2. February 20091 Implementation of HACCP based own control systems and co-operation with national feed control authorities Dr Brian Cooke Member & past Chairman of the Animal Nutrition Committee of FEFAC (European) and AIC (UK)

3. February 20092 The Principles of HACCP as in Feed Hygiene Regulation 183/2005

4. February 20093 a)Identify any hazards that must be prevented, eliminated or reduced to acceptable levels b)Identify the critical control points at the step or steps at which control is essential to prevent or eliminate a hazard or reduce it to acceptable levels c)Establish critical limits at critical control points which separate acceptability from unacceptability, for the prevention, elimination or reduction of identified hazards d)Establish and implement effective monitoring procedures at critical control points

5. February 20094 e)Establish corrective action when monitoring indicates that a critical control point is not under control f)Establish procedures to verify that the measures outlines in points (a) to (e) are complete and working effectively. Verification procedures shall be carried out regularly g)Establish documents and records commensurate with the nature and size of the feed businesses to demonstrate the effective application of the measures set out in points (a) to (f).

6. February 20095 Customer requirements The compound feed company needs to: 1.Identify the important feed safety and economic requirements of different customer groups 2.Assess whether and how these requirements might be addressed by the company

7. February 20096 Some common customer needs: Productive feeds to ensure efficient and economic animal production Safe feeds to minimise the risk to animal production from contaminants e.g. Salmonella, dioxin, etc. These safe feeds are required to give confidence not only to livestock producers but also to (a)Meat processing industry (b)Dairies (c)Egg packers and ultimately the retail trade and consumer

8. February 20097 Confidence must be earned The company’s management team MUST define and fully support: Safety targets and visions of the company’s operations The company’s objectives for feed safety and quality Targets and objectives which must be documented and monitored

9. February 20098 Targets and Objectives Targets and objectives must be practical, both in planning and implementing the risk management programme, and in communicating risk prevention to all staff -  One example is the prevention of cross contamination HACCP studies, as required by the Feed Hygiene Regulation (EC No.83/2005) and Codex, are essential to control contamination risks.

10. February 20099 What is HACCP? Hazard Analysis Critical Control Point A systematic plan for identifying Hazards to the safety of the products we produce, and introducing Controls at Critical Points in the process to prevent the Hazards from occurring, or reduce the Hazards to below critical limits

11. February 200910 APPLY HACCP  Work on facts  If no facts are available - measure and run trials  If necessary, develop a method  Apply to the mill process

12. February 200911 Steps & Principles of the HACCP System

13. February 200912 Define the Terms of Reference of the HACCP The manufacture of safe animal feedingstuffs Start at the selection of raw materials and end with delivery to farm Consider hazards from microbial & chemical contaminants to both human and animal life and health

14. February 200913 Define the Terms of Reference of the HACCP Prevention of cross contamination between batches of feed Ensure the intended feed is manufactured to the correct formulation Prevention of the contamination of feeds with microbial or chemical contaminants that would  Cause an animal safety or welfare problem  Result in the presence of residues in meat, milk or eggs above the maximum residue limit or other action limit

15. February 200914 Assemble the HACCP Team Team Member Chairman Buyer Product specialist Production operator Engineer Transport planner External assistance Skills Facilitator, HACCP Knowledge of sources of feed materials Animal production Plant operation Plant construction Vehicle operation

16. February 200915 Define the Process  Obtain and check an engineering flow diagram of the feed mill  Divide the process into steps and draw a flow chart – the team will check for hazards at each process step  Describe & understand the production, especially heat treatment and delivery process  List the products made & the feed materials and additives used  List any existing controls designed to prevent contamination

17. February 200916 Typical Post Grind Feed Mill (computerised process control)

18. February 200917 Collect information to identify cross-contamination hazards  Medicine/zootechnical residue analysis of feed  Problem of validation of levels of cross contamination  Microtracers (Microtracer Inc) can be used to mimic action of medicines or other additives  If additive used @ 100 mg/kg, microtracer added @ 100 mg/kg  Gives 2,500,000 particles/tonne = 1250 particles in each 0.5 kg of feed

19. February 200918 500g samples taken at various stages in both spiked and subsequent mixes enables points of loss to be identified and the level (quantity) of carry-over to subsequent mix at each point to be measured.

20. February 200919 Collect Information to Identify Cross Contamination Hazards  Calculate possible contamination in conveyors & elevators. Check screw conveyors, slide pockets & elevator boots  Look inside bins & mixers to check cleanliness on discharge.  Weigh or calculate any remaining residues  Check dispersion in mixer. 10 samples taken at intervals as mixer discharges tested for trace elements

21. February 200920  Check physical characteristics of individual additives, medicines & zootechnical substances, e.g. are they electrostatic? Compare granular products & fine powders  Check contamination at hand tip points. Are residues left in hopper or in filter units? Collect Information to Identify Cross Contamination Hazards

22. February 200921  Check timers on conveyors & elevators. Does one batch clear before the next follows?  Check the weight of sievings returned to following batches Weigh residues from cooler & from sievings that could return to following blended batch. Collect Information to Identify Cross Contamination Hazards

23. February 200922 RESULTS OF HACCP STUDIES A.Dust extraction at tipping point - sulphonamides still present in 20th mix B.Screw conveyors can lead to variable carry over. For instance, a 7m screw conveyor leads to a 0.36% carry over to next mix

24. February 200923 RESULTS OF HACCP STUDIES C.Even with fairly well designed equipment, the first 2 mixes after additive addition are likely to contain more than 1% of the added level of additive D.Traces of additive as shown by microtracers may be present up to 10 batches after the time of addition.

