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welcome to animal food hygiene and animal food safety this module was developed to help animal food facilities meet the personnel training requirements of the preventive controls for animal food rule of the Food Safety Modernization Act hi my name is dr. Cassie Jones I'm an associate professor in the department of animal sciences and Industry at Kansas State University I'm also a member of the food safety preventive controls Alliance which is an alliance of regulatory academic and industry people who have bridged together to help provide training on the Food Safety Modernization Act as part of that alliance I'm a member of the steering committee and I actually served as lead editor of the animal food training curriculum that's being used to train both inspectors and Industry on the preventive controls for animal food rule through the F SPCA I'm both a trainer of trainers and a lead instructor the objectives of this short module are to first understand the regulatory requirements or the rules of personnel that are going to manufacture process pack or hold animal food I'll also plan to explain the importance of animal food hygiene and animal food safety and identify expectations for employee health and personal hygiene I'll also highlight other areas where personnel may impact animal food safety and finally a description of how you can document this training in a way that meets the expectations associated with the animal food with the preventive controls for animal food rule so we'll start out with why is animal food safety important and in general well first it's just the right thing to do as individuals who manufacture process pack or hold animal food we take that commitment very seriously because we understand that our day-to-day efforts can impact both animal and human health we also consider the importance of animal food because it's what our customers expect in order to stay in business in this day and age it's an expectation that the product is not only high quality but of course safe for consumption and because of that improving and maintaining animal food safety is just good business sense and finally animal food safety is now the law with the preventive controls for animal food rule we now have regulatory requirements that make sure that our animal food is safe and specifically this training is focused on helping make sure that individuals understand their expectations for maintaining their employee hygiene and personal health to make sure that the animal food is safe so let's talk about those regulatory requirements in title 21 of the Code of Federal Regulations part 507 and there is a section called section 4 which identifies the qualifications of individuals who manufacture process pack or hold animal food and so the expectation in the regulation lays out that all of the individuals engage in those active processes manufacturing processing packing or holding that food whether they are supervising or actually doing those activities whether they are full-time or part-time employees temporary or seasonal personnel if they're engaged in those active processes there are specific expectations first individuals need to be qualified individuals meaning that they have the education training or experience or some type of combination of those necessary in order to do their job appropriately or necessary to manufacture process pack or hold safe animal food as appropriate to their assigned duties second the expectation is that these individuals receive training on the principles of animal food hygiene and animal food safety including the importance of employee health and personal hygiene as appropriate to the animal food the facilities and the individuals assign duties and the second part is really the goal of this training module in most of our facilities I would argue that we do a pretty good job of making sure that individuals are qualified for their job to manufacture process pack or hold animal food in a safe way the second part is one that at least in my experience I've identified as a gap prior to FISMA implementation where most facilities did not have cific recognized training on the concepts of animal food hygiene and animal food safety and so that's the intent of what this module will be focused on so let's talk about those what are the principles of animal food hygiene and animal food safety well to start with we have to understand that animal foods including raw materials and ingredients may be a vector for hazard transmission into the food chain and therefore it can impact both animal and human health and I don't want to say that this is highly common in fact I would emphasize that the US feed supply is the safest in the world that said we've still had instances where raw materials ingredients or finished product have been a vector for hazards that have impacted both animal and human health and because of that this concept of animal food hygiene and animal food safety is highly important second we have to understand that we as people the personnel who manufacture process pack or hold animal food play a key role in preventing its contamination a number of times we have the capability to either prevent or sometimes by accident impact the safety of animal food or animal food hygiene and so we have to take that responsibility very seriously and understand that we as personnel can play this key role of preventing contamination so let's talk about some of those examples some common examples of hazards that may be impacted by personnel could potentially be undesirable microorganisms where perhaps an individual has an undesirable microorganism like Salmonella or Listeria monocytogenes on their hands or on their clothing and goes and touches finished product that's intended for consumption by a pet in that way an individual could contaminate the finished product secondly we as individuals have the ability to accidentally drop metal objects or other foreign material into animal food or processing equipment we may make mistakes that have caused nutrient deficiencies or toxicities by either not adding enough or adding too much of the dead they needed premix or accidentally adding the wrong one or finally similarly we can see that there can be impacts of personnel on drug carry overs maybe we forget to