A quick look at the FDA Animal Food Recall and Withdrawal page confirms that animal food safety incidents are on the rise. From potentially elevated levels of aflatoxin, elevated levels of vitamins, Salmonella, Listeria, issues with nutrition claims, or choking hazards, the list of health hazards associated with pet food is well documented. It is no surprise to see certifications like Safe Quality Food (SQF) gaining popularity. Retailers are not taking any chances with costly recalls and have increased the compliance standard for their supplier approvals.
The legal definition of food in the United States includes pet food and animal food. The US Federal Food, Drug, and Cosmetics Act defines “food” as (1) articles used for food or drink for man or other animals, (2) chewing gum, and (3) articles used for components of any such article.” Under the law, FDA regulates pet food similarly to human food. The FD&C Act requires that “all animal foods, like human foods, be safe to eat, produced under sanitary conditions, contain no harmful substances, and be truthfully labeled.”1
Pet Food is also categorized as high-risk or low-risk based on its intrinsic properties. High-risk pet food would, for instance, allow bacterial pathogen growth and survival or would be more susceptible to food fraud, leading to contamination (See melamine in pet food incidents). When developing a food safety plan to address health hazards in pet food, animal health must be considered, as well as the health of pet owners who are preparing the food and feeding their animals. Specifically, the plans are designed to protect populations at risk. Young children, elderly, or immuno-depressed pet owners may become ill when coming in contact with human allergens and other food contaminants present in the pet food.
If you are a pet food manufacturer and you intend to distribute your product through retail chains, you may consider the SQF food safety certification. A question we often receive from potential clients is: Will attaining SQF pet food certification be faster and easier than human food certification”? The answer is no. In fact, your implementation may be more encompassing if we consider labeling and nutrition claim requirements.
In addition, should you decide to certify canned pet food, you will be required to meet food safety categories FSC 32 (Pet food) and FSC 15 (Canning, UHT, and Aseptic Operations). This is because the SQF scheme, which is an American certification, aligns with canned food legal requirements. So canned pet foods must be processed in conformance with the low-acid canned food regulations to ensure pet food is free of viable microorganisms (see Title 21 Code of Federal Regulations, Part 113 (21 CFR 113)).
Specific SQF Pet Food Requirements
Similarly to the manufacturing of human food products, SQF for pet food manufacturing requires two practitioners at the helm, one lead and one backup practitioner. The practitioners are responsible for the development and implementation of the HACCP-based (pet) food management system. They report to an individual in a position of authority at the site. These individuals may be the Plant Manager, the Director of Operations, or the Company President. Both practitioners must obtain HACCP training certificates (see International HACCP Alliance Training).
The core elements of the pet food program in SQF are aligned with that of SQF for human food: Management Commitment, Food Safety Culture, Product Specifications and Approved Suppliers, Document and Record Control, Correction Actions, Verification, Validation, HACCP, Training, Internal Audits, Recall/Traceability, Food Fraud, and Food Defense are mandatory programs for pet food.
Furthermore, Environmental Monitoring (2.4.8) will be mandatory if your risk assessment concludes that your pet food product is susceptible to re-contamination with bacterial pathogens before packaging. This is to prevent cross-contamination incidents with Listeria Monocytogenes and Salmonella spp. This program will require a budget for you or a contractor to take swabs for micro-testing.
The site will also be subject to internal audit and inspection requirements. In doing so, internal auditors and site inspectors will require training. If the internal audits are performed by a consultant, this activity will need to be budgeted.
In SQF, food safety system elements must be implemented by all manufacturing sites regardless of the type of food manufactured. Site requirements (Module 4 for pet food manufacturing and Module 11 for food manufacturing) reflect the good manufacturing practices that are expected for a given Food Sector Category. While Pet Food and Human Food code elements are well aligned, the SQF Pet Food Manufacturing code presents unique requirements.
Under 2.3.1 Product Formulation and Realization, “Product formulations shall be developed by authorized persons to ensure that they meet the intended use, including minimum and maximum nutrient and medicinal values (e.g. vitamin D, thiamine, life stages, species, animal size, and or breeds).” As a pet food manufacturer, you will need to validate the accuracy of your product formulation and nutritional profile by conducting laboratory analysis. In SQF, contracted laboratories must be ISO17025 certified.
