Petfood Industry - January 2018 - 37

www.PetfoodIndustry.com | 37

continue to be so). They tend to take more time (six to
eight hours) than checklist-type inspections because it's a
new rule, and people on both sides are still learning.
■ Inspectors asked questions (and will continue to do so)
about preventive controls readiness.
■ The overall industry report card is very positive, even
exceeding FDA's expectations a bit.
■ Most common findings in terms of problems were with
pest infestations, especially in warehouses.
Murphy said pet food companies whose facilities were
inspected shared concerns with FDA, including why inspectors asked to see consumer complaint files (see sidebar
below) and pest management records. She speculated that
the "disconnect" comes about because neither of these is
required by FSMA, but it is standard operating procedure
for inspectors. "So, you're not required to share these files
or records, but if you have a good, positive story to tell, do
share it!" she said. An inspection is a snapshot in time, she
added; the inspector has to make a determination based on
what she or he sees at that time. Files and records can help
give a more complete or detailed picture.
Finally, for CGMP inspections in fiscal year 2018 -
which, in addition to large businesses, will include small
businesses (those with fewer than 500 employees but more
than US$2.5 million in annual sales) - Murphy said to
expect:
■ More inspections, which will be conducted by FDA and
state inspectors. (The latter must go through FDA regulatory training.)
■ However, they will not inspect all large and small businesses.
■ CGMP inspections may be combined with inspections for
BSE and, at some point, sanitary transportation; that is
still being determined.
■ FDA will continue to educate before and during the
inspections.

Pet food industry's take, tips for
successful CGMP inspections
During a separate, interactive session at the conference,
representatives of pet food companies presented their experiences and lessons learned from CGMP inspections to date.
Michele Sayles, executive director of food safety and quality
for Diamond Pet Foods, and Richard Driggs, director of
operational quality for Nestlé Purina PetCare, role played an
ongoing inspection, with Sayles as FDA inspector and Driggs
as the quality and safety manager of a pet food or feed facility.
Industry January 2018

The enacted inspection included several scenarios: FSMA
readiness, inspection preliminary questions and the actual
CGMP inspection, in this case of a feed mill and covering
plant and grounds, receiving, hazard disclosures and
written assurances and outbound product shipments. Matt
Frederking, vice president of regulatory affairs and quality
for Mid America Pet Food, narrated each scene, while
Cassandra Jones, PhD, associate professor at Kansas State
University and a participant in FDA inspector training, led
audience discussion and questions via online polling, then
shared helpful information and tips.
During the discussions, Driggs revealed that Purina
facilities have already undergone 16 CGMP inspections,
confirming Murphy's earlier report that FDA was actively
carrying out the inspections. His experiences, along with
those of the other presenters, also corroborated Murphy's
comments about industry concerns over questions asked by
FDA inspectors but not necessarily covered under FSMA.
Like Murphy, they advised that, while documentation is
not required to answer those questions or for many FSMA

How to handle FDA requests
for consumer complaint files
➥"During a routine FSMA inspection (not investigating
a food safety incident), FDA does not have authority to
require access to consumer complaint files, emphasized
Cassandra Jones, PhD, associate professor at Kansas State
University and a participant in FDA inspector training. But,
if such files are listed in your food safety plan as verification for something, then it's fair game - so don't have that
in your food safety plan, she advised. It's wise to develop a
policy before an inspection for whether and when to share
complaint files.
A member of the audience during an interactive session
at the eighth annual Feed and Pet Food Joint Conference
shared his experience with an FDA inspector requesting
consumer complaint files. In his company's case, they
negotiated to sharing complaints from a specific month.
FDA is hearing from consumers, he explained, so it
helps the inspection go more smoothly if you address it
somehow. But, be sure to provide context, he advised, such
as a transcript of the consumer's call to the company, the
size of batch or distribution of the product in question and
that there were no other complaints for that batch. Then
you can also demonstrate that you have a process for
handling complaints.


