21 The manufacturers’ role in feed quality and safety

A discussion on methods used in feed manufacturing processes to assure feed hygiene and safety

Introduction

Quality in equine feedingstuffs

Feed quality can mean different things to different people; for some it is the nutrient content or presence of certain ingredients, for others the consistent appearance and physical form and for others still it is the assured absence of undesirable substances.

All involved in the feed chain from suppliers of raw ingredients, manufacturers and distributors, to the end user, the horse owner/feeder, have a role to play in ensuring the horse receives a diet that is of appropriate quality and is safe to eat.

On its journey from individual ingredients to landing in the feed bucket, a feedstuff faces certain challenges to its inherent quality and safety that can arise through its harvest, storage and/or transport. Once in the feed room, the responsibility for quality and safety is with the owner or feeder of the horse, in ensuring that the feed has been stored appropriately, is the right product being fed at an appropriate level for the horse, and, if being fed in conjunction with other feedstuffs, no harmful deficiencies or excesses of nutrients are being administered.

The manufacturer’s role is essentially to consistently make products that simultaneously contain those nutrients and ingredients which it holds out to be present, in the stated proportions and in its expected physical form, but that also do not contain levels or concentrations of substances that could affect the health or performance of horses, or the legal status of the feed. It is fundamentally illegal to knowingly manufacture or provide feed that is not safe. Manufacturers also have a commitment to ensure that appropriate recommendations for storage and use of their products are clearly visible for customer use.

Adverse quality can result not only in potential physical harm to the horse, but also seriously affect a feed business in several ways, including unwelcome media interest, loss of business, brand damage and prosecution. Therefore it is incumbent on feed producers to safeguard the safety, quality and integrity of feed products, to minimize the opportunity for product contamination and mis-manufacture.

There are many harmful or undesirable substances that can enter the equine diet, for example:

• Microbiological contaminants

• Pesticides

• Dioxins

• Mycotoxins

• Heavy metals

• Certain nutrients used at levels above those recognized as safe, for example selenium or rapidly digestible/fermentable carbohydrate.

Additionally to the list above, there is a further category of undesirable substance, those that are not considered harmful but are prohibited under the rules of racing and equestrian sport see Box 21.1 for recent examples of adverse feed product quality in the marketplace.

Box 21.1

Recent Examples of Adverse Feed Product Quality in the Marketplace

• April 2009: 21 polo ponies in Florida died of acute selenium toxicity, linked to a faulty manufacture of a supplement preparation (Anon 2009).

• May 2008: Nationwide product recall instigated after elevated Aflatoxin content found in equine and other feed products manufactured at three sites in the US (FDA 2008).

• Oct 2002 – Jan 2003: 43 horses, including 16 winners test positive for morphine in post race samples in UK and Ireland. The source was identified as racehorse feed (BHA 2004).

This chapter focuses on what the manufacturer’s role in assuring feed quality and safety is, and outlines tools commonly used to help achieve this in practice.

The scope of this chapter is taken to apply to commercially manufactured and packaged products. However, the general principles may also apply to products where there is no required regulatory compliance, such as forage.

Characteristics of equine feeds

Whilst the equine diet is nominally described in terms of its forage and concentrate proportions, in practice a further degree of complexity exists due to the wide range of feed type, physical form, feeding rates, packaging and shelf life (Table 21-1) exhibited within the category of equine feedstuffs.

Table 21-1 Characteristics of Commonly Fed Equine Feedingstuffs with Typical Feeding Rates

a In some countries, forage is presented in cube, pellet or wafer form.

b Where long forage is scarce or unavailable, complete pelleted fiber feeds, designed to provide the total daily diet, are available, with maximum feed rates therefore greater than the 10 kg described in the table.

It should also be noted that manufacturers can only directly influence the quality of their products up to the point of dispatch. With product shelf life extending from around 90 days to over one year, feed products have potential exposure to further risk of damage or contamination throughout the subsequent distribution chain right up to the point of consumption. Manufacturers should, however, offer guidance on the product packaging with respect to the optimum storage of feedstuffs to their customers.

Feed Ingredients

Whilst the main proportions of the equine diet are comprised of forage and cereal based ingredients, other components provide other essential nutrients (Table 21-2).

Table 21-2 The Nature and Source of Common Feed Ingredients Used in Equine Diets

Ingredient source	Examples
Raw agricultural commodities	Oats, corn (maize), barley, peas, beans, lupins, naked oats, linseed, lucerne, straw, timothy hay, grass pellets, straw pellets
Human food by-products	Wheat bran, wheatfeed (wheat middlings), oatfeed (oat hull by-product), soy(a) hulls, rice bran, soy(a)bean meal, sunflower meal, linseed meal, sugar beet pulp, distillers grains, molasses.
Additives	Amino acids, vitamins, yeast products, mold inhibitors
Minerals	Limestone, calcium phosphates, salt, calcined magnesite (magnesium oxide)
Human grade ingredients	Vegetable oils (e.g. soya, corn), herbs

Manufacturing facilities

Given the variety in form of feed, it follows that there is a range of manufacturing processes, such as blending, pelleting, flaking and extrusion. It is not always the case that feed products for horses are manufactured in facilities that solely manufacture equine products; conversely it is more often the case that other animal feed products are manufactured in the same premises, especially feedstuffs for food producing animals.

