Years ago, I was in a production facility, and a worker threw some trash into a barrel of product destined for a local pig farmer. The worker thought his actions were acceptable because of the common belief that pigs eat anything.
Over the years, many production facilities have taken products and by-products failing to meet finished product specifications and have sold them to “pig farmers” or other animal food companies. As I witnessed, sometimes employees would throw foreign material into the “pig food” or “animal food” container. Often, this product would be offered for “free” to farmers, as long as they picked it up frequently. Commonly, these containers on the back dock or in a walk-in refrigerator would not be labeled. Workers would throw trash in them because they were not trained about the risk of mixing trash with potential animal feed.
These actions can be explained by a lack of understanding that the animals being fed from these bins could potentially become a source of human food in the future. Any “thrown in” hazards could make it through the entire food chain, from inside animals, such as pigs, cattle, chickens, turkeys or other farm animals, to our food through meats or other animal products, such as milk or eggs. A new regulation addresses this as part of the new Food Safety Modernization Act (the new cGMPs part 117.95): Holding and distribution of human food by-products for use as animal food.
The first requirement in this new cGMP states, “Human food by-products held for distribution as animal food without additional manufacturing or processing by the human food processor must be held under conditions that will protect against contamination.” This means that any items going to animal food must have dedicated containers, be properly labeled and be protected against further contamination.
The law further focuses specifically on the containers and equipment used to store the by-products meant for animal consumption. According to the law, it “must be designed, constructed of appropriate material, cleaned as necessary, and maintained.” This details the maintenance and safety of those containers to make sure the food is not contaminated before it leaves the facility.
Additionally, the new regulation specifies that any container used to transport the product must be examined prior to use to ensure contamination will not occur during transportation. This applies to a variety of transportation containers, such as a tote, drum, and bulk loads like a tanker. Manufacturers must protect these items while at their facility and should work with any transportation companies to ensure the protection extends through the transportation of those items.
The bottom line is federal law now requires we protect all products designated as animal food or pet food because of the potential for it to end up in our food. I personally would not want to pick up a ham sandwich and take a bite out of it to see glass pieces in the ham that originally came from the barrel of by-product. Would you?
Meet the Author
Technical Consultant, Mérieux NutriSciences
Jeff Strout is a food safety trainer and consultant with extensive food industry experience as an auditor. Jeff educates on current and relevant topics and provides insight to the entire food industry for SQF, BRC, Food Defense, HACCP, Seafood HACCP as well as other areas of food safety and regulatory compliance.