The Food and Drug Administration (FDA) has made three Federal Register notices available regarding Salmonella. The first revokes the current regulation on the books from 1967 that any Salmonella in animal feed is an adulterant. This has been long supported by the National Renderers Association (NRA) and promised by FDA when it published the draft “Compliance Policy Guide Sec. 690.800 Salmonella in Animal Feed” on August 2, 2010.
The second notice withdraws the compliance policy guide (CPG) entitled “Sec. 690.700 Salmonella Contamination of Dry Dog Food” as this CPG is now obsolete. The third notice finalizes the CPG entitled “Sec. 690.800 Salmonella in Food for Animals.” This CPG will guide FDA staff in their handling of animal feed/pet food that contains Salmonella, specifically:
• relating to pet food or pet food ingredients that are contaminated with Salmonella;
• relating to animal feed and animal feed ingredients that are contaminated with certain Salmonella serotypes that are pathogenic to the particular species of animal for which the animal feed or animal feed ingredients are intended; and
• defining ingredients going to pet food as “pet food,” but the guidance says to determine if they will be heat treated or not to determine risk.
Changes in this new CPG from the 2010 draft include a title change from “_Salmonella_ in Animal Feed” to “_Salmonella_ in Food for Animals” to clarify that the CPG covers all animal food, including pet food and animal feed. The new CPG also removes the term “direct human contact animal feed” because commenters found the term confusing. The term “pet food” is used instead and is defined to mean food for pets, including treats and chews.
In regards to feeding fats, while NRA believes that Salmonella is rare in feeding fats, experience has shown that accumulating condensation, dust, or other situations can cause fats to test positive for Salmonella. The CPG will likely be applied equally to feeding fats and protein meals. Only eight serovars are considered hazards for livestock and poultry feed, and there is no reason to believe they occur very often in rendered products. However, pet food is a different story, with expectations that retail pet food should be Salmonella negative. If the ingredients going into pet food will be subject to another thermal step during pet food manufacture, there is not much concern. However, fats used for flavors sprayed on pet food kibbles post extrusion, for example, may be required to be completely negative since the pet food will receive no subsequent heat treatment.
The new CPG is available at www.fda.gov/downloads/ICECI/ComplianceManuals/CompliancePolicyGuidanceManual/UCM361105.pdf and finalizes the draft guide from 2010, which NRA commented on at that time. Additional comments on the CPG can be made at www.regulations.gov, but the FDA is unlikely to make additional changes for quite some time. According to NRA, this CPG is a big improvement over the adulterant language adopted in 1967, though things are becoming more challenging for pet food.
August 2013 RENDER | back