Upcoming Compliance Dates for Animal Food Manufacturers

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Last September (2016), was the first implementation of FSMA for animal food manufacturers. Because of the staggered compliance dates, large businesses (> 500 full-time equivalent employees) were only required to be compliant with Current Good Manufacturing Practice requirements at that time. This year (2017), marks important compliance dates for large businesses and small businesses (< 500 full-time equivalent employees). It is important to be aware of the distinction between large and small businesses, with respect to full-time equivalent employees (FTE). The size of a business is classified based on the total number of employees working for the parent company, which doesn’t necessarily mean just the facility for which the food safety plan is written. Part-time employee hours are also considered in calculating the amount of FTE for a given company or facility. 

Large businesses will be expected to have a written food safety plan (written or signed off on by a Preventive Controls Qualified Individual) and be compliant with the remainder of the preventive controls for animal food rule. For more information on the requirements of the preventive controls for animal food rule and the food safety plan, please visit our website.

Small businesses, those with less than 500 FTE, will reach their first FSMA compliance date on September 18, 2017. At this time, small businesses will be expected to be compliant with Current Good Manufacturing Practices (CGMP). With this compliance comes mandatory employee training on animal food safety and hygiene to ensure all employees meet the requirements of qualified individuals. Small businesses then have one year (September 17, 2018) to become compliant with the remainder of the preventive controls for animal food rule, which includes having a written food safety plan.

In a recently released article, Jenny Murphy, a consumer safety officer at FDA’s Center for Veterinary Medicine, provided some insight as to what to expect with these upcoming compliance dates and inspections.

If you or anyone in your facility is interested in attending the Preventive Controls for Animal Food course offered at NC State, or have any questions concerning FSMA for animal food, please contact Marissa Herchler for more information.