1. Current Topics – Perfect Storm
Current Topics – Perfect Storm? March 4, 2017 PCRA Meeting Carmel Valley, CA

2. Food Safety Modernization Act
FSMA Basics
Food Safety Modernization Act
We make Animal Food according to FSMA.
FSMA defines Animal Food as:
“Food for animals other than man and includes pet food, animal feed, and raw materials and ingredients.”

3. Perfect Storm Brewing for Rendering?
Export requirements dictated by importing country
Trends:
No By-Product
All Veg diets
Food Waste
Perfect Storm Brewing for Rendering?
FSMA
FDA Ingredient Review
AAFCO definitions & inspections
The point is… FSMA is not the only issue that is changing our business.

4. More markets for US products needed
Export Issues
More markets for US products needed
Ruminant MBM continues to be banned in key markets, such as Mexico
Indonesia & APHIS approval needed
China – documentation burdensome and invasive
Antibiotic residue-free
Occurrence of reportable animal diseases
FSMA – retaliation
Foreign Supplier Verification Program?

5. Trends May be driven by marketing Counterintuitive
Sustainability is a trend but many marketing strategies conflict with sustainability
Shape consumer perception while ignoring science/nutrition
No By-Products in Pet Food
All vegetarian diets fed to poultry and swine
“Feather meal” from poultry fed no ruminant proteins
4D/3D-free animal proteins and fats
Repercussions from law suits over marketing claims
PCR testing to show purity or exclusions
Sensitive – need to have tolerance
Veterinarians not understanding process controls
Assume rendered products spread disease without facts to support assumptions
Reduce material going to land fills

6. The Pack is not always headed in the right direction

7. Some trends don’t make sense

8. FDA Ingredient Review Verify safety of approved ingredients
May require New Animal Feed Application
Want label transparency
Buyer needs to know what he is buying
Focus on adulteration – product safety and economic
Driving AAFCO definitions
Redefined animal fats
Deleted Fat product Feed grade
Modified Animal Fat definition
Tallow = Beef fat
White Grease = Pork Fat
Used Cooking Oil
Yellow Grease (Animal Fat + UCO)
Trap Grease prohibited in animal feed
Protein meals????
Opportunities???

9. Animal Food Safety Plan Required by FSMA Is More Than HACCP – Now HARPC
Hazard Analysis
Preventive Controls
Personnel hygiene & training
Plant Ops, maintenance & grounds
Holding & distribution
Processes & controls
Equipment & utensils design, use & maintenance
Holding & distribution of human food for animal food
CGMP
Food Safety Plan
Recall
Plan
Process
Control
Other
Controls
Supplier Programs
Sanitation
Control
Other Controls are CGMPs & Other Prerequisite Programs required to make safe animal food.
CGMP – Current Good Manufacturing Practice

10. FSMA NRA doing good job helping industry prepare New Acronyms
CGMP – Current Good Manufacturing Practices
FSP – Food Safety Plan
PC – Preventive Controls
QI – Qualified Individuals
PCQI – Preventive Control Qualified Individuals
HA - Hazard Analysis
RA – Risk Assessment
HARPC – Hazard Analysis Risk-Based Preventive Controls
How will customers react when we cannot guarantee salmonella free?
§ Disclosure in shipping documents that the animal food is “not processed to control [identified hazard]”
Requirement to obtain written assurance that customer has procedures to minimize or prevent the identified hazard delayed.

11. AAFCO Definitions and Inspections
AAFCO feed definitions
Process flawed
Does not follow rulemaking process
Consensus (influenced by FDA) driven
Lack scientific or nutritional basis
“By-Product” label
Poultry Meal
Not superior to Poultry By-Product Meal except on perception & price
Some in pet food industry hope NRA will drive revising definitions for animal proteins
i.e. byproducts are OK
States adopting FSMA regulations

12. What do these threats have in common?
All require greater assurance of:
Transparency
Traceability
Product safety
Controls over process & RM
Disease control
Awareness of what rendering does

13. Industry Issues to Address
Potential changes in FDA compliance policy
3D and 4D material
Driven by pentobarbital recall of dog food.
FD&C Act does not permit in animal food
FDA uses regulatory discretion to allow if processed with heat
Driver may be controlling chemical rather than microbial hazards
CVM or DO approval required before diverting adulterated human food to animal food
USDA relies on rendering to address condemned/recalled/contaminated meat
Would Hazard Analysis and Risk Assessment identify these as hazards requiring a preventive control?
With FSMA, are changes in policy warranted?
Food Waste reduction legislation – Federal and state

14. Fixes?
NRA lead coalition to fix inaccurate or misleading ingredient definitions/names
Encourage FDA to allow certain raw materials and/or adulterated human foods to be used in animal feed with evidence an appropriate food safety plan is in place.
Delay requirement for disclosing hazards not controlled until certification that customer is able to control the hazard is required.
Target industry compliance to FSMA to meet or exceed level achieved for BSE
Industry standards for facility biosecurity to reduce chance of spreading animal disease from the rendering plant to feed mills/customers.
Educate legislature that meat and UCO waste is not a part of the food waste issue.