VOLUNTARY MODULE 9 MANAGEMENT OF FOOD MATERIALS FOR ANIMAL FEED

Transcription

1 BRC GLOBAL STANDARD FOOD SAFETY ISSUE 7 VOLUNTARY MODULE 9 MANAGEMENT OF FOOD MATERIALS FOR ANIMAL FEED Supplementary Documents Judith Nelson

2 What is AIC? The Agricultural Industries Confederation (AIC) is the agrisupply industry s leading trade association. The trade association represents several sectors within the agrisupply industry including: Animal Feed; Crop Protection and Agronomy; Fertilisers; Grain and Oilseed; Seed. AIC works on behalf of its Members by: Lobbying policy makers and stakeholders; Delivering information; Providing Trade Assurance; Offering technical support. Who do we represent? AIC Members represent the agrisupply industry which provides inputs into the agricultural and farming sectors. The sectors and % representation is shown below: Animal Feed 90 % Crops Protection and Agronomy 90 % Distributors Fertilisers 95 % Grain and Oilseeds 90 % Seed 80 % UKFFPA The United Kingdom Former Foodstuffs Processors Association (UKFFPA) is an affiliated association of the AIC. VM002 issue 2 Management of Food Materials for Animal Feed - Supplementary Documents 1 of 9 28/8/2015 Page 1

3 Regulation 183/2005 on feed hygiene and the supply of former foodstuffs Introduction Any company involved in the supply of former foodstuffs and vegetable oils and fats for use as feed for farmed livestock must comply with Regulation 183/2005 on feed hygiene which contains provisions aimed at improving: feed safety; the operational standards of feed businesses and; traceability measures so that, in the case of contamination, feed products can be easily traced and recalled if necessary. The supply of former foodstuffs and vegetable oils and fats includes both the:- physical storage and transport of this feed material and; handling the paperwork and arranging the storage and transport. Under the terms of the Regulation 183/2005 on feed hygiene, a company involved in the supply of material from the food or drink industry for feed use is a feed business. Materials for feeding animals are not waste products and their transportation is not subject to a waste transfer licence. Food Standards Agency (FSA) Guidance The following is extracted from the FSA s document Summary of Requirements for Food and Drink Businesses that Supply Material for Animal Feed Use (Regulation 183/2005). Scope Virtually all feed businesses that produce, supply or use animal feed, are covered by the scope of Regulation 183/2005. This includes:- food and drink businesses (including retailers) that supply products for animal feed use (including for pet food) and intermediary companies involved in the storage and transport of these products; Prohibitions Where appropriate, it is particularly important that systems are in place to ensure that products prohibited for use in animal feeds (in particular, animal products such as meat and fish) do not enter the farmed livestock feed chain. Specific Requirements In general terms, any food and drink business that puts into circulation, material for feed use (including pet food) comes within the scope of the Regulation. Some examples (non-exhaustive) include: food and drink manufacturers supplying former foodstuffs(e.g. out-of-date products, products that do not meet the required specification, or surplus ingredients such as dough. This may include biscuits, bakery products, confectionery, pasta, pastry, dairy products such as ice cream, potato chips or cereals that are the wrong size or shape; leftover dough and liquid chocolate, surplus bread collected from retailers and bakeries; vegetable oils and fats from the food industry that are processed and blended into animal feed). retailers that supply former foodstuffs for feed use. These may include major supermarkets or smaller retail outlets such as bakeries. VM002 issue 2 Management of Food Materials for Animal Feed - Supplementary Documents 2 of 9 28/8/2015 Page 2

