Cargill Feed Safety and Regulatory

Cargill Feed Safety and
Regulatory
June 5th, 2018
CONFIDENTIAL. This document contains Cargill Confidential information. Disclosure, use or reproduction outside Cargill or
Cargill Feed Safety inside Cargill, to or by those who do not have a need to know is prohibited. © 2017 Cargill, Incorporated. All rights reserved. © 2017 Cargill Incorporated. All rights reserved.
www.cargill.com
Introductions
Krystal Gage Clover Heneger
Feed FSQR Manager Enterprise Feed Specialist
Starches & Sweeteners North America Starches & Sweeteners North America
Oversight of quality, feed safety and regulatory Branded Feed process trials, quality systems and
programs for SSNA branded Feed plant locations process improvements
• Blair, NE – Cargill’s largest asset in the world! • Management of feed safety programs and systems
• Fort Dodge, IA
• Feed production support
• Eddyville, IA
• Dalhart, TX
• Bovina, TX
• Dayton, OH
• Wahpeton, ND
2 Cargill Feed Safety © 2017 Cargill Incorporated. All rights reserved.

Cargill History
Founded in 1865
• Small grain warehouse in Conover, Iowa
• Expansion of the company followed the expansion
of railroads
• Cargill consists of several global operations
• Food Ingredients & Bio-Industrial
• Animal Nutrition
• Protein & Salt
• Agricultural Supply Chain
• Metals & Shipping
• Risk Management
• Transportation and Logistics

Starches and Sweeteners North
America (SSNA)
• 2,140 Employees
• 9 Manufacturing facilities
• One of four major global product groups in the Food Ingredient &
Bio-Industrial Enterprise (FIBI)
– Cocoa & Chocolate (CCC)
– Global Edible Oil Solutions (GEOS)
– Malt
– Starches, Sweeteners & Texturizers (CSST)

Starches and Sweeteners North
America – Feed Products
BRANDED FEED PRODUCTS COMMODITY FEED
• Empyreal® • Corn Gluten Meal
• Sweet Bran® • Corn Germ Meal
• SB Plus • Corn Gluten Feed
• RAMP® • Sweet Gluten Feed
• OneTrak® • Corn Gluten Feed Pellets
• Value driven by added benefits and • Widely sold on the market, prices based on
services to our customers market trade value
• “Everyone makes them”

Feed Safety and Regulations in
Industry
FOOD SAFETY MODERNIZATION ACT (FSMA)
• Rules for Animal Food Preventative Controls – Rules published by the FDA
– Firms shall register with the FDA
– Good Manufacturing Practice Requirements (GMP)
– Establish and implement Food/Feed Safety systems
• Hazard analysis, preventative/process controls, sanitation, etc.
• Management of preventative controls – monitoring, corrections, corrective actions, verification
– Supply chain management
• Risk assessment for suppliers
• FDA/CVM
– Increased inspection rights
– Access to all food/feed safety documents and records
– Forced recall

Feed Safety and Regulations in
Industry
VETERINARY FEED DIRECTIVE
• Veterinary Feed Directive (VFD)

– Effective January 1, 2017
– Process for authorizing use of animal drugs intended for use in animal feed that require the supervision of a
licensed veterinarian
• VFD Drug
– Drug intended for use in or on animal feed
– Applies to medically important antimicrobials in feed when needed for specific animal
health purposes
• VFD
– Written statement issued by a licensed veterinarian in the course of the veterinarian’s
professional practice, ordering the use of VFD drug or combination VFD drug in or on an
animal feed

Consulting Bodies
FOOD AND DRUG ADMINISTRATION / CENTER FOR VETERINARY MEDICINE (CVM)
• FDA regulated both food and feed

• Center for Veterinary Medicine (CVM) is the animal side of the FDA
– Derive authority from Code of Federal Regulations
• BSE – Bovine Spongiform Encephalopathy
– 21CFR589 – Substances Prohibited from Use in Animal Food or Feed
• Medicated Feed
– 21CFR225 – Good Manufacturing Practice for Medicated Feeds
• Facility inspections
• Recall authority
• Reportable Food Registry
• GRAS notification

Consulting Bodies
AAFCO – ASSOCIATION OF AMERICAN FEED CONTROL OFFICIALS
• Organized in 1909
– Standard feed laws and regulations
– Feed definitions
– Feed labeling requirements
– Members: State Regulators and FDA and CVM representatives
– No enforcement power itself – Most states adopt

Feed Regulations
Feed Tags and Placards
• Feed labels are legal documents
• Incorrect feed labels with a load are
considered misbranding and can result in a
fine
• Information on the feed labels is dictated by
the state and AAFCO
• South Dakota requires sulfur to be listed on
the feed tag
• High Aflatoxin must be declared on the label

Feed Safety
WHY IS FEED SAFETY IMPORTANT
• Animal welfare and health
• Safety of the food produced by an animal (eggs, milk, meat, fish, poultry)
• Safety of the people handling the feed

Feed Safety
WHAT IS FEED SAFETY
• Food/Feed safety is the process of anticipating and controlling hazards in the products we
manufacture
• Our Feed Safety program is made up of two parts:
– Pre-requisite Programs (PRPs) + HACCP Principles (Hazard Analysis Critical Control Points)
• Our programs have no CCPs for Feed

