BRCGS - Animal Feed Policy

Hello All,

I work at a raw nut processing facility  that would like to use by-products as animal feed.  I am tasked with writing the policy and would like some guidance/direction from some of you that may have animal feed experience.  Our auditor is an expert in this area, so I expect this policy to be scrutinized at our next audit.

Some info on the product.  This is by-product will be handled and stored with the same CGMP's as we do for human food and will be labeled and stored accordingly. It will also be added to our HACCP plan with specs. We weren't planning on processing this further, but as I type this, I realize that we have a large volume of international shipments that do not want their (human food) product pasteurized which then results in unpasteurized by-product that would then need pasteurization to be used for animal feed. 

Is there anyone that can share their policy and are we required to be PCQI Certified for Animal Food.  Any thoughts and guidance are greatly appreciated.

Yes, you need to be PCQI certified.

I have a couple of questions. You said "We weren't planning on processing this further, but as I type this, I realize that we have a large volume of international shipments that do not want their (human food) product pasteurized which then results in unpasteurized by-product that would then need pasteurization to be used for animal feed."

So some of your product is pasteurized and some is not, correct? Are you going to have to add more equipment to pasteurize the by-product? Or will you be able to reintroduce it back into the equipment where your typical product was pasteurized?

Hi Lisa,

My apologies for not clarifying properly.  My mind went another direction while I was explaining the product.  Yes, some product is pasteurized, some is not.  We don't actually pasteurize in the facility itself, we send our product out to local pasteurization/treatment facilities that we have contracts with.  Our facility is strictly bulk packing (not consumer packed).  We receive raw, shelled product from the huller and we simply bulk pack it while removing any FM that typically comes from growers. This is then sold to customers and is intended for further processing.   

I guess what threw me off a bit was that, in short, I read that facilities that pack and hold raw agricultural products are exempt to certain regulations unless the by-product is processed further.  

"Manufacturing/processing is defined as making animal food from one or more ingredients, or synthesizing, preparing, treating, modifying or manipulating animal food, including food crops or ingredients. Examples of manufacturing/processing activities include: baking, canning, cooking, grinding and mixing."

After reading it over again, I don't think it matters if we are exempt or not as our facility operates with all CGMP's in place and is a BRC Certified facility.  The by-products would be handled in the same manner as human food.  I may have been overthinking that portion, but please correct me if I'm wrong.  We currently do not have any staff that are PCQI Certified for Animal Food.  However we do have several have staff that are PCQI Certified for Human Food.

In addition, would my policy need to just cover the basics about being handled under conditions to prevent contamination, labeled properly, in proper containers while following CGMP's?

Not sure If I am making more fuss than needed.

Hi Lisa,

I think it's better to ask too many questions than not enough :smile:

The link below references OTJ training. With that said, a PCQI for human should be equivalent.

https://imepik.com/t...or-animal-food/

In some cases, yes. If an employee has equivalent experience or training, they may automatically qualify as a PCQI and will not need additional training. However, it’s best to get trained so you can share your completion certificate should an FDA inspector ask for it.

Here is my take.  I do both human and animal feed.  

I personally believe that the PCQI course for human food is similar enough to the animal food course that having both is not needed.   I have had auditors (including the FDA) not mention it and BRC auditors argue about it.  its best to do it, but I don't feel its necessary.   

I would review the human food byproduct section of the human food PQCI manual.   the requirements will be very easy for you to meet if you are treating it just as you are human food.   I'm guessing your unpasteurized product is labeled " not processed to control pathogens, etc.   the same applies to animal food / feed

You will want to look into the feed license requirements for your state and every state you intend to sell to.  the rules are all over the place as to who requires you to be licensed / registered and the fees involved (some require fees based on tonnage)  Honestly, this may be a bigger pain in the ass than the rest of the requirements.   

I would also suggest that you purchase the AAFCO manual and review.   they make the rules that everyone follows.   things like labeling are different than human food.   

Here is my take.  I do both human and animal feed.  

 

I personally believe that the PCQI course for human food is similar enough to the animal food course that having both is not needed.   I have had auditors (including the FDA) not mention it and BRC auditors argue about it.  its best to do it, but I don't feel its necessary.   

 

I would review the human food byproduct section of the human food PQCI manual.   the requirements will be very easy for you to meet if you are treating it just as you are human food.   I'm guessing your unpasteurized product is labeled " not processed to control pathogens, etc.   the same applies to animal food / feed

 

You will want to look into the feed license requirements for your state and every state you intend to sell to.  the rules are all over the place as to who requires you to be licensed / registered and the fees involved (some require fees based on tonnage)  Honestly, this may be a bigger pain in the ass than the rest of the requirements.   

 

I would also suggest that you purchase the AAFCO manual and review.   they make the rules that everyone follows.   things like labeling are different than human food.   

Many thanks for all the info you provided.  It gives me a much better idea and a starting point.  Our unannounced audit window is a few weeks away so this had me a bit stressed.  I truly appreciate your detailed response.