Over the years, more small meat shop operations have moved into pet food processing and many others are considering expanding that activity as an adjunct to their business. But most have questions about what is required, what they are allowed to produce and, more importantly, who provides oversight for that activity.
To begin with, there are both federal and state requirements. The US Food and Drug Administration (FDA) has overall authority but most states also require registration for products sold within their boundaries. The FDA updated its pet food marketing rules in 2011 and requires that both human and animal food be safe for consumption, that ingredients be listed and that they serve a nutritional or safety purpose.
In essence, the FDA wants to see a good manufacturing program in place, such as Hazard Analysis and Critical Control Points (HACCP), which most small meat processors have in force under federal US Department of Agriculture (USDA) or state meat inspection programs for human foods. The FDA will do some inspections but doesn’t have a field staff in place to conduct on-site inspections at every location. They will respond when food-caused injury or sickness has occurred or when a complaint has been filed.
Facilities under the inspection jurisdiction of the USDA or state meat and poultry programs normally lessen FDA or state FDA-equivalent agency concerns since they are already under regular or often round-the-clock surveillance, including pre-operational and post-operational standards.
AAFCO warns that there is no single agency or group that will give approval for sale of pet food products in all states and that registration and licensing requirements must be met for every state.
Many small meat and poultry processors already provide simple pet food items like smoked or unsmoked bones and treats made from inspected meats or by-products that would otherwise be picked up by rendering companies at a cost to them. Pet foods may contain other generally recognized as safe (GRAS) ingredients or those approved by organizations such as the Pet Food Institute that lead to a balanced diet or provide other substantiated descriptors, such as lean, low fat or organic.
Smaller processors should be aware of, identify and also be alert to labeling requirements for ingredients obtained from foreign countries. Further information about pet food labeling is available from www.petfoodinstitute.org and the Association of American Feed Control Officials (AAFCO) at www.aafco.org, which also details state-level rules and labeling requirements.
AAFCO also warns that there is no single agency or group that will give approval for sale of pet food products in all states and that registration and licensing requirements must be met for every state. This can complicate marketing for those companies wishing to offer their pet foods online, through distributors or even via social media. However, all pet foods must be registered with the FDA’s Center for Veterinary Medicine.
Smaller companies manufacturing pet foods need to separate those items from meats or foods produced for human consumption. As a general rule, USDA and state meat and poultry inspection officials want to see a separation of facilities for items being produced for humans and pets. Over the years, however, they have permitted common facilities to be used provided the plant has documented separation procedures and follows strict clean-up between different product categories.
It should be noted that the USDA provides a voluntary inspection program for canned pet foods, meaning that the processor pays for that inspection. Under this program, the agency indicates the amount of meat ingredients and minimum nutritional profile used, as well as labeling approval specifications. Processors using this program may apply an inspection seal to the product, although it is not that widely used.
APHIS, the USDA’s Animal and Plant Health Inspection Service, requires state-approved pet foods to be registered with them. They may also provide annual label reviews and random food quality checks, and are authorized to look into complaints and check on production facilities.
For those smaller meat and poultry processors who see the potential in a growing market for pet food items beyond bone and dried pet snacks, it can be a time consuming but rewarding process. Pet foods do not have to be pre-approved before they go to market, but ingredients used in them are regulated by the FDA and must be safe for consumption and have a purposeful function.
Interest in pet food processing has intensified for small family-operated meat firms enough that the American Association of Meat Processors has scheduled a session on the subject at its 80th Annual Convention July 25-27, 2019 in Mobile, Alabama.
Find more articles related to pet food and treats on the Pet Food Processing landing page.