25. February 200924 Analyse Information & Consider Control Measures  First…..  Modify plant & equipment to remove cross contamination hazards where possible. Engineering controls  Design any new equipment & vehicles to minimise cross contamination.

26. February 200925 Analyse Information & Consider Control Measures  Then…..  Consider each process step in turn  Is a control needed at this step to remove contamination or reduce it to below the critical limits?  A control may be:-  A manual procedure  A computer control

27. February 200926 Computer Process Controls  Cross contamination “rules” programmed into process control computer. Cross contamination matrix (CCM)  Prevent harmful cross contamination from a batch into following batch of feed  At mixer & down the press line  Prevention by scheduling or “flushing” plant

28. February 200927 Control Measures Careful production planning to avoid production of sensitive feed for at least 2 batches after additive addition - possibly include flushing Accompany the above by replacement of contaminating equipment such as: screw conveyors, dead areas above slides & base of elevators Install self-cleaning equipment Good maintenance

29. February 200928 Typical Critical Control Points CCP NoProcess StepCritical ControlMonitoring 1Feed material Supplement & Premix Purchase Approved & audited suppliers Supplier analysis data 2FormulationControl level of any returned product Feed residue analysis 3IntakeFlush intake after intake of medicated returned product Feed residue analysis 4Blending & weighing Do not add medicines & zootechnical premixes here Feed residue analysis

30. February 200929 Typical Critical Control Points Batch records Cross Contamination trials Mixer flushed with e.g. wheatfeed, if harmful cross contamination into following batch could occur. Computer controlled Mixer6 Batch records Auditing Cross Contamination trials Maintenance records Premixes tipped or blown into mixer. Batch identification. Inspection of hand tip point and flushing if necessary. Filters shake down into same batch Hand tip point for Premixes 5 MonitoringCritical ControlProcess StepCCP No

31. February 200930 Typical Critical Control Points Manager checks press line schedules Feed residue analysis Production records. Batches scheduled through the plant to prevent harmful cross contamination from one blended batch to to the following batch. Computer controlled e.g. pig finisher feed does not follow pig feed containing sulphamethazine Press lines, coolers, sieves, fats coaters 8 Hygiene audits Routine inspection & cleaning especially if bin is not self cleaning Press bins7 MonitoringCritical ControlProcess StepCCP No

32. February 200931 Typical Critical Control Points Delivery records checked Bins & bin labels checked before delivery Delivery on farm11 AuditingVehicles inspected before loading. Rules on feed that should not be in adjacent compartments Loading vehicles10 Timers checked if plant changed Auditing Self cleaning conveyors installed. Timers set correctly. Bins inspected before re-filling. Route to & from finished product bins 9 MonitoringCritical ControlProcess StepCCP No

33. February 200932 Monitoring the Control Points Control Monitor Are the Controls Working? Improve the controls Yes No Keep records!!

34. February 200933 Conclusion The practical application of HACCP to resolve contamination problems in the feed meal is not only a legal requirement but is an effective tool for the feed compounder to ensure the safety of the feed produced

35. February 200934 Co-operation with national feed control authorities UK Experiences A close working relationship between the authorities and industry can benefit both parties:  Reduced workloads  Reduced costs  Reduced inconvenience  Safer feed

36. February 200935 Close co-operation and exchange of views over pending EU legislation  Reduces costs to industry  Ensures as far as possible that new controls are practical and implemented reasonably easily

37. February 200936 Co-operation over policing – inspection & authorisation or registration  Various EU Regulations require inspection & authorisation or registration  Medicated Feeds Directive, Feed Hygiene Regulation  2 Inspectorates in UK – AMI and Local Authorities (LA). If AMI approved & inspected – automatic LA approval/registration without LA inspection

38. February 200937 Recognition of Industry Codes of Practice Under Regulation 882/2004 on Official Controls, it is stated that these should be carried out regularly on a risk basis and with appropriate frequency.

39. February 200938 In the UK the Agricultural Industries Confederation, the trade association that covers manufacturers of animal feeds, has developed: 1.UFAS the ‘Universal Feed Assurance Scheme’ which incorporates the ‘UFAS Code of Practice for the Manufacture of Safe Compound Animal Feedingstuffs’ 2.FEMAS the ‘Feed Materials Assurance Scheme’ Both are lodged with our Food Standards Agency

40. February 200939 Members of both schemes are independently audited on an annual basis. In recognition of this, the authorities acknowledge that membership of the schemes leads to a reduction in feed safety risks, and thus carry out official inspections of members’ sites on a less frequent basis than of sites of non-members.

41. February 200940 Conclusion Co-operation between the trade and feed control authorities is welcomed by both parties and leads directly to reduced costs of implementation of EU law by all concerned