Livestock feed and specialty products producers have an inherent interest in making the highest quality complete feed and value-added products at economical prices. This will become more important as the Food Safety Modernization Act (FSMA) is shaped and implemented. Regulatory authorities are rolling out the proposed rules and taking public comments; however, there are several practices any feed mill can customize to their operation — not only for FSMA — but to ensure its manufacturing safe, quality products every time.
Your facility, your process
During the rollout meetings, FSMA regulators acknowledged that a “one-size-fits-all” approach will not work for the feed industry. No one knows your facility and your procedures better than you do — use that to your advantage. Demonstrate your expertise by keeping thorough records of your standard operating procedures:
- Document your process flow and equipment.
- Record how and when each unit is maintained and cleaned.
- Define the parameters which are important to monitor when your equipment is operating.
- Indicate the accuracy of measuring devices, such as scales, and keep calibration records.
- Your mixer produces a uniform, evenly-dispersed complete feed – find a way to compile this nutrient data.
- Your finished product storage is always swept and self-inspected on a regular basis. Document how often this is completed and keep records showing that it has been done.
The more you own what happens in your facility, the more likely you are to consistently produce a safe, quality product — and the more likely you will have happy customers.
If you have been making the same product for 30 years on the same equipment with the same ingredients from the same suppliers, collect this historical data. For example, if you have health data demonstrating that animal performance improved or became more consistent when the farm started using your diets or ingredients.
Good manufacturing practices
FSMA broadly speaks of two main areas of focus: good manufacturing practices (GMPs) and preventive controls. Here is an overview of some key areas to consider:
Think of GMPs as the foundation upon which your plant produces safe, quality feed. This literally includes the mill’s foundation and everything that makes up the facility. For example, if your roof leaks when it rains and water drips onto bags of finished product, this could easily cause microbial contamination. Likewise, if the walls have holes or if overhead doors don’t close completely and evenly, rodents, birds and insects will invade your facility.
Pest control measures rely on proper building design and maintenance and minimizing hiding and nesting places. Don’t pile scrap waste next to your exterior walls, and leave a free area around the interior walls, too, to allow for cleaning. A pest control company employee once told me his job only controls 20 percent of pests — housekeeping and cleaning make up the other 80 percent. While I don’t know how to verify these percentages, I thought he made a great point: you play the major role not someone else.
While on the subject of cleanliness, employee hygiene is another GMP that is easily overlooked, but is extremely crucial. Establish guidelines — and even a company culture — that indicates how people should behave around feed products; this includes practices to minimize any source of human-to-feed contamination:
- Encourage frequent handwashing
- Wearing clean clothing or restricting what is worn by requiring uniforms
- Keeping sick employees away from certain areas or at home until they get well
Having a company-defined program and policy, along with basic training for all employees, will help to instill what otherwise could easily be ignored.
Know your suppliers
Incoming raw materials require focus and attention as part of the mill’s GMPs. Every time an ingredient, packaging or finished product is handled it is an opportunity to affect its quality or safety. Therefore, it is imperative to start with the highest quality raw materials relative to their costs. This may involve considerable work with your suppliers and brokers who, after all, you are paying to provide you with the basic components of your products. It is important to have well-defined standards and to develop testing programs to verify that your standards are met. This could include something as basic as having an album of color pictures that you use to compare with an incoming load. If the color of an ingredient is constantly changing, from load to load, what else might be changing?
Additionally, you may want to take samples and test for nutrient content, either with an outside lab, or with an in-house, rapid test. It’s hard to make feed with the correct protein content, for example, if you cannot get an ingredient with a consistent level. Perhaps the most important procedure that must be defined and given to your suppliers and brokers is what will happen if you reject a load of raw materials. This can be somewhat tricky and delicate, but, again, these people are being paid to perform for you.
Once you believe you have control of the foundational GMPs in your operation, it is also important to devise a written, preventative control plan.
The concept of preventive controls is typically dealt with in a written hazard analysis and critical control points (HACCP) plan. Simply put, the plan acknowledges specific biological, chemical or physical hazards that could easily exist and describe how they will be eliminated or minimized.
Rendered or co-products containing pathogenic bacteria or toxins is an example of a hazard. The idea is to define how a hazard will be detected and controlled at the critical control points. To do this, it may be necessary to use equipment to eliminate pathogens at a known temperature for a certain period of time, i.e. a kill step. This would require determining what the temperature must be and to devise a system to document that the temperature has been reached for the required time. If the temperature is not reached or is not achieved for the required time, what do you do then? Having these types of corrective actions documented is also important.
In some situations, when the hazards have been identified, it may be advantageous to avoid using ingredients or products that introduce these hazards. Additionally, a hazard analysis specific to your situation may reveal that what others typically encounter is not common to your part of the country or to your operation.
As FSMA is in the process of being shaped by public comment, you can take steps to meet the challenge of producing safe, quality feed for your customers. Having a complete understanding of your facility and processes will help you make better decisions in the future.