The Food and Drug Administration (FDA) has issued a warning letter January 3 to animal feed manufacturer ReConserve after an investigation prompted by a complaint from a state regulatory partner about ingredient storage conditions.
The FDA inspected the company’s animal feed manufacturing site in Baltimore from May 23 to June 29, 2023. As the agency noted in its letter to ReConserve President David Luskin, the inspection found evidence of “significant violations” of federal regulations.
“Additionally, this inspection found evidence that your product is adulterated because it consists in whole or in part of a filthy, putrid or decomposed substance,” the letter states.
According to the company’s website, ReConserve recycles leftover, expired or inedible bakery, cereal grain, snack foods and related food byproducts into a dried component for livestock feed.
Inspection findings included a pile of bakery byproducts intended for animal feed production stored outdoors on the facility’s gravel driveway. The 3-foot-high pile was uncovered and contaminated with foreign objects, such as rocks and deteriorated packaging materials, and exposed to birds, insects, weather conditions and other potential food safety hazards.
According to the FDA, ReConserve stopped using the outdoor pile of ingredients on June 1, 2023, but resumed using these ingredients a few weeks later without conducting an evaluation to determine if the ingredients were fit for feed.
Among other issues, the FDA said, ReConserve didn’t conduct a proper hazard analysis to identify and prevent animal feed manufacturing, processing, packing or storage risks at the facility. The company also didn’t establish preventive controls or written procedures to address these hazards.
ReConserve received the agency’s findings after the inspection and sent a response dated July 14, 2023, to address the results. However, the recent warning letter suggests the manufacturer had not made sufficient progress toward fixing the issues observed at the inspections.
The FDA stated ReConserve had not conducted a proper hazard analysis to identify and prevent animal feed manufacturing, processing, packing or storage risks at the Baltimore facility. The company also failed to establish preventive controls or written procedures to address these risks.
FDA officials gave the company 15 working days to describe how it planned to address the violations and prevent their recurrence, and failure to comply could result in actions such as seizure and injunction, the letter states.