Methods for adequately maintaining the grounds around a plant include properly storing equipment, removing litter and waste, and cutting weeds and grass within the immediate vicinity of plant buildings and structures. Litter, waste, tall grass, weed, and old equipment around plants can harbor pests which will try to enter the facility and could contaminate animal food and ingredients. Roads, yards, parking lots, and other areas in the vicinity of the plant would be required to be maintained and adequately drained so as not to contribute to contamination of animal food by seepage, foot-borne filth, or providing a breeding place for pests. Water seepage into animal food ingredients and finished products can promote growth of mold which could produce mycotoxins in the animal food. The PAS 222 (p. 4) contains a provision similar to proposed section 507.17(a). It provides the [s]ites to be maintained in good order. Vegetation shall be tended, removed or otherwise managed to address animal food safety hazards. Roads, yards and parking areas shall be drained to prevent standing water and shall be maintained (Ref. 44).
Proposed SEC 507.17(b) would require that the plant's size, construction and design allow for cleaning, maintenance, and exclusion of pests. Specifically, this proposed section would require that the size of the plant provide sufficient space to place equipment, store materials, and allow precautions to be taken to prevent contamination of animal food inside the plant and in outdoor bulk vessels. It would also require that construction of the plant be such that floors, walls, and ceilings can be kept clean and in good repair; that condensate from fixtures, ducts, and pipes not contaminate animal food; that there be enough space between equipment and walls to permit employees to perform their duties and protect against contaminating animal food; that lighting be adequate, and lighting fixtures, skylights, and other glass suspended over exposed food be of such construction that in case of breakage, glass does not contaminate animal food; that sufficient ventilation be provided to minimize odors and vapors without contaminating animal food; and that where necessary, adequate screening be provided to protect against pests. Proposed
The Codex animal food CGMPs contain similar provisions that state that locations, design and construction of premises should deter pests and restrict access to pests to a minimum. Building and facilities should be designed to allow easy access for cleaning, including access to the inside of relevant equipment. There should be enough space to satisfactorily conduct all process operations and products inspections. Lighting sources should be sufficient to ensure that hygienic conditions are maintained throughout the product and storage areas. There should be protected lighting fixtures. There should be adequate means of ventilation to minimize airborne contamination of animal food from aerosols and condensation droplets (Ref. 2).
Proposed SEC 507.19(a) would require that buildings, fixtures, and other physical structures be maintained in sufficient sanitary condition and repair to prevent animal food from becoming adulterated. Equipment and utensils would need to be cleaned and sanitized to protect against contamination of animal food, animal food contact surfaces, and animal food packaging materials. Reports of animal food contamination continue to be reported to the Agency due to improper flushing (cleaning) of equipment. In one incident, a vitamin D supplement for a poultry food was carried over to a dog food. The excessive vitamin D levels in the pet food caused toxicity in the animals consuming the food (Ref. 48). In addition, during facility inspections,
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