brands shamlett@klnfamilybrands.com
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