Food Safety: A Business Imperative for the
Rendering Industry

By Don A. Franco, DVM, MPH, The Franco Foundation

The media continues to be replete with reports highlighting problems with the food chain in the United States. Some editorials in recent months have suggested that the current food safety system has failed at protecting consumers, and is itself at risk. Critics and consumer advocates have referenced a U.S. Government Accountability Office (GAO) report that indicts the current federal food inspection system by selectively quoting from the report, which states in part: “The current fragmented federal system has caused inconsistent oversight, ineffective coordination, and inefficient use of resources…to help ensure the rapid detection and response to any accidental or deliberate contamination of food before public health and safety is compromised.”

The concerns expressed by GAO are historically the worst-case scenario, a tradition of the “office.” Nonetheless, the published findings of GAO become a part of the public record and is used by Congress as agents of change to institute corrective measures and establish modifications (regulatory or policy) to preclude recurrences of embarrassing headlines that accentuate failures in food safety and consumer protection. Additionally, government-type reports, GAO or otherwise, provide consumer advocates fuel for criticism and rationale for some of their proposed reforms. This clearly demonstrates the attributes of transparency practiced by the United States and Canada, providing both critics and supporters of programs open windows of expression to heighten the debate regarding the varied perspectives of food safety in both countries. In the interim, the public remains concerned, and at times alarmed, often feeling poorly informed and confused by the myriad of issues that surface and contribute to what appears to be a continuum of distinct challenges to food safety.

The central theme of concern has always been described as the threat to public health. This tends to be difficult to define, mostly overblown, and seldom or never in consideration of the protective measures taken by the industry or regulatory agencies to mitigate or prevent harm to consumers once the “hazard” has been identified. This is a situation clearly understood by the food producing industry, consumer advocates, and others directly or indirectly involved with food, including the technical and professional staffs of agencies and politicians.

The process has become predominantly political in the last two decades. It is part of the reality of the existing world of food safety politics, and the competing pressures to influence change in policies and regulations. It is contentious and entails the promotion of agendas by special interest groups to see that their inherent biases are amplified, whether or not the supporting science exists to validate or affirm their positions. That does not necessarily mean that some of the expressed concerns about food safety are without foundation, but it also shows that some groups have become so emotionally trapped by the entire realm of safety that most often they have no patience to examine the nuanced science of risk that is so fundamental to objectivity, and a pre-requisite for making sound decisions. This often results in emotion ruling reason and a resulting inability to attain consensus. This is unfortunate. Food safety becomes a successful venture when forces work with a common agenda and in unison, with respect for diverse opinions.

In like manner, the food-producing industry must continue to pursue the transparency that has evolved over the past two decades or so, and keep the public informed of the many programs instituted over the years to ensure a safe food supply. Some regimens, like hazard analysis and critical control point (HACCP) programs, were mandated by government, but most sectors of the food chain have implemented voluntary prevention and control measures that heighten safety, incurring great cost in the process without a regulatory requirement. Fortunately, experience has affirmed that the incorporation of safety measures in food production always seems to result in long-term benefits that outweigh the cost. Thus, the proactive approach has added value for the rendering industry.

Early in my association with the rendering industry, I reminded renderers that they produce food. Doubtless, some continue to think of their production in terms of feed ingredients/supplements that go into livestock, poultry, aquaculture, and pet food. Accepted that this is true, it is also the minority thinking in today’s rendering cohort.

According to law and regulation, the rendering industry produces food and is subjected to the Food and Drug Administration’s (FDA’s) expanded meaning of adulteration in 1967, which states that articles used in food for animals are included within the definition of food in Section 201(f) of the Federal Food, Drug, and Cosmetic Act. Therefore, aspects of adulteration and contamination of rendered products are treated in like manner as human food – under the law. This must be fully appreciated by the rendering industry when agents of government intervene to investigate or perform audits.

The law is clear and stringent. Fortunately, the rendering industry, based on official government audits, has a compliance record that should be the envy of the food industry, averaging during the last decade evaluations in the 95-plus percentage compliance range. Bilateral communication between the industry and FDA assuring compliance contributed to the success. Renderers also recognized that the cost of non-compliance came at a price that they were not prepared to pay.

Aspects/Concepts of Food Safety Assurance
The rendering industry’s primary function is to produce and sell safe products through operating systems to make money and stay in business. This objective recognizes that each company has ownership over production, with the responsibility for proper maintenance and controls over and above regulatory requirements imposed by government. This does not differ from any other sector of food production. In essence, each company has the sole function to manage and control any potential product safety failures. Therefore, every rendering company must have in place the following:

The aforementioned five major assurances/objectives can be accomplished through:

The Role of the Chief Operational Officer:

Recommendations to Creating a Record Keeping Program to Validate Company Controls:

Government/Industry Communications
Government has the mandate to formulate policies and establish regulations to ensure a safe food chain. In both the United States and Canada, affected industries are provided opportunities to communicate concerns with government officials during agreed-upon meetings or in writing. Quite often, good faith disagreements occur during policy and regulatory discussions. These could add value to the debate, if sincerity and professionalism is central to the differences, with both sides making concerted efforts to assure that mutual respect predominates while providing insightful information to resolve the major issues in contention.

Trust and respect is an important element in these discourses. This is best accomplished when both sides prepare thoroughly for discussions and present solutions and options for consideration with rationale and logic. The industry would be well-served, when it is applicable, to bring a short position paper and considerate recommendations to government officials for assessment, especially in the early stages of any potential regulatory process.

Agreement is not an absolute. What is necessary, however, is a fair and thorough overview of the subject, and a professional point-counterpoint of differences when they occur, with maturity and civil decorum, accepting that the industry has definite rights, and the government the responsibility and accountability to ensure safety to protect animal and human health. Not surprisingly, most often, differences can be resolved at a technical level, resulting in the evolution of mutually agreed-upon solutions. This is best accomplished in a business-like atmosphere, already alluded to, where everyone involved is intent to contribute objectively to the debate, recognizing and respecting each other’s viewpoint and perspective. The rendering industry is well represented by a professional association staff that fully understands these attributes during discussions with government agencies.

The correlation linking food safety as a business imperative for the rendering industry was started in different forms over 25 years ago. It formally began with the establishment of the Animal Protein Producers Industry (APPI) as the biosecurity arm of the industry in 1984. While APPI’s initial objective was the prevention and control of Salmonella contamination of finished product (protein meals), the industry’s goals have been expanded over the years to holistic safety programs, conforming to the principles of HACCP for all rendered products to assure end-product safety.

Most of the topics presented in this article have been discussed in one form or another within APPI over the years and subsequently adopted by most companies. Like all preventive control programs, there tends to be overlap, and this is not unusual in programs to ensure safety. Nor is it different in any way from the processing of food for human consumption where overlapping and some redundancy prevail.

In effect, it is nothing new, except to enhance and promote the rendering industry’s current Code of Practice that heightens safety from every conceivable dimension. But the process also needs quality management and structure and the ability to forecast and plan, organize, command, coordinate, and control. It is about assessing probable future scenarios, deciding how best to respond to them, bringing the resources needed for a successful response, and deploying them as effectively as possible. Anything less could result in failure of the system that no company can afford in today’s climate of food.

The rendering industry is fully cognizant of this, and, without doubt, ahead of the curve, as we continue to produce safe ingredients to assure safe feed, healthy livestock, poultry, fish, and pets, and safe food.

Tech Topics – October 2008 RENDER | back