Developing a biosecurity plan for your feed or feed ingredient facility is the first line of defense against the potential threat of spreading livestock and poultry diseases. It’s also key to meeting the FDA’s requirements for animal food controls under the Food Safety Modernization Act.
A biosecurity plan is a written document outlining the controls taken at a facility to prevent any foreseeable pathogens — or hazards — from entering their feed chain. Each feed facility’s plan must be customized based on the particular hazards of that location.
Developing a good biosecurity plan requires extensive knowledge of the plant’s manufacturing processes, suppliers, transportation operations and storage practices, and the risks that each aspect poses.
Dr. Henry Turlington, director of quality, education and training, American Feed Industry Association, works closely with the Food Safety Modernization Act and AFIA’s third-party certification programs. He advises companies to establish an animal food safety team to ensure the quality implementation of a biosecurity plan. According the AFIA’s guidance document, “Developing Biosecurity Practices for Feed & Ingredient Manufacturing,” responsibilities of the team include:
- Identifying areas of reasonably foreseeable hazards for the spread of an animal disease;
- Developing a site-specific biosecurity plan for animal disease;
- Increasing biosecurity awareness and ensuring compliance with policies;
- Ensuring proper training is maintained and completed; and
- Keeping management informed of potential animal disease risks and updating the biosecurity awareness plan as needed
In order for the team’s efforts to be successful, it also requires complete “buy-in” from everyone in the organization. Company leaders are responsible for upholding a workplace culture that takes the biosecurity plan seriously.
“It really is a top down effect, as management establishes a facility’s culture,” said Turlington. “Once a facility’s management team decides to put a biosecurity plan in place, and then follows through with its implementation, the saying ‘lead by example’ comes into play to the fullest effect.”
Perhaps one of the team’s most important responsibilities is the education and training component. The more employees understand the policies and the reasoning behind their implementation, the more they will comply with the biosecurity plan. Sharing his insights into how to effectively train your staff, Turlington sat down with Feed & Grain to discuss the AFIA’s education opportunities and certification options, and how they relate to FSMA-compliance.
Feed & Grain: Where should companies look for direction on howto start a biosecurity plan for their feed facilities?
Turlington: We highly recommend using AFIA’s biosecurity guidance document, “Developing Biosecurity Practices for Feed & Ingredient Manufacturing,” to assist facilities in identifying potential hazards and risks of occurrence when creating and implementing a brand-new biosecurity plan. The document can be found at here. The guidance document provides feed and ingredient manufacturers with recommendations that can be used to develop a biosecurity plan to control the potential spread of animal diseases through feed and feed ingredients. Procedures should be developed to ensure the plan is implemented and remains effective as situations evolve.
F&G: What are some effective ways to train employees on a facility’s new biosecurity plan?
T: Communicating that there is currently a biosecurity plan is always a good start. Employees cannot implement the plan if they are not educated on the plan. A biosecurity plan’s effectiveness in preventing disease is only as good as the efforts of the people using it.
Additionally, facilities should make the plan a part of their culture, leading by example from the top down; making continuous improvement part of the plan, scheduling a time frame for updates on a regular basis; and communicating the plan to your suppliers and customers. Suppliers must understand the facilities’ requirements for incoming materials, and customers should know your practices to ensure the biosecurity of products provided.
F&G: What training is required by FSMA for those responsible for implementing preventive controls for animal food?
T: FSMA requires a facility to develop a food safety plan using a “preventive control qualified individual” or PCQI. A PCQI is “a qualified individual who has successfully completed training in the developmentand application of risk-based preventive controls or at least equivalent to that received under a standardized course seen as adequate by the U.S. Food and Drug Administration, or prior job experience, to develop and apply for a food safety system” (507.3 Definitions).
AFIA is currently offering trainings on FSPCA Preventive Controls for Animal Food, or PCQI training, for the animal food rule. While this training is not required, it provides a sound foundation for understanding the FSMA rule and implementing an effective food safety plan. PCQI [training] is highly recommended.
It is also important to remember, there can be more than one PCQI designated per facility, and PCQIs are not required to work within the firm. It’s recommended a facility have a designated PCQI prior to its date of compliance, which could be as early as September 2017.
F&G: What role should the certified Preventive Controls Qualified Individual play in educating feed mill staff about the biosecurity plan?
T: The most important process for completing a food safety plan is identifying “known and reasonably foreseeable hazards.” The PCQI, along with support from the facility’s animal food safety team, should assess all potential hazards, including those that may cause the spread of animal disease. I consider the biosecurity plan a key Current Good Manufacturing Practice (CGMP) to help mitigate biosecurity risks. Thus, training of personnel and assessment of effectiveness are part of the plan.
F&G: What does AFIA provide for biosecurity planning and PCQI certification?
T: To assist industry in complying with FSMA animal food rules, AFIA scheduled trainings on FSPCA Preventive Controls for Animal Food. One was in Nashville, TN, on July 12-14, 2016 and one was in Auburn, AL, Aug. 16-18, 2016.
AFIA, National Grain and Feed Association and Pet Food Institute collaborated to hold the first Lead Instructor FSPCA Preventive Controls for Animal Food training for the industry in July 2016. The goal is to provide our members with training that allows them to return to their facilities and train others. It was a dynamic training session. ❚
More information on AFIA’s trainings is available here.
