A proposed rule to regulate the production of food for animals was released last month by the FDA. The rule, promulgated under the Food Safety Modernization Act, for the first time proposes current good manufacturing practices (CGMPs) and preventive controls specifically addressed to animal food.
The proposed rule, titled “Current Good Manufacturing Practice and Hazard Analysis and Risk-Based Preventive Controls for Food for Animals,” was published in the Federal Register on Oct. 29 and is open for public comment until Feb. 26. It follows the FDA’s proposed rule for human food, published in January and with a comment period closing on Nov. 15th.
“The new proposed rule overall is strikingly similar, appropriately, to the proposed preventive controls rule for human food,” says Jennifer McEntire, PhD, vice president and chief science officer for The Acheson Group, a food industry consulting firm in Washington, D.C., and a member of the Food Quality & Safety Editorial Advisory Panel. “There are some nuances. One of them is that, although this rule would govern food for animals, when assessing the risks, the facility would also have to look at the risk to humans.”
The potential risks to humans from animal feed could include consumer contact with pet food, as well as workers’ contact with animal food ingredients or products in the manufacturing setting, she points out.
“In addition, in the case of farm animals that eat this food and then become human food, there are potential risks from any contaminants in the animal feed that could pose a threat to the humans who then consume the meat or milk from the animal,” Dr. McEntire says.
The preventive controls in the proposed regulations would apply to domestic and imported animal food, including pet food, animal feed, and raw materials and ingredients. The CGMPs, while similar to the proposed human food CGMPs, are not identical; they do not address certain practices that do not pertain to animal food, such as allergen cross-contact, according to the FDA.
Dr. McEntire notes that some industry representatives have expressed a desire for clarity regarding the production of food originally intended for human consumption, but with byproducts that are purposed for animal feed.
“Some facilities could be manufacturing human food, but if they have a stream that’s going to be diverted to animal food, then there are questions about what standards would apply, from a regulatory perspective, to that food waste,” she says. “The FDA has tried to address this issue in the proposed rule, but there is still confusion.”