FSMA – Where Are We Now?

The Food Safety Modernization Act (FSMA), the single most sweeping change to U.S. food safety laws, offers a new regulatory approach to food safety – including pet food. Instead of a regulatory focus that is primarily reactive (for example: product recalls), the goal of FSMA is to establish a preventive approach to food safety that focuses on identifying and addressing potential safety hazards. The requirements under FSMA further enhance and codify many of the manufacturing safety protocols already used by PFI member companies.

After FSMA was first signed into law in 2011, FDA issued its final regulation for animal food in September 2015, and pet food and treat makers are now in the implementation and compliance phase. Starting September 19, 2016, most pet food facilities are expected to be in compliance with Current Good Manufacturing Practices (CGMPs) and can be inspected by FDA. The compliance dates vary based on company size, and small and very small companies have more time to prepare. CGMPs include requirements for employees, facility design, equipment upkeep and maintenance

By September 2017, pet food and treat makers will have conducted a full analysis of safety hazards and have established preventive controls to mitigate those hazards. FDA’s rules implementing FSMA require that at least one preventive controls qualified individual (PCQI) be identified for each facility. To prepare for this requirement, PFI joined the Animal Feed Industry Association (AFIA) and the National Grain & Feed Association (NFGA) to host a four-day “lead instructor” training course. The course trained PCQIs and also provided instructions on how to teach the course themselves, thus helping to establish more PCQIs in advance of the 2017 deadline.

To assist all pet food and treat makers to be in compliance with FSMA, whether or not they are members of PFI, we also issued an open letter earlier this year. It is up to all pet food makers to understand their requirements and obligations under FSMA. The safety and wellbeing of your pet is our highest priority.

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