The FDA regulates each can of cat food, bag of dog food, and animal treat in your pantry. These foods are regulated just as any other animal feeds available in the U.S. The Federal Food Drug and Cosmetic Act requires pet foods to be safe to eat, produced under sanitary conditions, contain no harmful substances, and be correctly labeled. Additionally, canned products must be processed in conformance with low-acid canned food regulations to ensure they are free of viable microorganisms. [21 Code of Federal Regulations (CFR) Part 113].
Pet food sales in 2011 reached $80 billion. This, coupled with a growing rate of pet ownership in the U.S., creates a significant number of people in contact with these products on a daily basis. One question often asked is: “Besides pets, who is the second most common consumer of pet food?” Most tend to respond that the elderly consume a portion of this food. In actuality, toddlers who have no inhibitions about what they place in their mouths tend to ingest pet food far more often. The food for the family pet is normally stored on the floor for the pet to access. A child crawling on the floor has instant access to Rover’s interesting treats.
The role of the family pet has changed significantly over the years. What once was a yard dog to alert the family to intruders or protect farm animals from predators has transitioned to a companion with a strong bond with its owner. Pets play an important and often therapeutic role in helping people through trying times as loyal and forgiving companions. Emotional attachments run deep between people and the animals they love. Any abrupt separation has ramifications.
The pet food industry faces a number of challenges as it strives to meet current regulatory and customer expectations. The industry, plant personnel, and some in the supply chain still view pet food as just animal feed. Attempting to meet the current challenges is expensive and requires a level of commitment that many manufacturers have embraced, while others continue to face the handicaps of the past.
Pet food industry leaders deserve credit for taking the lead on several fronts by funding research to improve product packaging, making it less attractive to insects and extending shelf life. When microbiological issues became a focus in dry food processing, this industry was one of the leaders in looking at strategies and technologies to provide better control and reduce issues. New facilities have been built with significant regard for new technologies to reduce the threats to food product integrity that most food plants face. Improved air filtration, moisture control, system integrity, and supply chain management are a few areas they have diligently worked to improve.
Since pet food is often the sole dietary intake for many animals, these manufacturers are in a different category than most food manufacturers. Not only must they comply with all GMP provisions, they also are classified as nutraceutical manufacturers with another set of challenges. Where one ingredient may be used as a binder to keep ingredients together, the same ingredient may have health effects, and its presence may trigger health claims that render the finished product subject to other regulatory compliance issues. Imagine the challenges of a company using what they believe to be a functional ingredient only to have its use interpreted as a dietary supplement requiring additional regulatory oversight.
Changes to overcome these challenges will take time, commitment, and education to make all in the process understand that product safety is non-negotiable. Investments are being undertaken to improve the structure of many manufacturing facilities. These will be beneficial, but can be nullified unless the people issues are also restructured.
We can physically segregate pre-kill from post-kill processes by using barriers such as walls and doors over openings. But, what will this achieve if an employee transports raw materials or themselves through these spaces with no regard to barrier segregation? How do we essentially reprogram their awareness of these new requirements after years of working in the plants without regard for them?
Educate them. Provide these otherwise great employees with an understandable and justifiable reason why they need to change and become more aware of these changes. After all, haven’t they spent the last 10 to 20 years in the facility being told what to do, making it a requirement at the cost of their employment? When was the last time someone actually explained the reasoning behind the policies or procedures in a way that they saw a value to themselves and the company?
Many of these changes will affect several aspects of a plant’s operation. Moving materials to where they will be needed will take some time to get used to. Changes in cleaning procedures will cause many disruptions and eat up time until all the kinks are worked out. Testing and verifications will likely cause problems not before realized. Transitions to become fully compliant with new regulations or accepted practice take time, and bumps in the road should be expected.
Just as with every challenge we face in the food industry, experience has taught us that the best route is education of all involved, regardless of the positions they hold in the organization. Understanding the needs and successful approaches has always yielded the best long-term results.
The author is Head of Food Safety Education, AIB International.