Food safety in the US seems to have taken a big step last month with passage of S. 510, also called the Food Safety Modernization Act of 2010, which will also affect regulation of petfood. (Whether the step taken is forward or backward depends on your point of view regarding the bill and, possibly, legislation in general.)
At press time, 10 days before the end of the year, the law had just been passed by the lame duck US Congress: first by the Senate in a Sunday night surprise, then by the House of Representatives two days later. It was expected to be signed by President Obama soon after.The bill endured a roller coaster ride of more than a year-the House originally passed an initial version in July 2009-that included a different version being passed by the Senate in early December 2010, only to be held up a day later by a procedural snafu, followed by debate over controversional amendments and threats of filibusters. Even by US legislative standards, it was a rather torturous path.
Still,passage had seemed nearly inevitable, and all along the bill has generated quite a bit of praise but also criticism. Even proponents are expressing concern about what the nitty-gritty details will look like once regulators start working with it.
This concern spreads to petfood. In fact, many people in our industry have already been voicing real and legitimate apprehension about what the new law will mean for petfood manufacturers, especially smaller companies that don't have the resources or economy of scale to absorb the higher costs of meeting new regulations.
But the good news for our industry is that most players-manufacturers, suppliers and regulators-have been anticipating the impending new regulations for well over a year. If you've attended any industry or related events over the past six months or so, you've likely heard experts and regulators such as Dan McChesney, PhD, director of the Office of Surveillance and Compliance for the US Food and Drug Administration's (FDA) Center for Veterinary Medicine, explaining what's likely to happen.
Sowhat is that? For one, the bill will require that companies currently registered as food producers under the Bioterrorism Act-and that includes petfood producers-register with FDA and create written, risk-based hazard control programs. If you already have, use and thoroughly document within a HACCP (hazard analysis and critical control points) program or current GMPs (good manufacturing practices), you're probably in good shape.
If not, you would do well to start creating such a program soon. Extru-Tech Inc. has some good tips and suggestions in the latest issue of its e-newsletter,The Extru-Technician.
Also, please watch upcoming issues and PetfoodIndustry.com for helpful articles on developing HACCP and other risk-based programs. (You can find information and a checklist now here.) You might also want to plan on attending Petfood Workshop: Safety First, April 13-14, where you can learn from experts about the new regulatory landscape, how to set up a HACCP program and prepare for an FDA inspection and much more.
In this issue, you'll find an articleon how to determine and validate a kill step for toxins such as Salmonella. While this is just one aspect of a safety program, having it in place will help assure regulators-as well as customers-that you're producing safe, healthy products.