A review of a recent FDA inspection reports made clear what hazards are the subject of focus. The list isn’t new information. You know this list if you’ve attended a PCQI class, had an inspection or have worked with us. The purpose of this article is a reminder that if you have these fundamentals down, you will have a successful inspection. Here are the three chemical and one physical hazard types that must be identified in every Hazard Analysis for nearly all feed mills.

Mycotoxins – A Naturally Occurring Chemical Hazard
Mycotoxins, especially Aflatoxin and DON are found in commodities like corn, wheat, oats and barley. Processed grains like distillers and midds are also subject to being contaminated with mycotoxins. When received directly from a farm, the most accurate and timely way to determine if the grain has mycotoxins at higher than safe levels is to perform onsite testing at the time of delivery.

If this type of testing is not feasible, your firm needs to be able to explain what steps it takes to keep mycotoxins out of animal feed. Samples can be sent for lab testing. Temporal (field) conditions can be monitored to evaluate the likelihood of mycotoxins in grain. Suppliers of processed grain like distillers and midds can be required to provide their testing information as part of your purchase agreement.

All feed mills need to answer the question “What are you doing to make sure the feed you are selling doesn’t contain mycotoxins at unsafe levels”?

Medications – A Potent Chemical Hazard.
Medication hazards are not just found at licensed medicated facilities. All medications used in feed mills can be hazardous to at least some species of animals. We can learn from the regulations that licensed facilities must follow.

Licensed medicated mills operate under CGMPs that have been enforced for many years. The practices that are required to be in place for these mills can be used by non-licensed mills to control the hazards posed by the medications they use. Proper storage, a means of accounting for use and what’s on site, and means to prevent cross contamination are key ways to minimize the likelihood of medications leading to the use of medications. The question to answer for this one is “What procedures do you have in place to prevent the use of the wrong medication or the incorrect amount of the medication?”

Nutrient Deficiency and Toxicity-A Chemical Hazard When the Wrong Amount is Used.
The formulation calls for this much of this and that much of that. How do you prevent a mix up where that becomes this and this becomes that? Your mixing process may involve the use of an automated micro-ingredient addition process or it may be accomplished through hand adds. Inspectors have viewed automated systems more favorably primarily due to the records that such systems generate. Errors can still be made, but much of the human factor is removed. If you hand add, you must have a clear SOP in place that is backed up by effective and documented employee training.

The question here is similar to the one for medications. “How do you prevent too much or too little of an essential nutrient being added to the mix?”

Foreign Materials-Never a Good Addition to the Feed
Metals, hard plastic, glass and other objects can find their way into animal feed. Sources of these materials can be directly from the field, during production or during shipping. Magnets at receiving typically pick up ferrous metals that include anything from a bolt to a wrench. It is not abnormal for these items to be found so prevention is unlikely.

Other items like glass and aluminum will not be picked up by a magnet. In many cases these materials were hauled previously in the trailer.

To prevent these items from entering the grain stream, a verification of the last load hauled is important.

Magnets and screening equipment may be used in various phases of production. You should have a documented inspection and cleaning schedule and track what is being found. An annual magnet pull test is a way to verify that the magnet is still effectively removing ferrous material.

A documented preventive maintenance program is another way to help prevent equipment malfunctions that can lead to foreign materials falling into the feed product. There should be an established schedule along with documentation that the scheduled tasks have been completed.

The bottom line question is “What equipment and procedures do you have in place to minimize the likelihood of foreign materials ending up in the finished feed?”
The Key Takeaway
Stay on top of these four types of hazards so that you can continue to sell a safe product and pass an audit or regulatory inspection.

If you would like to receive a free full page flyer to remind employees of these four key hazards, please send us an email and we will email it to you.