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Should petfood manufacturers regularly test their finished products for Salmonella, holding them in inventory until test results return? And should that testing be mandated by the Food and Drug Administration (FDA) as part of the new preventive control rule for feed soon to be released under the Food Safety Modernization Act (FSMA)?
At this weekâ€™s 2013 Feed and Pet Food Joint Conference, held September 24-26 in Indianapolis, Indiana, USA, these questions were among the most debated and discussed of all issues, elements and challenges of the upcoming rule. The conference was presented by the Pet Food Institute and National Grain & Feed Association.
The preventive controls rule for feed (which will also cover petfood) is due to be released for comment by FDA no later than November 30. Dan McChesney, PhD, director of the Office of Surveillance and Compliance for FDAâ€™s Center for Veterinary Medicine and a speaker at the conference, said he expected the rule to be out before that deadline and that it will be similar to one already released for preventive controls in human food.
But one key difference between how FDA is looking at petfood vs. human food lies in Salmonella contamination; for petfood, the agency, under FSMA, now has a zero tolerance for the bacteria. That has caused many petfood companies, especially larger manufacturers, to include finished products in their Salmonella testing programs. This comes at a huge expense because it means holding the related lots of product in inventory until test results come back.
At Petfood Insights: New Approaches to Quality & Technology, a symposium hosted by Kemin just two weeks before (September 10-11), several petfood executives said holding finished product inventory while waiting for test results had become the largest petfood safety related expense for their companies â€“ even for those that have invested heavily in infrastructure, equipment, personnel and training to fortify their safety systems. During the joint petfood and feed conference, Jill Franks, director of scientific and regulatory affairs for Mars Petcare US, agreed: â€œItâ€™s very expensive for us to hold that product to wait on testing.â€
Yet Franks said Mars is very supportive of finished product testing and sees it as the final step of a risk-based preventive controls safety system, adding that it is a way to verify the system is working. She stated her companyâ€™s position as part of a panel discussion on the upcoming FSMA preventive control rule. One of her fellow panel members, Jan Campbell, manager of regulatory affairs for Land Oâ€™Lakes Purina Animal Nutrition, took the opposite position â€“ though the fact that her company produces feed rather than petfood made it somewhat of an apples to oranges comparison.
Another panel member, Jason Vickers, section head of global product stewardship for P&G Pet Care, added that the industry has already had a lot of debate over whether finished product testing should be required under FSMA. â€œWeâ€™re still debating, but the general thought now is that it should not be a requirement but up to individual companies,â€ he said. â€œIndustry supports it but not as a mandate.â€
That word, â€œsupport,â€ came up often during the discussion. In response to a direct question about whether she believed this should be a mandate, Franks again said, carefully, that she and Mars â€œsupportâ€ finished product testing at this point and reiterated that Mars does it as part of its overall facility risk-based program. In other words, she evaded answering.
Perhaps the person whose words matter most â€“ McChesney â€“ didnâ€™t really provide a definitive answer, either. He described it as beneficial because it can verify that control of hazards is effective. Yet when he posed the question himself â€“ whether it should be mandatory â€“ his answer was â€œit might depend on the type of product and hazard.â€
I took that as a sign that FDA is open to the industryâ€™s comments and feedback on this issue, as well as other elements of the new preventive control rule. So, get ready: Once the rule is released, youâ€™ll have at least six months to provide those comments.