All Natural**

What does All Natural mean to you?  Ask 10 people and get 10 different answers.  Actually whether you know what all natural means also depends largely upon your background and interest in the subject.  Confusing matters further are ‘absence’ claims such as Non-GMO.

As anyone who reads this site regularly, you know that my background is meat and poultry.  I’ve worked in that industry for over 20 years and I know what all natural means when it appears on a label – or at least I think I do.  I’ve done my fair share of label submittals documenting why my products were all natural.  I’ve worked with USDA to explain what, when and how.  I’ve attended public and industry meetings and hearings where very smart folks have argued why the addition of sodium nitrate shouldn’t render a product not all natural.

When I first began work in industry a USDA label specialist explained their approval of all natural as something that a home consumer could do to the product – grind it, slice it, cook it, marinate it.  That was pretty clear to me and how I’ve always associated the term.  Do you run breast cages through a Wolfking to produce MSP? Not likely to be labeled all natural.  Addition of various chemicals and preservatives? Not likely to be labeled all natural.  Think of the USDA required note All Natural * Minimally Processed, No Artificial Ingredients.

For the most part, the issue is consumers not understanding nor caring to learn what food terms mean.  Like it or not, as a consumer, it is our responsibility to understand where our money is going and what the terms mean.  Granted, as a ‘industry insider’ I have insight other may not but the information is available to all.  I know nothing about cleaning products.  If I decide to buy certified organic cleaning products it is my responsibility to determine what that means and whether I am willing to spend more for the product.  The company has the responsibility to not mislead me but proper use of a defined term should not be viewed as misleading.  But in reality that’s where the problem for All Natural arises.

USDA has a plain definition.  FDA does not.  Couple that with the fact that FDA has no label review and approval process (USDA does) and the term Natural has gotten an undeserved worthless term reputation.  The non-meat food world uses the term loosely with little definition.  Consumers don’t separate the meat world from the other but those of us in industry do making the issue to a consumer much larger than it may seem to me.

The amount of press this topic has gotten yet again in recent days will hopefully move government officials to address it once and for all.  It’s all well and good for USDA to sit on their pedestal and say “we have a definition” but if the general consumer doesn’t understand nor differentiate the problem is not going to go away.  Distrust is the US food system is at an all time high.  It is our (industry and government) responsibility to improve this opinion.  The vast majority of companies do not intend to mislead their customers and if we could only develop an easily understood and simple to enforce program I believe it would be adhered to by industry and embraced by consumers.  I’m willing to do my part – are you?

FSMA Animal Feed Compliance – September 17, 2018

​​September 17, 2018 marks a big day for all animal feed facilities subject to the Food Safety Modernization Act.  Effective this day all sites must have implemented the cGMP requirements, small sites must be in compliant with the full rule and large businesses, which were to comply last September, will now be subject to routine Preventive Control inspections.

 

FDA delayed the start of routine PCAF regulatory inspections of large facilities last year and has done the same with small facilities this year.  This is being done to allow the industry as a whole to continue to learn about the process and alter their programs to be more in sync with regulatory requirements and best practices.  FDA is also focusing this time on education of the industry.

 

FDA has maintained a fairly transparent communication program throughout the implementation process and another example of that can be found here, Jenny Murphy Q & A, which again details the how and why of FDA’s approach to the Animal Feed rule.

 

It is important to note that delay of routine inspections does not remove the facility responsibility of compliance.  FDA reserves the right to perform random inspections of small facilities and, if an event occurs warranting investigation, your site will be expected to be in compliance with the rule and you can be held to the new provisions.

 

The next phase of industry learning will begin as FDA begins their routine inspections and we continue to see what application of the rule looks like in practice.  To assist the industry in compliance, FDA has published PCAF final guidance on compliance with CGMPs and the small entity compliance guide; and draft guidance on the hazard analysis and preventive control requirements, the supply-chain program, and the use of human-food byproducts as animal food.

 

Have questions about what steps you need to take to become compliant?  With over 25 years of food and feed manufacturing experience Ranck & Associates can help you meet regulatory requirements while ensuring continuity with your business objectives.  Please contact us today to set up a review of your program.

FSMA 2018 Update

With the effective date of the Produce Safety Rule in January 2018 all 3 food and feed rules are now in use and members of our industry are working hard to implement the requirements and understand the impact to their business.  While the programs … [Continue reading]

FDA FSVP Clarification

In mid January 2018 FDA released additional guidance to assist importers of raw grains with the implementation and management of their Foreign Supplier Verification Program. Details of the guidance can be found here: FSMA FSVP Raw Grain … [Continue reading]

Food Safety Modernization Act (FSMA) – Implication for Feed Safety Enforcement

FSMA, which became law in January 2011, is designed to give FDA more authority to protect the safety of food for humans and animals. It gives FDA new authorities for addressing issues concerning the safety of food for animals and will ultimately … [Continue reading]

Upcoming FSMA Trainings in Lancaster, PA

These classes have been closed to further registration … [Continue reading]

All Natural Advertising

What does All Natural mean to you?  The current adage is ask 10 people and get 10 different answers.  Actually whether you know what all natural means also depends largely upon your background and your knowledge. As anyone who reads this site … [Continue reading]

September is Food Safety Month

September is Food Safety Month which leads us to consider the implications of food safety throughout the supply chain.  For the previous few years the emphasis has been shifting, or perhaps expanding is a better word, toward the farm.  We see more … [Continue reading]

cGMP Implementation Deadline – September 2017

An important portion of FSMA to be implemented by animal feed mills is the application of cGMP’s consistent with the type of feed being manufactured. Some things you should know: The word ‘current’ indicates implementation of rules consistent … [Continue reading]

Is FSMA Going to Change under Trump?

With the inauguration of a new administration focused on reducing regulatory burden there has been much discussion about the potential effects on the Food Safety Modernization Act. Currently there has been no indication of any change of course by the … [Continue reading]