PREVENTING MEDICATION CARRYOVER
What’s the likelihood of the wrong medication ending up in a batch of feed at your facility? “Perish the thought” you say. That’s understandable because we know that certain species of animals cannot tolerate certain medications-medications you likely have in your mill. Your Food Safety plan must fully identify this hazard and point to the procedures that are followed to prevent medication carryover.
TWO KEY AREAS OF FOCUS
Your employees are trained to mix feed to a specific recipe (formulation). This process may be automated with little direct action by an employee or employees may be responsible for selecting the ingredients adding each one, including medications, by hand into the batching system. The rest of this article will focus on hand adding vs. the use of an automated system.
When ingredients, we rely on training to make sure employees understand how to perform these tasks safely. We maintain and reconcile inventory records to track use of medications. We review production records to make sure the batch of feed was manufactured according to the formulation.
CARRYOVER OF MEDICATIONS
The FDA recently issued a draft guidance document GFI 272 Practices to Prevent Unsafe Contamination of Animal Feed from Drug Carryover. According to the FDA, this guidance describes practices available to medicated feed manufacturers to prevent unsafe contamination from drug carryover into a non-medicated animal feed or a different medicated feed. This guidance contains much of the information found in the Compliance Policy Guides Sec. 680.500 Unsafe Contamination of Animal Feed from Drug Carryover and 680.600 Sequencing as a Means to Prevent Unsafe Drug Contamination in them Production, Storage, and Distribution of Feeds (both of which we intend to withdraw after this guidance is finalized), but includes updates and additional information.
The guidance document covers flushing, sequencing and physical cleanout practices to prevent unsafe carryover of medications between batches of feed.
YOUR ANIMAL FOOD SAFETY PLAN
If your mill uses medications, the hazard of drug carryover must be identified and addressed in your food safety plan. Here are a few steps to take:
Review your Hazard Analysis and see where you have identified the
hazard and what SOPs or other practices you have in place to help control the
Review the SOPs to make sure the steps are being followed.
Train employees to follow each SOP.
PRO TIPS – ABCs
Determine what equipment
needs to be physically cleaned.
Set a written schedule for cleaning
Document when cleaning occurs
Establish when flushing is to be done in writing in a Standard Operating rocedures.
Identify the material and amount to be used for equipment flushing
Document when flushing takes place.
Develop a written sequencing plan.
Post this plan in the control room or mixing area.
Review production records to make sure the schedule is being followed.
Follow these steps and you will be going a long way towards preventing drug carryover at your facility.
Rich Galutia CSP specializes in the areas of employee safety (OSHA), trucking compliance (FMCSA) and animal feed safety (FDA).