Inspections, Compliance, Enforcement, and Criminal Investigations
Rocky Ford Pet Foods 8/27/13
Department of Health and Human Services
|Public Health Service|
Food and Drug Administration
Denver District Office
Bldg. 20-Denver Federal Center
P.O. Box 25087
6th Avenue & Kipling Street
Denver, Colorado 80225-0087
- The brain and spinal cord of cattle 30 months of age or older;
- The entire carcass of cattle infected with BSE; and
- The entire carcass of cattle 30 months of age or older that have not been inspected and passed for human consumption if the brains and spinal cords were not removed or otherwise effectively excluded from animal feed.
- Failure to prevent the inclusion of cattle materials prohibited in animal feed (CMPAF) in animal feed or feed ingredients, as required by 21 CFR 589.2001(c)(1). Specifically, on February 25, 2013, our investigator observed that the unmarked CMPAF posterior sections of vertebral columns for two cows, identified by your firm as older than 30 months of age, were separated from the rest of the marked CMPAF material from those animals. The unmarked CMPAF material was then commingled with 18 additional posterior vertebral columns and placed in a trailer for shipment to another renderer for further processing and possible use in animal feed.
- Failure to maintain adequate written procedures specifying how the process of removing the brain and spinal cord from cattle not inspected and passed for human consumption or 30 months of age or older is carried out, as required by 21 CFR 589.2001(c)(2)(ii). Specifically, your written procedure “Rocky Ford Ped [sic] Food Standard Operating Procedure for handling 30 month and older Beef and CMPAF Products” indicates that the head, vertebral column, and rib cage for cattle 30 months of age and older are kept in one piece. This written procedure is not consistent with actual operations observed at your firm on February 26, 2013. Our investigator observed that posterior vertebral columns from two cows 30 months of age or older were separated from the animals’ heads and anterior vertebral columns; the posterior sections were not marked as CMPAF material. Your written procedures fail to specify how, for animals 30 months of age or older, posterior vertebral columns separated from marked anterior vertebral columns would themselves be marked as CMPAF material.
- Failure to mark the CMPAF and products that contain or may contain CMPAF with an agent that can be readily detected on visual inspection, as required by 21 CFR 589.2001(c)(2)(v). Specifically, the posterior sections of vertebra columns from cattle identified by your firm as 30 months of age or older were separated from the head and anterior vertebral columns but then were not identified as CMPAF with an agent readily detectable on visual examination. Therefore, the CMPAF posterior vertebral columns were indistinguishable from the non-CMPAF posterior vertebral columns.
- Failure to label containers, including vehicles when used as containers, which contain CMPAF with the required statement, “Do not feed to animals,” as required by 21 CFR 589.2001(c)(2)(iv). Specifically, the dump truck and trailer used for storage and transport of CMPAF materials did not bear the statement “Do not feed to animals.”
- Failure to avoid cross-contamination once CMPAF have been separated from other cattle materials as required by 21 CFR 589.2001(c)(2)(iii). Specifically, both marked and unmarked CMPAF were observed to be stored on the floor of the processing area rather than in separate containers that adequately prevent contact with animal feed, animal feed ingredients, or equipment surfaces, 21 CFR 589.2001(c)(2)(iii)(B). As described in item #1 above, the unmarked materials were indistinguishable from non-CMPAF materials and could result in cross-contamination.