4 Often food and drink manufacturers and retailers sell products to an intermediary such as a former foodstuffs processor, who processes the material for animal feed use. In other cases, food businesses may sell products direct to farms. In all these cases, the company supplying the products from the food and drink sector must comply with the requirements of the Regulation. A food business which is supplying a product, such as dough, only for use in food production or sale to consumers does not need to register as a feed business operator. It is likely that the vast majority of food and drink establishments supplying products for feed use will be carrying out activities subject to the registration requirement. The retail sale of surplus food direct to consumers for use as pet food is not an activity which requires registration. Registration involves completing a form which can be found on the FSA website at: completed form must be sent to the local authority where the activities requiring registration are undertaken. The local authority will add this to their register of feed businesses and their inspection programme.. The other main requirements of the Regulation 183/2005 on feed hygiene with which food and drink businesses must comply The Regulation contains various operational requirements with which businesses must comply and which are set out in the Annexes to the Regulation. Annex II is applicable to businesses supplying the feed chain, and includes requirements relating to:- facilities and equipment; personnel; production; quality control; storage and transport; record-keeping; and complaints and product recall. In addition, businesses are required to apply the principles of a HACCP system. It is important to note that the extent of the application of Annex II and HACCP will depend on the nature of the activities being carried out. For example, at food and drink business establishments, including those businesses involved in storage and transport, the requirements will apply to the relevant operations that relate to products that are to be supplied for feed. Many food businesses will have a form of HACCP in place to cover their food operations and it may extend these to materials designated for feed. Key aspects include measures to ensure that material is not contaminated and record-keeping to ensure that material can be traced in the event of a feed incident. Documents and records that must be kept should be commensurate with the nature and size of the business. This full text of the FSA s document Summary of Requirements for Food and Drink Businesses that Supply Material for Animal Feed Use (Regulation 183/2005) is available from the following link:- The FSA s document also provides information on:- how food and drink businesses and intermediary companies apply for registration; the other legislation with which feed business operators have to comply. This includes the Animal By-Products Regulation which bans the use of meat and meat products in feed for farmed livestock. The Feed Hygiene Regulation is available from the following link:- VM002 issue 2 Management of Food Materials for Animal Feed - Supplementary Documents 3 of 9 28/8/2015 Page 3

5 Regulation 767/2009 on the Marketing and Use of Feed labelling Labelling serves enforcement, traceability and control purposes. In addition, labelling provides the necessary information to purchasers and it should be consistent, coherent, transparent and understandable. Article 12.2 of Regulation 767/2009 specifies that the person responsible for the labelling Shall be the feed business operator who first places feed on the market or, where applicable, the feed business operator under whose name or business the feed is marketed. Regulation 767/2009 defines feed materials as meaning:- products of vegetable or animal origin, whose principal purpose is to meet animals nutritional needs, in their natural state, fresh or preserved, and products derived from the industrial processing thereof, and organic or inorganic substances, whether or not containing feed additives, which are intended for use in oral animal-feeding either directly as such, or after processing, or in the preparation of compound feed, or as carrier of premixtures; Regulation 767/2009 also contains, in Article 3, a number of other definitions. Commission Regulation 68/2013 introduces the second update of the EU catalogue of feed materials. This Regulation:- is established under Article 24 of Regulation 767/2009; is a non-exhaustive list of feed materials and a voluntary tool aimed at improving market transparency; includes in Part C List of feed materials Category 13 Miscellaneous - a number of feed materials from the food and drink industry; for example, Products from the bakery and pasta industry. Each individual entry also includes a definition and list of compulsory declarations. When a food and/or drink manufacturer is supplying a feed material to either a former foodstuffs processor or direct to farm, the product will need to be labelled by that company. The following is a specimen label of a feed material being supplied by a food and/or drink manufacturer to either a former foodstuffs processor or a farmer. Potato Mash This is a feed material and is listed in the EU Feed Catalogue at No The company making this declaration is XXXX, address YYYY. The company is registered by the Local Authority: Registration No. GB AAA BBBB Batch Ref Number see weighbridge ticket number Net Quantity - as shown on weighbridge ticket Analytical declaration: moisture 78%, starch 13%, crude fibre 1%. VM002 issue 2 Management of Food Materials for Animal Feed - Supplementary Documents 4 of 9 28/8/2015 Page 4

