When you take a look at a packaged food in the United States and compare it to one from Canada, it’s more than just the dual languages that are displayed that make the Canadian market unique from their southern friends. Let’s discuss a few of these not so obvious differences that you need to consider when producing or marketing your product in Canada.
Regulatory Round Up: Insights on the FSMA Rules for Pet Food Safety – Are You Prepared for the Upcoming FDA Facility Inspections?Patrick Kennedy /
How important is pet food safety to the average American? The American Pet Products Association has estimated that 70% of U.S. households own a pet, including more than 100 million households with at least one dog or cat. In recent years, consumer demand for premium and specialty pet food products has fueled a spike in U.S. sales of pet food to nearly $30 billion annually. Due to the growing consumer demands for high-quality pet food and an increasingly complex pet food supply chain, it seems the safety of animal food has never been more important.
To date this year, more than 50 pet food products have been recalled in the U.S. due to food safety issues, including microbial hazards such as Salmonella spp. In recent years, microbial hazards in pet food have become a North American public health issue and the economic adulteration of pet foods has resulted in hundreds of pet food recalls and animal deaths.
Addressing the upward trend in pet food safety issues, the U.S. Food and Drug Administration (FDA) unveiled the final version of its rule, “Current Good Manufacturing Practice and Hazard Analysis and Risk-Based Preventive Controls for Food for Animals,” in 2015. As mandated by the Food Safety Modernization Act (FSMA), the final rule established a new food safety focus applicable to the majority of facilities involved in the manufacturing, processing, packing and holding of animal food. The FDA recently announced plans to launch animal food facility inspections this year to verify compliance with the rule.
Expect Greater Oversight of Pet Food Facilities
For the first time, regulatory compliance dates for the animal food preventive controls are now in effect for all three business sizes (large, small and very small). Effective September 2018, all large animal food businesses should be prepared for routine federal inspections that will scrutinize both Current Good Manufacturing Practices (CGMPs) and preventive controls. Large animal food facilities were required to comply with the preventive controls rule by September 18, 2017, but inspections were delayed as part of the FDA “educate before and while we regulate” approach.
Beginning this year, the FDA has shifted its focus for small and very small businesses to increase the oversight of CGMPs through more routine facility inspections. Small businesses were expected to comply with the new requirements for CGMPs by September 2017. All small animal food businesses were advised to comply with the preventive controls requirements by September 17, 2018. However, the FDA has indicated that routine inspections of small facilities for preventive controls will not occur until 2019 unless a food safety problem triggers a “for cause” inspection of the facility.
During an FDA inspection, large animal food facilities must demonstrate compliance with the hazard analysis and risk-based preventive controls requirements, including the implementation of a food safety plan. Animal food facilities are required to evaluate their operations for hazards (biological, chemical, physical and radiological). Based on the hazard analysis, the food safety plan would address preventive controls (if applicable), monitoring procedures, corrective actions, verification activities, and a recall plan if hazards are reasonably likely to occur.
In January 2018, the FDA issued a draft guidance entitled, “Guidance for Industry #245: Hazard Analysis and Risk-Based Preventive Controls for Food for Animals,” which provides support regarding the food safety plan requirements, recommendations for conducting a hazard analysis, hazards associated with animal food, examples of preventive controls and preventive control management components.
Is a Supply Chain Program Mandatory?
Ensuring the safety of the supply chain is a critical element of the FSMA regulations for Foreign Supplier Verification Programs (FSVP) for Importers as well as the rules for preventive controls.
The animal food preventive controls rule requires manufacturers to develop and implement a risk-based supply chain program if its hazard analysis determines a hazard would require a preventive control and the control would be applied in the facility’s supply chain. A supply chain program is not required in cases when the hazard is controlled within the manufacturer’s facility or controlled by their customer.
If a manufacturer determines that raw materials and other ingredients require a control within their supply chain, then the facility should source such materials from approved suppliers. The regulations permit the use of unapproved suppliers on a temporary basis only if the “raw materials are subject to verification activities before being accepted for use.”
In June 2018, the FDA issued a draft guidance to advise animal food facilities regarding the application of a supply chain program in compliance with the preventive controls rule. The guidance addresses the need for a supply-chain program, and advises facilities regarding the identification and implementation of appropriate supply-chain program activities. Moreover, it provides additional recommendations regarding verification activities, record keeping requirements and applicability of the FSVP rule to animal food importers.