sequence the diets in the correct manner which leads to unintended drug carryover that can cause a hazard in a separate species and so we'll talk about each of these in a little more detail moving forward which leads us to the role of employee health and personal hygiene and here the goal is that we prevent employees from being a potential vector of spreading undesirable microorganisms like Salmonella or Listeria monocytogenes or other hazards to animal food so how can we make sure that people and both their health and hygiene are maintained to prevent any hazards to animal food first we would do this by maintaining adequate personal cleanliness second by washing hands thoroughly as necessary for the type of animal food we would remove or secure jewelry and other objects as appropriate we would store clothing or other personal belongings appropriately in designated locations and finally we would take any other necessary precautions to protect against the contamination of the animal food any surfaces that that animal food is manufactured on or any packaging material that's going to be used to package that animal food so again we'll cover each of these in more depth beginning with how we could maintain adequate personal cleanliness and what it means maintaining adequate personal cleanliness is really the goal of how clothing or hands are used so that they're not a source of contamination for example hands should be washed or sanitized as appropriate for the type of animal food such as after using the toilet if our hands our clothing become contaminated with process related chemicals or before touching animal food the surfaces on which animal food is manufactured processed packed or held or the packaging material that it's going to be going into this is particularly important if the animal food is a potential source of the undesirable microorganisms where we might move from a raw to a finished area we may need to make sure that our hands and clothing are not a potential vector or source of contamination into the finished secondly it's important for employees and personnel to wash hands thoroughly in an adequate hand-washing facility as necessary and appropriate to protect against against contamination we do understand that the use of hand sanitizers may be adequate when hand washing facilities are not readily available or there is not a high risk of pathogen transmission for that type of animal food however we have to understand that hand sanitizers are appropriate only if our hands are clean they'll only be effective if we start with clean hands and then they're used to sanitize at that point effective hand-washing includes the application of soap and warm water rubbing hands together vigorously for about 20 seconds rinsing hands with warm clean water and drying hands with a clean towel or air dryer so that the drying material does not serve as a source of recontamination to our hands third one of the things we can do in terms of employ in terms of employee health and personal hygiene is remove or secure jewelry or other objects that might fall into animal food equipment or containers for example personnel should maybe not wear jewelry unless it's secured and unable to create a hazard some facilities have a no jewelry policy altogether other facilities have policies or expectations that if jewelry is worn it is tightly secured and not capable of falling off of the hands or falling off of the ears where it could create a hazard of the in the animal food itself but we also have to think about other objects outside of jewelry commonly we see tools may be cellphones or radios pens and personal protective equipment all of those also need to be secured by by tethers or by making sure that they are and confined pockets or holders with the real goal of those products or objects not creating a hazard by accidentally falling into animal food equipment or containers fourth we'll plan to store clothing or other personal belongings in areas other than where animal food is exposed or where we're equipment or utensils are clean for example things like gloves jackets frocks coveralls and boots or other clothing should be stored so that it's not going to create a hazard or a potential animal food safety hazard where it could potentially fall into the animal food manufacturing equipment or it could contaminate it in some way finally personal belongings like the sunglasses that are seen here or even utensils such as the utility knife that's being used in this picture should be kept outside the area where animal food is manufactured processed packed or held the goal here is to again prevent any of these products from falling into animal food or serving as a source of contamination and finally we would need to take other necessary precautions to protect against the contamination of animal food animal food contact surfaces or animal food packaging material so there's a number of ways that we could do this one of those would be to restrict or exclude ill or sick employees from working in direct contact with food contact surfaces or packaging material this would particularly be in the cases of some illnesses where we would have contagious diseases or disorders illnesses or open sores or if we have a fever diarrhea or vomiting in those circumstances we would have employees avoid contact with food the contact surfaces or packaging material report symptoms to management or obtain medical attention when appropriate this is going to change from one type of animal food to another but it's always a good idea that if you have symptoms fever diarrhea or vomiting and you're feeling ill to report that to management and think about what is the role of your illness and employee health on the potential safety of that animal food other precautions that may be taken by some facilities include implementing biosecurity procedures for example we may see facilities that are implementing how personnel move through the facility so that they prevent cross-contamination from insanitary objects and personnel to animal food the surfaces on which it's manufactured or its packaging material we would try to limit the movement of raw material to the process product area and restrict personnel traffic to areas where animal food is manufactured processed packed or held and as part of that immediately report any