http://www.PetfoodIndustry.com

Table of Contents for the Digital Edition of Petfood Industry - January 2018

Petfood Industry - January 2018
Contents
Top 2018 pet food trends: clean label, full transparency
Industry News
New Products
WellPet: focus on freeze-dried, raw meat premium pet food
3 pet food trends that continue to redefine the industry
Top pet health trends impacting pet nutrition research
Addressing health issues in older dogs with pet food
What to expect from FSMA pet food safety inspections
Petfood Forum Asia: innovation for rising pet food markets
How to convene a GRAS panel for novel pet food ingredients
Agar-agar: Gelling agent option for canned dog and cat foods
US pet food market to reach US$27 billion in 2018
Marketplace
Advertiser’s Index
Petfood Industry - January 2018 - CT1
Petfood Industry - January 2018 - CT2
Petfood Industry - January 2018 - Petfood Industry - January 2018
Petfood Industry - January 2018 - Cover2
Petfood Industry - January 2018 - 1
Petfood Industry - January 2018 - Contents
Petfood Industry - January 2018 - 3
Petfood Industry - January 2018 - Top 2018 pet food trends: clean label, full transparency
Petfood Industry - January 2018 - 5
Petfood Industry - January 2018 - Industry News
Petfood Industry - January 2018 - 7
Petfood Industry - January 2018 - 8
Petfood Industry - January 2018 - 9
Petfood Industry - January 2018 - New Products
Petfood Industry - January 2018 - 11
Petfood Industry - January 2018 - 12
Petfood Industry - January 2018 - 13
Petfood Industry - January 2018 - 14
Petfood Industry - January 2018 - 15
Petfood Industry - January 2018 - 16
Petfood Industry - January 2018 - 17
Petfood Industry - January 2018 - WellPet: focus on freeze-dried, raw meat premium pet food
Petfood Industry - January 2018 - BB1
Petfood Industry - January 2018 - BB2
Petfood Industry - January 2018 - 19
Petfood Industry - January 2018 - 20
Petfood Industry - January 2018 - 21
Petfood Industry - January 2018 - 3 pet food trends that continue to redefine the industry
Petfood Industry - January 2018 - 23
Petfood Industry - January 2018 - 24
Petfood Industry - January 2018 - 25
Petfood Industry - January 2018 - 26
Petfood Industry - January 2018 - 27
Petfood Industry - January 2018 - 28
Petfood Industry - January 2018 - 29
Petfood Industry - January 2018 - Top pet health trends impacting pet nutrition research
Petfood Industry - January 2018 - 31
Petfood Industry - January 2018 - Addressing health issues in older dogs with pet food
Petfood Industry - January 2018 - 33
Petfood Industry - January 2018 - 34
Petfood Industry - January 2018 - 35
Petfood Industry - January 2018 - What to expect from FSMA pet food safety inspections
Petfood Industry - January 2018 - 37
Petfood Industry - January 2018 - 38
Petfood Industry - January 2018 - 39
Petfood Industry - January 2018 - 40
Petfood Industry - January 2018 - 41
Petfood Industry - January 2018 - Petfood Forum Asia: innovation for rising pet food markets
Petfood Industry - January 2018 - 43
Petfood Industry - January 2018 - How to convene a GRAS panel for novel pet food ingredients
Petfood Industry - January 2018 - 45
Petfood Industry - January 2018 - 46
Petfood Industry - January 2018 - 47
Petfood Industry - January 2018 - Agar-agar: Gelling agent option for canned dog and cat foods
Petfood Industry - January 2018 - 49
Petfood Industry - January 2018 - US pet food market to reach US$27 billion in 2018
Petfood Industry - January 2018 - 51
Petfood Industry - January 2018 - 52
Petfood Industry - January 2018 - 53
Petfood Industry - January 2018 - Marketplace
Petfood Industry - January 2018 - 55
Petfood Industry - January 2018 - Advertiser’s Index
Petfood Industry - January 2018 - Cover3
Petfood Industry - January 2018 - Cover4
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