6 For information, the following is a specimen label of a feed material being supplied by a former foodstuffs processor to either a compound feed manufacturer or direct to farm. Super Biscuit Description This is a complementary feed. Composition Products and By Prod - Savoury Snacks Industry Products from the Bakery and Pasta Industry Sugar - Products from the Confectionery Industry Rice Bran and Germ Meal Biscuit - Products from Bakery and Pasta Industry Analytical Constituents - General Profile Crude Protein (%) 9.0 % Crude Oil (%) 15.0 % Crude Fibre (%) 2.3 % Crude Ash (%) 2.9 % Sodium (%) 0.30 % Lysine (%) 0.44 % Methionine (%) 0.18 % Feeding recommendations Poultry up to 7.5% of total ration Pigs over 10kg up to 20% of total ration Growing cattle up to 3kg and up to 40% dry matter intake Dairy Cattle up to 3kg mixed with other feeds Ensure adequate source of long fibre such as silage or straw for cattle Store in a cool dry place Manufacture Premises Joe Bloggs, Joe Bloggs House, Joe Bloggs Lane FEMAS - certificate ends Feed Hygiene Regs 183/2005 Reg No: GB-020-N Batch No. -- See attached weighbridge ticket number Date see w/b ticket Version 23 Best before 90 days VM002 issue 2 Management of Food Materials for Animal Feed - Supplementary Documents 5 of 9 28/8/2015 Page 5

7 Regulation 1069/2009 on Animal By-Products (ABPs) and Regulation 999/2001 on TSEs Guidance on Restricted Products The following is an extract from Defra and Animal Health and Plant Agency (AHPA) Guidance on How food shops, manufacturers, and distributors must dispose of or handle former foodstuffs or food waste of animal origin or contain products of animal origin If former foodstuffs or food waste are of animal origin or contain products of animal origin, they must be handled or disposed of in a way that doesn t pose a risk to human or animal health. When foods become former foodstuffs Foods of animal origin or foods that contain products of animal origin and are intended for human consumption may be removed from sale when they: have passed their sell by or use by date are visually imperfect, or have damaged packaging are spoiled, mouldy, or decomposing The manager of the site must then make the decision that the foodstuff is no longer intended for human consumption. At this point the foodstuff becomes an animal by-product (ABP) and this decision can t be reversed. Risk groups for former foodstuffs category 3 ABPs All former foodstuffs of animal origin or contain products of animal origin are category 3 ABPs and they are classed as low risk. Within this they can be divided into 3 groups, based on the risks they pose when disposing of them. Higher and medium risk The following products must not be used to make from animal feed: raw meat, fish, and seafood in packs or loose which needs to be cooked before eating raw sausages, bacon and gammon raw meat, poultry, fish or seafood items in any coating (like breadcrumbs or batter) or sauces (eg barbeque, curry etc) raw burgers raw eggs (including shells) untreated milk all raw meat and fish that come from food production, even if they were not meant to be cooked before human consumption partially cooked meat sashimi (raw fish) or sushi containing sashimi smoked dried or cured meat, eg bresaola, beef jerky, salami, parma ham, chorizo etc any meat and fish products, that are fully pre-cooked any products that contain cooked meat or fish cooked prawns, dressed crabs and lobsters, seafood sticks, cooked ready to eat mussels shells from cooked seafood and eggs ready meals (meals for reheating where the meat or fish is precooked) pies and pasties (including sausage rolls) and pizza where the meat is pre-cooked highly processed meat and fish products in cans, jars, pouches or shelf stable aluminium packaging dried animal products - eg powdered soups VM002 issue 2 Management of Food Materials for Animal Feed - Supplementary Documents 6 of 9 28/8/2015 Page 6

