During a recent Ask the Petfood Pro chat, Will Henry, owner of Turkey Creek Holdings and a 30-year veteran of pet food manufacturing, outlined the core components of an effective food safety system, and where even well-documented programs tend to break down on the plant floor.
During the session, "Ramparts of a Strong Food Safety System," Henry drew on decades of hands-on experience to offer practical guidance for pet food manufacturers and processors. His recurring themes: the importance of people, the necessity of science-based procedures, and the dangers of complacency when processes or ingredients change.
Here are the top 10 takeaways from Ask the Petfood Pro | Ramparts of a Strong Food Safety System:
1. Your people are the foundation of any food safety system. No program, however well-designed, will perform without the right team behind it.
"If you've got a group that care about what they do, they care about the quality of the work they provide — that's going to make or break any kind of good program you could have," Henry said. "The best SOPs, the right research involved — but if you don't have the right technicians and team on staff to execute for you, it's not going to perform at the level that it should."
2. Food safety is not a one-and-done exercise. Systems require continuous review and cannot be treated as static documents.
"Food safety systems — it's not a one and done execution," Henry said. "You don't review it once, you don't look at the science once. It's a constant effort to make sure you've got the right solution moving forward."
He recommends a minimum annual review of the entire system, with additional reviews triggered by any changes to equipment, process flow or formulation.
3. Changes to equipment or facility structure introduce serious pathogen risk. Two of the most common reasons Henry said he is called in to address food safety hazards are structural modifications and equipment replacements.
"Anytime you break into an existing structure, whether it's a support wall, a breezeway, you always run the risk of coming across a previously hidden harboring point for pathogens," he said.
He recommends pre- and post-sanitization of all demo areas and strict zone protocols for contractors and maintenance crews.
4. Rising protein inclusion rates may outpace existing validated kill steps. As premium pet food formulations shift toward higher fresh meat and meat meal inclusions, manufacturers must reassess whether their preventive controls are still sufficient.
"If you only evaluate your process at five log — the bare minimum — yet you have a seven log inoculation for whatever reason, then you're going to end up with a measurable amount of pathogens that will survive," Henry said.
Validation studies conducted when inclusion rates were lower may no longer adequately reflect current formulation risk.
5. Internal challenge studies are essential to bridging the lab-to-plant gap. Because no pilot plant or biosafety lab can replicate a full-scale commercial extruder, manufacturers must conduct their own internal challenge studies to establish a valid correlation between small-scale validation data and large-scale production.
"Your job as a manufacturer, once you decide to use that study, is you've got to draw the line that says — what they did here in the lab, there's a direct linear correlation to what I'm doing with my large bore machine," Henry said. "The only way we can do that is with these internal challenge studies."
He noted that such studies allow manufacturers to document empirical data — on time, pressure, moisture and more — proving the small-machine process mirrors the large-machine process.
6. Preventive controls must never be compromised for throughput. When production demands push against food safety constraints, the controls come first — always.
"Your preventive controls should never be mitigated to support or enhance production and labor issues," Henry said. "Once you start mitigating your PCs, that's when you start seeing gaps in your food safety."
He recommends addressing throughput challenges through offline research and process improvements, such as preconditioner paddle configuration, shaft speed or ingredient substitutions, rather than adjusting critical control parameters.
7. Objective outside perspective is critical for risk assessment. Internal teams naturally become blind to gaps in their own facilities.
"To get a truly objective perspective, you've got to bring somebody in from the outside," Henry said. "A lot of times from an internal standpoint alone, you're not going to gain that objectivity."
He pointed to external accreditation bodies, including SQF, AIB, BRC and ISO, as well as private consulting groups as valuable resources for identifying vulnerabilities.
8. Management must model the food safety culture they expect from staff. Culture flows from the top, and inconsistency between management behavior and plant-floor expectations undermines the entire program, reminded Henry.
"If I go into a plant and I see the QA technicians wearing their gloves, they've got all their PPE on, then I see a manager walking in without a beard net, that tells me there's a breakdown between the culture of who's on the plant floor and who's managing," Henry said.
9. Training programs should be simple, accessible and continuously updated. The easier a training system is to use, the more likely employees are to actually engage with it. Henry cited dedicated on-site media centers, where operators can swipe in, access their training queue, and receive automatic alerts when an SOP is updated, as a best-in-class model.
"That showed a level of investment and dedication from management," he said.
He also emphasized that hands-on training must complement any digital or classroom instruction.
10. Supplier verification and ingredient consistency are non-negotiable. Even a commodity ingredient like wheat can introduce process variability if sourced from multiple regions, affecting everything from bulk density to extrusion behavior to pathogen load.
"As a manufacturer, you cannot waiver on the COAs for ingredients — you just can't," Henry said. He recommends annual supplier audits, transparent communication about sourcing changes, and clear requirements for region-specific sourcing where formulation consistency demands it.
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