At the onset of the ongoing COVID-19 pandemic in the United States, the U.S. Food and Drug Administration halted routine inspections to focus only on those defined as mission critical by the agency. For pet food producers, this included inspections triggered when FDA reasonably believed that a facility had serious pet food manufacturing problems or to investigate a specific problem or pet food complaint that came to FDA’s attention. From March through September 2020, FDA conducted seven mission-critical inspections of animal food facilities. Between October 2020 and March 2021, the agency conducted a further 19.
Tier 1: Mission Critical
Agency crisis or emergency response, for-cause work
Other mission-critical special assignment
Tier 2: Higher Priority
For-cause but not considered mission critical
High-priority and high-risk inspection and sampling
Tier 3: Lower priority
Routine-surveillance, including non-high-risk inspection and sampling assignment
After the initial response, FDA resumed prioritized pet food facility inspections. From March through September 2020, FDA conducted 13 prioritized inspections of animal food facilities. Between October 2020 and March 2021, the agency conducted only 4.
FDA plan to resume pet food facility inspections
FDA released a report on their inspection activity during the pandemic, “Resiliency Roadmap for FDA Inspectional Oversight,” with projections for a return to normal pet food facility inspection routines.
Future inspections will depend on how the pandemic continues to play out in the US. The FDA developed three scenarios for resuming operations: worst, base and best. In the basic scenario, FDA will continue to use the COVID-19 Advisory Level to assess all geographic surveillance inspection capabilities until full transition to standard operations in July 2021. The COVID-19 Advisory Level uses real-time data to qualitatively assess the number of COVID-19 cases in a local area based on state and national data
FSMA-mandated human and animal food surveillance inspections constitute the majority of surveillance inspections to be conducted.
Base scenario timeline:
- May 2021 - July 2021: FDA uses the COVID-19 Advisory Level to focus on mission-critical and prioritized domestic inspections.
- July 2021 - September 2021: FDA resumes standard operations.
- No travel or establishment access restrictions.
- Current investigators are available to conduct inspections.
- Suspend use of the COVID-19 Advisory Level.
- COVID-19 staff administrative leave levels remain constant through the end of fiscal year.