8 flavourings or other highly processed animal products stock cubes made using meat or fish extracts fats or dripping that came from cooking meat or poultry greaves honey jam containing ruminant gelatine. Lower risk Any of the following products can be used to make farm animal feed: bakery and confectionery products that don t contain meat, fish or shellfish milk or milk products - (see separate guidance note) egg or egg products animal fats and fish oils Catering waste Catering waste, including swill is banned from use in either farm animal or pet food. Any waste food (including used cooking oil) that comes from restaurants, catering sites, commercial or household kitchens is defined as catering waste. Emptying into separate containers There should be a separate container for: bread and bakery products raw meat and fish products other food products Any company using this method must make sure it: moves the materials in their containers for separate storage in a bulker or transport unit keeps each container 1.2 metres apart and only fill them from the front separates the containers and area 1.2m in front with temporary barriers, eg cones cleans the containers at the end of the day or the end of the shift Separate area An entirely separate area can be used at a site to store or hold roll cages containing ABPs. Any company using this method must make sure that: it s clearly delineated from areas where former foodstuffs ineligible for feeding are stored there are separate storage areas for foods that can be used for feed and foods that can t, with a solid boundary, a pallet s width away there are signs that clearly show the area is meant to be used as storage for foodstuffs eligible for feeding only VM002 issue 2 Management of Food Materials for Animal Feed - Supplementary Documents 7 of 9 28/8/2015 Page 7

9 Legislation Extracts from ACAF (Advisory Committee on Animal Feedingstuffs) Information Paper and FEMAS Sector Notes on Former Foodstuffs Traces of packaging material in feed derived from former foodstuffs Annex III of Regulation 767/2009 on the marketing and use of feed classes packaging from the use of products from the agri-food industry, and parts thereof as being prohibited for animal nutrition purposes. This prohibition has been interpreted as being a ban on the presence of residues of food packaging material in animal feed, as well as the use of the packaging material per se. Tolerances for traces of packaging material Feed processors routinely remove the packaging from surplus food mechanically. While this removes most of the packaging, small amounts can remain in the feed material. European Union Member States generally agree that a zero tolerance for these traces is neither practical, nor proportionate to the risk. In the absence of any guidance from the European Union, the UK s Food Standards Agency has adopted a tolerance of 0.15% in line with Germany and the Netherlands. However, this stance would be subject to revision once advice from EFSA is available. The operation and enforcement of the de facto tolerance will be reviewed by the Food Standards Agency. FEMAS The FEMAS Sector Notes for Former Foodstuffs states the following in relation to the control of packaging residues:- Section 3 Resources and good hygienic principles The aim of participants must be to reduce the presence of residual packaging to a level where it is very difficult to detect in the feed ingredients supplied. This must be achieved by removal of packaging and not simply by disguising the problem through reduction in particle size. The presence of any obvious residual packaging must be considered unacceptable. Section 5 Product safety management Residual Packaging In addition to removing packaging included with raw materials, processors must demonstrate all practical efforts have been made to ensure extraneous packaging is also being addressed at source (ie not entering raw material containers in the first place). The raw material risk assessment should identify, where appropriate levels or types of packaging, the presence of which would result in rejection or additional processing being required. VM002 issue 2 Management of Food Materials for Animal Feed - Supplementary Documents 8 of 9 28/8/2015 Page 8

10 Extract from Defra and AHPA Guidance - Using leftover milk and milk products as farm animal feed The following milk and milk products can be processed for use in feed products for general sale, or sent to farms unprocessed: milk and milk products fit for, but no longer intended for, human consumption by-products of the milk processing industry such as whey, centrifuge or separator sludge from a processor White water (water used to clean dairy equipment) can only be sent to farms unprocessed. It can t be processed for use in feed products for general sale. The following milk and milk products can t be used in any type of farm animal feed: milk or milk products from catering sources (kitchens or canteens in homes, restaurants or other businesses) milk directly from a farm (unless the farm is also a registered milk processing establishment, where it is treated as a dairy or creamery) If classical scrapie is confirmed in a sheep flock or goat herd, you may not be able to use milk from the flock in feed for ruminants (cud-chewing mammals such as cattle, sheep, goats and deer). Milk and milk products that will be used in feed products must be processed at either of the following: an approved ABP processing facility a milk processing establishment (milk processors don t need additional approval under ABP regulations) VM002 issue 2 Management of Food Materials for Animal Feed - Supplementary Documents 9 of 9 28/8/2015 Page 9