The Food Standards Agency (FSA) has allowed some pet food to be made in the same plant as food for human consumption.
In 2018, the FSA ran a public consultation on the subject with three potential scenarios. Based on responses, the agency went ahead with one of them. Manufacturing of pet food from ingredients fit for human consumption that contain products of animal origin (POAO) is permitted with the same equipment and rooms used for food for humans.
In December 2020, the FSA published guidance for food businesses and enforcement agencies in England, Wales and Northern Ireland. It also committed to review the document before December 2021.
Making human and pet food
The Food Standards Agency said it had received enquiries from firms and local authorities about the scope for food businesses to manufacture pet food.
The move may support companies in diversifying and reducing food waste but measures are needed to give consumers’ confidence in current controls, protect public and animal health and prevent food fraud, said the agency.
The Animal and Plant Health Agency (APHA) and Department of Agriculture, Environment and Rural Affairs (DAERA) are responsible for approval of pet food manufacturing. Pet food from non-animal ingredients does not need approval under the animal by-products (ABP) regulations but does require registration under feed hygiene legislation.
Commercial manufacturing of pet food in businesses also producing food for people needs to be done under conditions of strict separation, to eliminate the risk of cross-contamination of the human food chain or reintroduction of pet food into the food chain, according to the guidelines.
Any site already approved for producing food for people that also wants to manufacture pet food must notify the relevant authority before any dual operation starts. Any change will require revision and re-assessment of the Hazard Analysis and Critical Control Point (HACCP) based food safety management system. The firm will also need to apply for approval as a pet food plant.
The HACCP based management system needs to consider the potential cross-contamination risks and include a pest control plan. Records associated with making pet food must be kept for at least two years.
Consultation response
The guidelines state the pet food processing area and equipment can be shared with human food processing areas, provided they are used at different times or dates, but batch separation is also acceptable. Storage of pet food must remain separate from food, the same chillers or freezers can be shared, provided final products are identified and labeled, sealed and leak proof, and they are marked and designated for human food and pet food.
Unnamed firms producing pet food, the British Veterinary Association and Veterinary Public Health Association, the Wales Food Expert Safety Panel and the Pet Food Manufacturers Association responded to the consultation. Individuals including a food safety consultant and someone from environmental health said the proposals would make it easier for rogue traders to put pet food into the human food supply chain and increase the potential for food fraud.
After the guidance was published, the union Unison said the co-location decision for human and non-human food carries risks that the document does not consider.
Unison questioned if any food firm is suitably set up to have two separated areas and procedures to guarantee that the labelling is distinct for each food type.
“If many food business operators want to produce meat for humans and meat for pets, in the face of new export requirements arising from the new trade deal with the EU, we fear that mistakes may happen. These mistakes will only come to light if the industry is honest about them, or if the regulators find them. But it would be far better for the FSA to revise their approach and prevent mistakes from happening in the first place,” said Paul Bell, from Unison.
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