ATLANTA — The Association of American Feed Controls Officials (AAFCO) and the US Food and Drug Administration (FDA) led discussions on updated guidelines and food safety measures for animal feed and pet food manufacturers at the American Feed Industry Association’s (AFIA) Pet Food Conference held Jan. 25.
George Ferguson, president of AAFCO, covered the latest topics trending in pet food regulation, including label modernization, human-grade guidelines and the organization’s Hemp Project.
One of the current focuses for the association is that of pet food labeling. From label nutritional adequacy and safe handling to nutritional facts and ingredients, the association will be overhauling the current label and creating new guidelines. According to AAFCO, the idea is for pet food nutrition labels to mimic human food labels.
“It’s really about ensuring that customers are comfortable with these labels,” Ferguson said. “They’re going to look a lot more like what you would think of as a USDA-type label that’s on human food.”
Regarding guidelines for human-grade pet food, Ferguson announced that the Pet Food Committee within AAFCO had recently presented updated guidelines to make human-grade certification a bit easier for non-FDA facilities.
“[Originally] if you were making your product in a Food Safety Inspection Service (FSIS) facility, there was no way for it to be human grade,” Ferguson explained. “But a lot of states were allowing discretion because we understood there was an issue there… So, we reached out to USDA’s Ag Marketing Service (AMS) and we’ve now created a pathway for [FSIS facilities]”
The association is also looking into creating a model affidavit for manufacturers that don’t use an AMS process and will be developing unique pathways for companies to submit paperwork for human-grade applications, Ferguson said.
With a growing interest in CBD and pet wellness, there has been a spike in questioning about the proper use of hemp-based ingredients in pet food. According to Ferguson, AAFCO developed a joint letter to bring further awareness to states about the use of hemp.
The letter, released Feb. 9 and signed by 16 other industry organizations, addresses AAFCO’s concerns with the wide use of hemp in animal food, including hemp’s impact on animal health and safety; safety of food derived from hemp-fed animals; legal implications of hemp for animal producers and feed manufacturers; and the lack of research and data on hemp ingredients in animal feed.
“We keep trying to let everyone know we’re not opposed to hemp, we understand the implications of the Farm Bill and where this is headed,” Ferguson added. “We just want to make sure we do it the right way. Let’s make sure we’re using it to feed animals and that it provides nutritive value… We encourage research, and we encourage states to support and help provide research.”
David Edwards, Ph.D., director of the division of animal feeds at the FDA’s Center for Veterinary Medicine (CVM), discussed animal and pet food safety topics, including updates on facility inspections, top concerns for pet food, and African Swine Fever.
As COVID-19 risk continues to decrease, Edwards explained that the FDA has set a plan in place for resuming routine inspections across all facilities, as recently mission-critical inspections have been fully resumed. Despite the drop in inspections, Edwards claimed there have been mixed levels in regulation compliance.
“Overall, we have had strong compliance with our cGMP requirements in our animal food facilities,” Edwards added. “The overall rate of inspections classified as No Action Indicated (NAI) is approximately 90%… [But] animal food facilities compliance with the hazard analysis and risk based preventive controls requirements… have not been as strong as the cGMP compliance, and the percentage of inspections that have been classified as Official Action Indicated (OAI) and Voluntary Action Indicated (VAI) is approximately 23% combined.”
Although Edwards explained that most inspections done during 2021 were mission-critical inspections, meaning the inspectors were going to places with a higher likelihood of having a known safety issue, the numbers for 2021 are still much higher compared to those of 2020. The FDA reported 24% inspections as VAI compared to 9% in 2020, and 8% inspections as OAI compared to 1% in 2020.
“We remain concerned with the elevated levels of OAI and VAI inspections and that may be predicting higher levels of non-compliance when we return to normal levels of surveillance inspections,” Edwards explained.
In food and facility safety, Edwards highlighted three major concerns for animal and pet food manufacturers that led to major citations:
- Failure of hazard analysis, in which the facility did not have a plan or the analysis failed to evaluate a known or reasonably foreseeable hazard or environmental pathogen
- Failure of preventative control, in which a facility did not identify or implement a preventive control of a hazard
- Failure of a food safety plan, in which no plan exists for the facility
Along with those three major concerns for citations, Edwards also claimed pet food facilities were issued citations when it came to taking measures against pests and pest contamination, including facilities with a food safety plan, but lacking hazard evaluation.
Edwards also noted that pathogens have become a major concern for animal food facilities, particularly pet food.
“We have unfortunately seen an uptick in reports of pathogens in raw diets, extruded diets and treats across the entirety of the industry,” Edwards said. “Additionally, we have seen things where we’ve had issues with mycotoxins, specifically aflatoxin.”
As well as pathogens, the CVM has growing concerns about issues with vitamin D in animal and pet food facilities.
“An additional top issue of concern is vitamin D toxicity has been an industry-wide problem that we have seen issues in both livestock food and in pet food,” Edwards said. “Unfortunately, there have been six recalls since 2019, and most often these start with complaints of illness or death from the animals. There have been four recalls so far in 2021. We have seen vitamin D issues originating in a variety of ways, and it seems to be an issue right now.”
Though not a regulatory requirement by the FDA, Edwards explained a renewed interest in lot codes in relation to food recalls.
“If a product is [recalled], we often ask for the lot code that helps us, and subsequently you, narrow down the problem,” Edwards explained. “Whether it’s a facility, the amount of product impacted, other products on the same line, etc., if a lot code is not used or found, that typically can implicate or tie-up a whole bunch of product. Depending on how lot codes are used in a facility, the scope of recall may be narrowed very significantly… If a lot code is used for a long period of time, such as for each month, and if a product is recalled, that might implicate the entire lot, which would be an entire month’s production of a product.”
Lastly, the CVM addressed the growing concern for African Swine Fever and that it would be working with the United States government to monitor and mitigate the virus.
“Although this virus only infects pigs and not humans or other pets, it can impact… the animal feed system, food supply chains and the ability to get certain materials,” Edwards added. “The virus has made its way to the Western Hemisphere, unfortunately, which has caused increased surveillance and discussion of actions if it does make it to our shores. CVM continues to pledge to do its part by covering prioritized reviews of the African Swine Fever virus mitigants that are submitted to CVM as a food additive petition.”
Continue reading our coverage of AFIA’s 2022 Pet Food Conference.