The guidance suggests appropriate supplier verification activities like:
- Onsite audits
- Sampling and testing of raw material(s) or other ingredient(s)
- Review of the supplier’s relevant food safety records, or
- Other appropriate supplier verification activities based on supplier performance and the risk associated with the raw material or other ingredient
According to the draft guidance, animal food facilities should consider three factors when approving suppliers and determining the appropriate supplier verification activities and frequency. Animal food facilities should consider: (1) the hazard analysis of the animal food; (2) the entity or entities that will apply controls for the hazards requiring a supply chain control; and (3) the supplier’s performance related to food safety.
Tools for Managing Your Pet Food Supply Chain
Ensuring the safety of pet food is an evolving regulatory priority. In order to comply with the new FSMA mandates for preventive controls and supplier verification, the animal food industry should capitalize on the value of monitoring their supply chain data.
Supplier audits are one of the most effective tools for ensuring the quality and safety of your ingredients, additives, packaging or services provided by contractors. Accredited auditors can examine your supplier’s organization, food safety management system and the sanitary conditions of their premises, equipment and facilities.
For importers, supplier verification activities could require the onsite auditing of foreign suppliers, sampling and testing of imported food and the review of foreign supplier safety records.
The role of environmental monitoring as a verification measure for preventive controls should not be underestimated. Due to the known biological hazards associated with pet food and animal feed, an environmental monitoring program can verify the effectiveness of sanitation controls designed to control microbial pathogens.
Are you looking for a way to make tracking and analyzing your environmental monitoring data easier? Consider implementing EnviroMap®, Mérieux NutriSciences’ cloud-based environmental monitoring solution, allows food companies to easily schedule, map and track their sampling procedures. Additionally, customizable dashboards give manufacturers the ability to view and analyze their data over time to recognize trends.
Merieux NutriSciences is now offering a professional information research services for a deep search and review of scientific literature and regulatory information.
Information Services Manager, Mérieux NutriSciences
Patrick Kennedy is the Information Services Manager for Mérieux NutriSciences. He has over 15 years of food industry experience and has written extensively covering a wide range of food safety and regulatory subjects. He holds a MS degree in information science from the University of Illinois, and is a member of several industry organizations including AOAC, IFT and IAFP.
You know the routine. You’re sitting at your desk trying to catch up on paperwork when you receive the notice: “Important Meeting in 30 Minutes in the Conference Room. Topic – Last Month’s Butterfat Losses.”
It seems every month you have the same issue – unaccounted losses in your dairy operation. How does it happen?
Losses of product or butterfat can be complicated in today’s dairy operations. There can be physical losses, in the form of leaks and spillage, and losses due to non-conforming products and damaged goods, or there can simply be the lack of properly accounting for the use of ingredients, milk solids, of butterfat.
These losses can be multiplied by improper testing and standardization or by inaccurate accounting of the products. Through overfills and delivery errors, you could have losses of monumental portions before you realize it.
If this sounds familiar to you join us in November for our one-day Dairy Shrink and Loss Course which examines the key attributes that can lead to uncontrolled and unaccounted for losses. In addition to a practical look at how to reduce losses, the course includes a primer on understanding and utilizing the Federal Market Order.
Our dairy shrink and loss course examines the key attributes that can lead to uncontrolled, and even worse, unaccounted for losses. Join Andy Novakovic, Ph.D., of Cornell University, and myself as we take you through Dairy Shrink and Loss.
Date: Wednesday, November 7th, 2018
Time: 8 am – 5 pm
Location: Regus, 5600 North River Road, Suite 800, Rosemont, IL, 60018
- Understand Milk Composition and how it affects loss control
- Identify Loss Hot Spots found in dairies
- Discover how to put together a Fill Control that meets Regulatory requirements but does not promote excessive product giveaway
- Understand how Formulation and Standardization effects product loss
- Explore the basics of The Federal Market Order
Meet the Author
Technical Consultant, Mérieux NutriSciences
Tedd Wittenbrink has more than 30 years of management experience in the food industry. He is an American Society for Quality Certified Quality Auditor and has a proven track record in developing and implementing Food Safety / Quality Assurance Programs. His employment history includes tenures with Beatrice Foods, Hawthorn Mellody Farms Dairy, and Borden Inc. During his career, he has held positions of QC Manager, Director of Quality, and Corporate Quality Assurance Manager.
