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The Pet Food Institute (PFI) has received recommendations from the National Pet Food Commission (NPFC) and is in the process of developing a plan to implement them. The NPFC was established by PFI in April 2007 to conduct an independent review of the petfood recalls of 2007. The commission was comprised of recognized authorities in nutrition, toxicology, veterinary medicine and quality control. Its charge was to study the findings on the cause of the recall.
From its study the NPFC recommended steps the industry and government can take to further build on the safety and quality standards already in place for petfood. The recommendations are being presented by the NPFC to the regulators of the industry – the U.S. Food and Drug Administration (FDA) and the Association of American Feed Control Officials (AAFCO) – and to veterinarians as well as to the petfood industry as a whole. Implementation of the recommendations of the NPFC by the petfood industry will support the industry’s role in the effort to further strengthen the nation’s food safety system.
NPFC recommendations to PFI include:
1. Develop a model product safety/quality assurance program, based upon industry best practices, that addresses ingredient sourcing (domestic and international) and receiving; product manufacturing and co-manufacturing; labeling; transportation; and distribution of commercial petfood.
2. Utilizing existing, or develop additional, contractual trading rules governing the purchase and sale of ingredients when procuring raw materials used in the manufacture of commercial petfood. Utilize, to the degree practical, existing industry trading rules, such as those promulgated by the National Grain and Feed Association (NGFA), as a starting point.
3. Expand existing educational and training initiatives concerning ingredient procurement, with an emphasis on developing a risk-based approach for ingredients sourced from all suppliers, both international and domestic. Such education should include, but not be limited to the role and responsibilities of brokers; as well as the role and reliability of certificates of analysis (COAs) as indicators of ingredient safety, quality and wholesomeness.
4. Explore mechanisms to communicate identities of recalled products to consumers via various methods in addition to the Internet.
5. Work with retailers and FDA-CVM to develop more efficient methods to remove recalled petfood products from sale.
6. Develop a model emergency response plan for the commercial petfood industry. Offer risk communication education and training to PFI membership, and where
possible, to non-member companies.
7. Provide education on the CARVER+Shock method for vulnerability assessments that has been adopted by the federal government for the food industry. The CARVER+ Shock method includes a software tool to help evaluate seven attributes of vulnerability to attack.
8. Volunteer to host a vulnerability assessment exercise regarding the Strategic Partnership Agroterrorism Initiative for the commercial petfood industry, in cooperation with the U.S. Department of Homeland Security, FDA, U.S. Department of Agriculture and Federal Bureau of Investigation.
9. Approach colleges of veterinary medicine, animal/veterinary science departments and appropriate professional and trade associations to provide basic knowledge of the petfood industry.
10. Establish ongoing communication links with colleges of veterinary medicine, animal/veterinary science departments and appropriate professional and trade associations regarding petfood, ingredient and other issues of mutual interest.
Recommendations to petfood manufacturers include:
1. Update existing (or for new companies, develop) company specific quality assurance programs to incorporate best practices for product safety, including, as appropriate, those developed by PFI to address ingredient sourcing and receiving; product manufacturing and co-manufacturing; labeling; transportation; and distribution of commercial petfood.
2. Reevaluate current sampling and testing protocols using risk-based analysis to evaluate ingredients and finished petfood in an effort to detect adulterants and/or contaminants that may adversely affect product safety using existing and emerging technologies.
3. Assure that individual lot and date codes appear on all finished products to facilitate product traceability and recalls. Although the vast majority of companies do this already, this is a point of special emphasis related to traceability.
4. Participate regularly in PFI, AAFCO and FDA educational programs and regulatory processes.
5. Establish ongoing communication links with colleges of veterinary medicine, animal/veterinary science departments and appropriate professional and trade associations regarding petfood, ingredient and other issues of mutual interest.