unauthorized personnel in those locations there are a few areas where personnel may specifically impact animal food safety one of those would include plant and grounds and here we would expect employees to maintain or personnel to maintain and our plant and grow and grounds to protect it against contamination of animal food more specifically it would be important to properly store equipment remove litter and waste and cut weeds or grass in the area near the plant the goal here would be activities that we as personnel could do in order to minimize any pests harborage or any potential source of contamination that may be a part or potentially contaminate the animal food secondly there are some expectations with sanitation we as personnel are expected to keep buildings structures fixtures and facilities clean and free of trash and in good repair to prevent adulteration of the animal food we would clean maintain and properly store utensils such as shovels and scoops and buckets and the equipment and we would also restrict toxic materials from the facility unless they are going to be used for cleaning in laboratory testing as part of operations or maintenance in those cases where toxic materials are used they they still need to be labeled used properly and stored properly so that they don't lead to contamination for example in our feed mill we can use petroleum-based greases on non animal food contact surfaces but we would make sure that that petroleum-based grease is labeled properly used in a way that's safe and stored properly as such as in this chemical safety cabinet but it's not going to be a potential source of animal food food contamination we as personnel also have an expectation to make sure that equipment and utensils are safe for the animal food we would make sure that we're choosing shovels scoops and other utensils and equipment designed and constructed in a way to be cleanable we would need to make sure that they are properly maintained and have a responsibility of making sure we use them in a way to avoid adulteration for example the edge of the shovel that's in the picture clearly has been used in a way that was not safe it was obviously shoved into a piece of equipment that potentially damaged the shovel and we would need to be careful and think about maybe throwing it or grinding down the base if it was in a feed mill or in a grain elevator to make sure that that edge does not come off and potentially lead to metal fragments in the animal food and so we would need to make sure that our utensils and equipment are used in a way to avoid adulteration from things like non food grade lubricants fuel metal fragments contaminated water or other contaminants whenever we're operating the facility we also need to make sure that our raw material rework or finished product are accurately identified unlike that which is pictured and here in the picture in this slide and we also have a responsibility of examining raw materials to ensure that they're suitable for manufacturing into into animal food this would be by examining shipping materials or containers or the paperwork that they come on cleaning those raw materials when necessary and making sure that they're stored properly or evaluating raw materials that are susceptible to mycotoxin contamination so that we can make sure that they're used safely finally we also need to make sure that we're handling raw materials in a way to protect against contamination and to minimize any deterioration is that their safe for use and finally the last area where we could potentially as personnel impact animal food safety isn't its holding and distribution it's our responsibility to hold animal food to protect against its contamination or any potential trash to do this we need to make sure that we're labeling animal food that's ready for distribution and when applicable include labeling for safely using it in the intended species for example if we have a premix that's high in a specific copper level we may need to make sure that it's labeled for specific species that someone does not and accidentally feed it to sheep and cause copper toxicity issues it's our responsibility to examine ship in containers before use such as the one that's pictured here and that can be either through visual examination or through an evaluation of paperwork or other means to make sure that what was previously hauled in that ship in container is not going to cause an intentional adulteration of the product that's going to be loaded next and finally occasionally we may see facilities that will accept returned animal food if so we need to assess return to animal food for safety so that they can determine its appropriate disposition as part of this we need to make sure that any of that returned animal food is identified and segregated until it is assessed and then it's disposed of or utilized in a safe manner so that's it we have now completed this training on the principles of animal food safety and animal food hygiene and so I expect from this point that you also make sure to conduct Duty specific training this specific module is in is by no means sufficient for all of the training expectations follow-up training would include to make sure that there is associated training on making sure that individuals and personnel understand how their specific role is important for maintaining animal food safety and animal food hygiene and manufacturing processing packing are holding animal food in a safe way for their specific job duties that said this piece requires documentation ing to the preventive controls for animal food rule those records need to be maintained for at least two years and as part of this documentation the regulatory requirements include that you must include information adequate to identify the facility such as the name and address the date that this training was completed and the signature initials of the individual who's performing the activity finally I highly suggest that you consider periodic refresher training whether it's rewatching this module and documenting that activity or you conduct in-person refresher training it's important to remind your employees and personnel working within your facility of these expectations that we can maintain a conscious effort on manufacturing processing packing or holding animal food in a safe way