The Food and Drug Administration (FDA) and its state partners inspected 100 pet food facilities in the agency’s fiscal year (FY) 2022, and while those conducted by state agencies overwhelmingly returned findings of “no actions indicated” (NAI), the inspections conducted by FDA itself yielded more significant findings.
That is mainly because, if FDA is inspecting a facility, it’s due to a “for cause” situation in which a consumer or other complaint led the agency to believe a safety issue was present in the facility, warranting an immediate inspection.
These data and insights came from Jenny Murphy, deputy director for foods at FDA’s Center for Veterinary Medicine Office of Surveillance and Compliance. She presented as part of the American Feed Industry Association’s 2023 Pet Food Conference on January 24, 2023, during the International Production & Processing Expo in Atlanta, Georgia, USA.
Three top pet food safety observations
Murphy explained that the pet food facilities inspected during FY 2022 included not only plants manufacturing pet foods and treats but also ones manufacturing or preparing pet food ingredients, as well as warehouses and similar storage facilities. FDA inspected 35 such facilities and found that 22, or 62.9%, had “voluntary action indicated” (VAI) findings, meaning the company could choose whether to take the indicated actions. Nine facilities, however, or 25.7%, had “official action indicated” (OAI) findings, which means FDA mandated changes and actions.
At the state level, partner agencies conducted 65 inspections of pet food facilities, the majority of which (62, or 95%) had NAI findings. Only 3 (5%) had VAI findings, and none had OAI findings.
Of the issues found, three categories stood out as top food safety observations, Murphy said: hazard analysis (under federal code 21 CFR 507.33), preventive controls [21 CFR 507.34(a)(1)] and sanitation controls [CFR 507.34(c)(2)].
FSMA inspections: The total picture
Murphy presented the data under an umbrella of “FSMA metrics”—data that FDA collects through its enforcement of the Food Safety Modernization Act, which regulates human food in addition to animal foods. In terms of total FSMA inspections, FDA and states conducted 458 in FY 2022 to review compliance to current good manufacturing practices (CGMP) regulations and another 458 for preventive controls (PC) compliance.
The majority, or 90.9%, of CGMP inspections yielded NAI findings, which nearly matched the NAI findings for historical CGMP inspections, or ones that FDA has conducted since FY 2017, after FSMA regulations began going into effect. That total is 3,261, with the number of CGMP inspections peaking in 2019 at 953, when CMGP regulations came under full enforcement. The number of inspections have since fallen, also due to the COVID-19 pandemic.
Of the 458 PC inspections by FDA and state agencies in FY 2022, the portion of VAI findings was higher than for CGMP compliance, reaching 19.7%; 2.4% of PC inspections had OAI findings. As with CGMP inspections, PC inspections with NAI findings (77.9%) were close to historical totals (75.4%). The difference is that PC inspections under FSMA did not begin until FY 2019, so fewer in total (967) have been conducted. The numbers started climbing in FY 2021 and into 2022 as pandemic restrictions started to ease.
In addition, while the historical data for CGMP inspections shows no OAI findings, the data for PC inspections indicates 3.4% for those and 21.5% for VAI findings.