The previous examples demonstrate that failure of an animal food facility to control the overall plant production environment, whether the plant manufactures, processes, packs, or holds food for pets or for food-producing animals, can and does result in human disease. In addition, regulations addressing the production of human food obtained from animals do not address the safety or production of animal food being fed to those food-producing animals. The Agency concludes that the previously described situations point to the need for this proposed rule for animal food, including the need for CGMPs.
The Agency realizes that there is a spectrum of animal food producers and production facilities and that the hazards and risks can vary greatly. Therefore the Agency is requesting comment on its thinking that CGMPs similar to those for human food are appropriate for animal food. The Agency is also requesting comment on whether CGMP requirements that would be more appropriate for some types of animal food may not be appropriate for other types, and, if so, how the Agency can or should distinguish between those types during the various stages of animal food processing.
The need for enforceable baseline standards for producing safe animal food was a major consideration in
B. Proposed Current Good Manufacturing Practices (CGMPs) for Animal Food
FDA is proposing in
This proposed requirement is similar to PAS 222 at 13.5, which requires persons known or suspected to be infected with, or carrying, a disease or illness transmissible through animal feed intended for feeding within the home to be prevented from handling such food and food contract surfaces. Codex animal food CGMPs include a similar provision for all food employees who may be carriers for any disease or illness likely to be transmitted through animal food (Refs. 2 and 44).
Proposed SEC 507.14(a) would also require that while on duty employees maintain adequate personal cleanliness as appropriate for the activities they are performing. For example, employees would be required to wash their hands before starting work and at any other time when the hands become soiled or contaminated. The Agency is not proposing to require that employees wash their hands after each absence from the work station, as in the human food CGMPs, because in the animal food industry employee responsibilities are not typically limited to work stations. Employees would also need to secure jewelry and other objects such as personal belongings, tools, and writing implements to prevent them from falling into animal food, and store clothing and personal belongings in areas where they will not contaminate animal food. The Agency has received RFR reports of foreign objects such as pieces of a metal tape measure, plastic pieces from a hard hat, stainless steel shavings, and fragments of a soda can that were mixed into the animal food. In most of these reports, animal deaths occurred due to the consumption of the foreign objects in the food (Ref. 48).
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