• PRPs have replaced GHPs and GMPs

Feed Safety
WHAT IS FEED SAFETY

• Feed hazards can be grouped into the following categories;
– Chemical: pesticides, lubricants, mycotoxins (Aflatoxin)
– Biological: BSE (mad cow disease), pathogens
– Physical: glass, wood, metal, plastic
– Radiological: radiation, uranium, nuclear waste

Feed Safety
CHEMICAL HAZARDS
• Aflatoxin
– One of our biggest Feed and Food safety hazards
– Exposure to Aflatoxin can be either acute or chronic
• Acute – High levels can cause liver failure or Hepatotoxicity
• Chronic – Carcinogenic
– Can be expressed in cow milk as M1 toxin, potential impact to humans
– FDA Regulated
• Limits
– <20 ppb: Unknown animal, humans, immature animals
– <100 ppb: Adult poultry, breeding swine, breeding beef cattle
– <200 ppb: Swine over 100 lbs
– <300 ppb: Finishing beef cattle
– Cargill manages Aflatoxin through a rigorous testing program including testing of raw materials, in-process
and final product

Feed Safety
CHEMICAL HAZARDS
• Mycotoxins – 1000s of additional toxins, but • Fumonisin FDA Guidance
we monitor the following 6 in our programs – Swine and Catfish: <20 ppm*
• Aflatoxin (B1, B2, G1, G2) – Breeding ruminants, breeding poultry and breeding mink:
• Deoxynivalenol <30 ppm*
• Fumonisin (B1, B2, B3) – Ruminants ≥ 3 months old for slaughter: <60 ppm*
• T-2 Toxin – Poultry for slaughter: <100 ppm*
• Zearalenone – All other species or classes of livestock: <10 ppm*
• Ochratoxin
• Deoxynivalenol (DON) FDA Guidance
• Zearalenone FDA Guidance – Ruminating beef and feedlot cattle older than 4 months:
– <1000 ppb <10 ppm* / 5 ppm finished feed
– Chickens: Grain and grain by-products <10 ppm / 5 ppm
finished feed
– Swine: Not to exceed 20% of diet <5 ppm / 1 ppm
finished feed
– All other animals not to exceed 40% of the diet <5 ppm
*No more than 50% of the diet
Feed Safety
BIOLOGICAL HAZARDS
• Bovine Spongiform Encephalitis (BSE): Mad Cow Disease

• Title 21 Part 589 CFR
– Prohibits most types mammalian protein in food for ruminants - BSE High risk
– Meat meal, bone meal or products that contain meat meal (dog food) are not allowed
– Fish and poultry meal are ok because they are not mammals
• Focus on Prevention
– Our plants are mammalian protein free
– Prohibited back haul list

Feed Safety
BIOLOGICAL HAZARDS
• Pathogens or Mold
• Water Activity - Measurement of water “freedom” in a food/feed product
– Equal to the relative humidity in the air surrounding the feed divided by 100
– If relative humidity equals 65%, aW equals 0.65
• Product controls
– Knowing the characteristics of our products and their aW helps us determine safe storage
conditions for the products
• Salmonella is unlikely to grow at an aW less than 0.9

Feed Safety
PHYSICAL HAZARDS
• Metal, glass, wood, plastic, gasket material, tools

• ¼ inch to 2 inches long and less than 1 inch wide and sharp for cattle
• 7 mm to 25 mm all other animals (US FM Spec)
• Items recognizable shape (tools, nuts, bolts)
• System Controls
• Magnets
• Pre / Post load inspections
• Prohibited back hauls


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2 Cargill Feed Safety © 2017 Cargill Incorporated. All rights reserved.

3 Cargill Feed Safety © 2017 Cargill Incorporated. All rights reserved.

4 Cargill Feed Safety © 2017 Cargill Incorporated. All rights reserved.

5 Cargill Feed Safety © 2017 Cargill Incorporated. All rights reserved.

6 Cargill Feed Safety © 2017 Cargill Incorporated. All rights reserved.

• Veterinary Feed Directive (VFD)

7 Cargill Feed Safety © 2017 Cargill Incorporated. All rights reserved.

• FDA regulated both food and feed

8 Cargill Feed Safety © 2017 Cargill Incorporated. All rights reserved.

AAFCO – ASSOCIATION OF AMERICAN FEED CONTROL OFFICIALS

9 Cargill Feed Safety © 2017 Cargill Incorporated. All rights reserved.

10 Cargill Feed Safety © 2017 Cargill Incorporated. All rights reserved.

11 Cargill Feed Safety © 2017 Cargill Incorporated. All rights reserved.

• Our programs have no CCPs for Feed

12 Cargill Feed Safety © 2017 Cargill Incorporated. All rights reserved.

WHAT IS FEED SAFETY

13 Cargill Feed Safety © 2017 Cargill Incorporated. All rights reserved.

14 Cargill Feed Safety © 2017 Cargill Incorporated. All rights reserved.

• Bovine Spongiform Encephalitis (BSE): Mad Cow Disease

16 Cargill Feed Safety © 2017 Cargill Incorporated. All rights reserved.

• Salmonella is unlikely to grow at an aW less than 0.9

17 Cargill Feed Safety © 2017 Cargill Incorporated. All rights reserved.

• Metal, glass, wood, plastic, gasket material, tools

18 Cargill Feed Safety © 2017 Cargill Incorporated. All rights reserved.

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