In the EU, the Transmissible Spongiform Encephalopathy (TSE) Regulations (999/2001), which impose a Community-wide ban on the feeding of processed animal proteins to farmed animals, effectively exclude petfood manufacture in facilities manufacturing feed for equines. Although there are similar controls for certain bovine proteins in the US, horse feed can still be manufactured in facilities handling avian and porcine meat meals in the US, with their attendant risk of salmonella contamination.

Key Points –

The Manufacturer’s Quality Challenge

• To make products that consistently contain what they should contain and do not contain that which they should not

• This challenge applies across a complex and variable mix of feed forms, ingredients, feed rate, packaging and shelf life

• The consequences of not doing so are in the least, adverse publicity and loss of business for a company, but in the worst case can result in a serious health concern for the horse itself

Drivers of feed assurance

The primary driver of feed quality and assurance is a fundamental desire to ensure both customer (the owner/feed purchaser) and consumer (the horse) satisfaction. It is also driven by individual manufacturers’ own commitments to quality, by legislation, and by external factors such as requirements for due diligence, independent expert opinion and industry standards.

Regulatory requirements

In the EU, feed and food law are intrinsically linked and several pieces of legislation are in place designed to maximize food and feed safety. Furthermore, the horse is classed in the EU as a food-producing animal, such that manufacturers of equine products must follow legislation designed to ensure food safety throughout the food chain:

• EU Regulation (EC) No 178/2002 lays down the general principles governing food and feed in general, and food and feed safety in particular, at EU and member state level. Of particular note are articles 15 and 18 of the Regulation. Article 15 states that feed shall not be placed on the market or fed to any food-producing animal if it unsafe. Article 18 states that traceability of food, food-producing animals, and any other substance intended or expected to be incorporated into a food or feed, shall be established at all stages of production, processing and distribution.

• The European Regulation on Feed Hygiene (Regulation EC 183/2005) lays down general rules on feed hygiene, conditions and arrangements ensuring traceability of feed, and conditions and arrangements for registration and approval of feed establishments, applicable to the whole feed chain. It explicitly states that “Feed business operators shall put in place, implement and maintain, a permanent written procedure or procedures based on the HACCP principles.” Industry guides to good practice were published in accordance with Article 22 of this Regulation, the European Feed Manufacturers Guide (2005) (http://www.fefac.org/code.aspx?EntryID=265, FEFAC) and the Feed Ingredients Standard (2007) (http://www.ifsa-info.net/lmbinaries/ifs.pdf. IFSA).

• EC regulation 1831/2003 on Feed Additives. Substances such as vitamins, trace elements and preservatives can only be used if they have undergone an assessment for safety, quality and efficacy.

• EC directive 2002/32 and Commission Regulation (EU) No. 744/2012 on Undesirable Substances and Products control contaminants such as heavy metals, certain mycotoxins, cyanogenic glycosides and dioxins. In addition, to listing maximum permitted levels for such substances, it prohibits the blending down of contaminated feeding stuffs (i.e., the mixing of a consignment in excess of a maximum permitted level for an undesirable substance, with another consignment of a lower contamination, to obtain a legal product).

In the US, the quality and safety of food for humans and animals is covered under one federal law, which is implemented by the Food and Drug Administration (FDA) and state agencies. Food for horses is considered to be “pet food”, but there is no legal distinction for food consumed by companion animals versus livestock. As in the EU there is no separate distinction in the regulation for animal dietary supplements (see Chapter 19).

Legislative and regulatory requirements concerning animal feed in the US are governed by the Federal Food, Drug and Cosmetic Act (FFDCA) – the overarching law that gives the FDA the authority to oversee the hygiene and safety of feed and feed ingredients (see www.fda.gov/regulatoryinformation/legislation/federalfooddrugandcosmeticactfdcact/default.htm).

The FFDCA makes animal feed manufacturers responsible for ensuring that feed products:

• are pure and wholesome

• are produced under sanitary conditions

• contain no harmful substances

• are truthfully labelled.

Until recently there has been no legal requirement for Hazard Analysis Critical Control Point (HACCP), in the US but new legislation under the Food Safety Modernization Act will essentially require manufacturers to apply the principles of HACCP and provide the FDA with additional inspection and control authority.

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