LOVELAND, Colo. — Jenny Murphy, consumer safety officer for the US Food and Drug Administration (FDA) Center for Veterinary Medicine (CVM), spoke during the Pet Food Alliance 2019 Summer Meeting, held from June 26 to 28 in Loveland, to update attendees on key initiatives in pet food safety being led by the FDA.
Murphy covered FSMA updates, including 2018 inspection trends and 2019 data and expectations, as well as emerging food safety hazards, such as pathogens.
Throughout 2018, the FDA and state agencies conducted roughly 400 Current Good Manufacturing Practices (CGMP) inspections, of which 60% were conducted by the FDA and 40% were carried out by state entities.
Of the approximate 400 inspections, only 6% (24 inspections) resulted in a documented Form 483, which indicates an observed violation of the Food Drug and Cosmetic (FD&C) Act, according to the agency. Only one CGMP inspection, however, warranted an official warning letter in 2018.
Murphy reported the two most frequently observed issues in these CGMP inspections were pest management and general housekeeping. The most frequent Form 483 observations were overall plant management and pest management, she said.
From January to mid-June 2019, the agency has conducted 156 more CGMP inspections, of which 14% resulted in a Form 483 issuance; 75 Risk-Based Preventive Controls for Food for Animals (PC) inspections; 25 sanitary transportation inspections; and two Foreign Supplier Verification Programs (FSVP) inspections. Fourteen PC inspections were also conducted by state agencies.
The most frequent findings during the PC inspections were the implementation of prerequisite programs. “Know what you’re supposed to do and do what you say you’re going to do,” Murphy advised on this topic.
Processors were most commonly cited for failure to identify/implement a preventive controls and hazard analysis, although there were a handful of citations involving no written food safety plan or one that is not written by a preventive controls qualified individual, failure to implement corrective actions, failure to validate preventive control, and others.
“Where we’re seeing the problem arise is these plans developed by corporate headquarters are generic in nature,” Murphy explained. “It’s just a balance of making sure that what you’re doing is facility specific.”
Murphy also discussed emerging hazards and prevalent ones that pose a threat to pet food safety during her presentation, touching specifically on pathogens, pentobarbital, dilated cardiomyopathy and African Swine Fever.
The issue of pentobarbital in rendered animal products for pet food production has been addressed by the FDA with a method for detecting the chemical in rendered tallow products, but the agency continues to work on developing methods for detecting it in meat and finished pet food products.
Some research gaps Murphy pointed out include knowledge about the scope of the problem, the appropriate controls, whether they be along the supply chain or during processing, and humane animal euthanasia alternatives, which is a challenging research subject in itself, she added.
“This isn’t just a conversation we’re having with the animal food community. This is also a conversation we’re having with the veterinary community,” Murphy said.
Murphy detailed how pathogens such as Salmonella are a long-standing concern among all pet food products, whether they be dried kibble or wet foods. However, due to trends toward raw and frozen raw pet foods, concerns for Listeria monocytogenes and E. Coli have become more prevalent in the industry, she explained.
Murphy discussed three main areas for improvement that could affect how the industry approaches pathogens in the future: adequate controls for raw pet food products, addressing post-kill step contamination issues with ingredients and finished products, and implementing clearer best practices for transportation of unpackaged ingredients.
She touched briefly on the FDA’s third update into its investigation into increased reports of dilated cardiomyopathy (DCM), reiterating that the agency’s responsibility to release the raw data and updated number of reported cases, along with other relevant data, to the public when it potentially involves food safety.
“We know that we have an obligation, if we see a signal, to report it,” Murphy said.
She added that it is unclear whether there is a causal link between specific pet diets and DCM. “But what we might know is what’s not causing it, versus what is causing it,” she added. This research gap, along with formulation data and related medical records from animals with DCM, will drive a collaborative industry effort to gather more data to determine the cause of the issue, Murphy said.
Finally, Murphy touched on African Swine Fever, a highly contagious virus that has spread rapidly throughout Asia over the past year.
“Currently there is no drug to treat it and no vaccine to prevent it,” Murphy explained, adding the meat industry in the US is on “high alert” about this issue as it continues to spread in the Eastern hemisphere.
Murphy said she brought up the issue to raise awareness among rendering and pet industry professionals in case the disease was to spread to the US meat industry. She suggested the industry should further address this issue by determining the course of natural contamination, what a “positive” test means in animal feed and how to detect the live virus, and how to appropriately control the situation if it arises.
The pet food and treat industry will hear more from Murphy in September at the 2019 Feed and Pet Food Joint Conference.
The Pet Food Alliance is a cooperative organization focused on research and innovation in the pet food and rendering industries. It is funded in large part by the Fats and Protein Research Foundation, whose mission is to fund research that helps ensure a strong future for the rendering industry and its industry partners.
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