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Regulations: What 2022 Will Bring for Pet Food Processors

For 11 years, the standard for the food & beverage industry has been the Food Safety Modernization Act (FSMA). This federal law requires food & beverage operators, including pet food manufacturers, to comply with current good manufacturing practices (cGMPs) and other food safety measures, which focus largely on efforts to prevent contamination and the spread of pathogens. As FSMA rules and other regulations evolve and manufacturing technology advances, pet food processors must remain diligent in adhering to federal rules and upholding high standards for food safety.

Staying Current and Compliant


FSMA was signed into law in January 2011 and establishes standards for preventing food-borne disease and preserving a safe, high-quality food supply for the U.S. These rules apply to all foods regulated by the Food & Drug Administration—about 75% of the country’s food supply—so food & beverage operators, including pet food manufacturers, must be well versed in knowing and maintaining compliance with these rules.


From equipment upgrades, IT and OT integrations, and increased automation, the industry is experiencing frequent and rapid changes. Any increase in production capacity magnifies the importance of remaining FSMA-compliant. Larger manufacturers must ensure that food safety quality assurance (FSQA) managers, food engineers, and food safety compliance officers are well informed and systematic in their approach to communicating the need for and implementing safe, up-to-date processes from procurement through distribution. Smaller operators can contact their state Manufacturing Extension Partnership (MEP) advisor for guidance on aligning their processes with the latest regulations.


Recent FSMA Developments


Whether for R&D purposes or testing of products currently in production, pet food manufacturers must be aware of FSMA’s widening impacts as its implementation expands. The latest of the FDA’s final rules for FSMA is the establishment of the Laboratory Accreditation for the Analyses of Foods (LAAF) program. The program is designed to create uniform standards for food testing and enhance FDA oversight of participating labs. The rule will eliminate conflicts from contrasting third-party test standards and improve communication among regulators, laboratories, and pet food processors.


The new rule took effect February 1, 2022, and grants the FDA authority to recognize accreditation bodies, set eligibility requirements for accrediting food laboratories, and establish standards for food testing under certain circumstances specified in the rule. In these instances, manufacturers of human-grade food and pet food must use LAAF-accredited laboratories for testing.

From equipment upgrades, IT and OT integrations, and increased automation, the industry is experiencing frequent and rapid changes.

State Regulations Also Come into Play


States can also impose their own regulations on the food & beverage industry that go beyond federal regulations. For example, California’s Proposition 65, otherwise known as the Safe Drinking Water and Toxic Enforcement Act of 1986, continues to update a long and growing list of toxic chemicals every year.


Businesses must provide “clear and reasonable” written warnings to Californians if they may be exposed to potentially unsafe levels of carcinogens or reproductive toxicants. Warnings are only required if the rate of exposure to a listed chemical exceeds the limits established under Proposition 65, but these limits assume daily exposure and are relatively low.


Some companies—such as California pet food company Young Again—have chosen to add the Proposition 65 warning information to its food labels as a legal precaution, even though its products are contamination-free. “We use only lab-tested, safe ingredients approved by AAFCO, the U.S. government agency responsible for approving pet food ingredients,” the company states. “To be clear, none of the contents of our food are on the CA Prop 65 list of harmful ingredients. The statement has merely been added as a precaution so that we can continue to provide our pet food to California residents.”


Recordkeeping Is Key


To ensure maximum food safety and successfully navigate testing and audit procedures, pet food manufacturers must maintain proper records of their processes, including data regarding QA and sanitation that reflect regulatory compliance.


As regulations become more numerous, pet food processors can implement cloud-based software programs to monitor their efforts in real time. This includes tracking dates, deadlines, schedules, timelines, and the technical/operational details for systematically achieving compliance throughout the year. “Reg tech” tools include blockchain, artificial intelligence, automation, and machine learning, which help break through manual, siloed processes that can be inefficient, slow, and prone to error. “Implementing the right technology (and integrating those technologies thoughtfully where necessary) shores up gaps and creates a streamlined compliance process,” states Ascent, a reg-tech company.

"Implementing the right technology (and integrating those technologies thoughtfully where necessary) shores up gaps and creates a streamlined compliance process."

Looking Ahead


FMSA and Prop 65 are just two of the many regulations that affect pet food manufacturers. The regulatory landscape for the food & beverage industry will continue to evolve to provide greater product safety and quality—from the first supply chain shipments of raw materials through production and distribution. Successfully maintaining compliance and food safety requires a proactive approach to regulation that’s grounded in awareness and clear communication. Coupled with the latest IoT technologies, such an approach will streamline the compliance process, improve product quality, reduce or eliminate recalls, build customer loyalty, and reduce overall compliance costs.

Some opinions expressed in this article may be those of a contributing author and not necessarily Gray.

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