Food Legislation requirements (2.4.1) for the country of manufacturing or export must be considered. For instance, if you produce pet food in the United States or export pet food to the US, your site will need to comply with FSMA Preventive Controls for Animal Food. Under the FDA regulations, food safety documentation and records must be developed and verified by Preventive Control Qualified Individuals (PCQIs). FSPCA PCQI formal training is one way that pet food safety specialists can obtain their PCQI credentials. In addition, a Preventive Control plan for animal food will need to be maintained for SQF certification. This regulatory requirement will supplement the SQF code Codex HACCP requirements under section 2.4.3.
Under 2.7.1 Food Defense Plan, the scope of the pet food safety system will be smaller than that of a typical Human Food management system subject to FSMA. This is because animal food is not in the scope of the Intentional Adulteration Rule under FSMA. In other words, the site will not be asked to perform an FDA-compliant risk assessment (see TACCP plan) and identify mitigation strategies based on Actionable Process Steps (APS). While the food defence elements in SQF do not prescribe a methodology, your site’s threat assessment must nonetheless be robust enough to identify sensitive processing points. The program is subject to verification, recordkeeping, and corrective action and must be challenged annually.
Section 2.8 Identity Preserved Pet Food is specific to pet food and addresses label claims and the use of human allergens in the pet food formulation. Under this section of the SQF pet food code, practitioners must facilitate “a risk analysis of those inputs and processing aids, including food grade lubricants, which contain food allergens” and identify “the hazards associated with allergens and their controls.” On the topic of label claims, the site “that market [pet food] as having limited ingredients (e.g., grain-free, poultry-free, etc.)” must validate the safety and legality of process inputs and packaging materials. They must also perform label reconciliations during product changeovers so that the correct pet food label is applied to the correct product. This program relies on competent personnel to conduct these activities (see SQF training requirements under section 2.9 of the code).
The Module 4 requirements (Good Manufacturing Practices for Processing of Pet Food Products) show good alignment with the SQF Food Manufacturing Code. You will note that the documented risk assessments prescribed for Human Food in sections 4.1.2.5 and 4.1.2.6 are not required for Pet Food Certification. The site must still be inspected by trained employees, and inspection records must be kept on file.
As a refresher, examples of documented SQF risk assessments for Module 11 and Module 4 are as follows:
11.1.1.1- 4.1.1.1 Site environment.
11.1.2.5 Ducting, conduit, and pipes that convey ingredients, products, or services.
11.1.2.6 Pipes carrying sanitary waste or wastewater located over product lines or storage areas.
11.3.3.1- 4.3.3.1 Clothing and hair policy.
11.3.3.8 – 4.3.3.8 Exemptions on Jewelry and other personal effects
11.6.1.5 – 4.6.1.5 Temporary or overflow storage
Finally, under section 4.5.1.1, specific requirements address process water: “adequate supplies of potable water drawn from a known clean source shall be provided for use during processing operations, as an ingredient, and for cleaning the premises and equipment. The source of potable water shall be identified as well as on-site storage (if applicable) and reticulation within the facility.”
As with the SQF Food Manufacturing code, sources of “non-potable water” must be identified, and “a contingency plan shall be in place for instances when the potable water supply is deemed to be contaminated or otherwise inappropriate for use.”
When implementing SQF Pet Food, make sure to download the Audit Checklist from the SQFI website3 to perform a gap assessment. This will allow you to identify which GMP and HACCP programs are currently in place and which elements have yet to be developed and implemented.
References
- US FDA – PET Food
- SQF Pet Food Manufacturing Code
- SQF Checklists, Guidance Documents and Tip Sheets
- International HACCP Alliance Training
Sirocco Food + Wine Consulting provides SQF training and Consulting Services to the Pet Food and Human Food Manufacturing Industries. Our Team of food safety professionals (credentials include PCQI, SQF Practitioner, Certified SQF Consultant and Trainer, Lead HACCP, and Lead FSPCA PCQI Instructor) assist you in the development and implementation of food safety plans, importer plans, and management systems towards certification. Contact us to learn more.