Although it initially felt like the date may never come, the Food and Drug Administration (FDA) compliance date for the menu labeling regulation went into effect on May 7, 2018. Hooray! Restaurants and food service establishments are now required to add calorie counts to their menus and menu boards. Nutrition information can be found both on the restaurant’s website and within the establishment to provide customers with more transparency on the nutrition information for the menu items they love to eat.
While the regulation only requires restaurants with 20 or more locations to provide nutrition information, that doesn’t mean you can rest on your laurels if you only have 17 locations. Remember that if you’re close to having 20 locations, it is best to start calculating your nutrition information months before your 20th location opens. The menu labeling process can take anywhere from six to eight weeks, on average. If your menu contains more dishes than average, it may take even longer. As you are planning for the future of your business, this is important to consider because you will need to be in compliance with menu labeling regulations once your 20th location opens.
Now that the compliance date for menu labeling has come and gone, the restaurant industry still has questions left unanswered. Am I required to post allergen information? How is the FDA going to enforce menu labeling? Do I need to update my nutrition information? Mérieux NutriSciences reached out to restaurants and food service establishments to gather your burning questions. We selected some of the more popular questions to discuss in our latest vlog, which you can watch below!
Do you still have questions about menu labeling? Join the discussion by leaving a comment below with your question, and a member of our labeling compliance team will respond to you. If you need help complying with menu labeling regulations, Merieux NutriSciences’ Labeling Compliance & Nutrition Services department can help. Our team is dedicated to working with restaurants and food service establishments to comply with menu labeling regulations and meet other needs, such as developing menu items for special diets. Contact us today to get started!
Meet the Author
Sophie Lauer, RD
Associate Nutrition Program Manager, Mérieux NutriSciences
Sophie Lauer is the Associate Nutrition Program Manager at Mérieux NutriSciences. She received her Bachelor of Sciences in Applied Health Science, Dietetics from Indiana University. Sophie received her MBA from Dominican University. In her free time, she enjoys cooking for friends and family as well as playing with her goldendoodle.
Understanding the shelf life of your product plays a critical role in protecting your brand, but the way a food’s “best by” date is determined depends highly on the attributes of your individual product. When a food manufacturer contacts me about running a shelf life study, I typically ask a series of questions to help determine which methods are the most relevant – what is the pH and water activity? How is the product processed and packaged? Is it stored ambient, refrigerated or frozen? If you don’t have answers yet, don’t sweat it! We can walk you through what we need to know.
It’s no secret that Americans are incorporating more plant-based foods into their diet. When you’re grocery shopping, you may notice new plant-based alternatives filling the shelves next to many of the foods or beverages you have commonly purchased over the years. A Nielsen Homescan survey last year found that 39% of Americans are actively trying to eat more plant-based foods while the number of vegans in the U.S. is also growing. Additionally, Mintel found that U.S. consumers are actually choosing plant-based proteins primarily because of taste. Continue Reading
In a previous blog post, we detailed the regulation for the labeling of genetically modified organisms (GMOs) and bioengineered (BE) foods under the new National Bioengineered Food Disclosure Standard (NBFDS) in the United States. You may think that the terms of the law are black and white – if a GMO is present in your product, you need to declare its presence on your food label under new regulations. However, as with most things in life, there is a distinct grey area. To uncomplicate the regulations, we put together a guide to understanding the GMO labeling guidelines and the exemptions that may apply to your products. Continue Reading
Regulatory Round-Up: Are Warning Labels for Chemicals in Foods Based on the “Best Available Science?”Patrick Kennedy /
The potential risk of unsafe chemicals in foods has generated significant attention on social media in recent years due to growing consumer demands for “clean food” and food safety. Within the United States, the infamous Proposition 65 law in California is responsible for the majority of warning labeling requirements for chemical contaminants, but there has been an upward trend in state legislative proposals related to the risk of certain chemicals in consumer products. In response to this trend, several major food industry associations have joined forces to support a new federal bill titled the Accurate Labels Act, which seeks to impose more stringent scientific criteria for warning labels related to chemicals. If the bill becomes law, it could supersede or undermine the various state labeling requirements for chemical contaminants if the state rules are not grounded in the “best available science.” Continue Reading