Regulatory Approaches to Ensure the Safety of Pet Food
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Rural and Regional Affairs and Transport References Committee Regulatory approaches to ensure the safety of pet food Submission from Nestlé Australia Ltd July 2018 Thank you for the opportunity to provide a submission to the Inquiry into regulatory approaches to ensure the safety of pet food. Nestlé Australia is a subsidiary of Nestlé SA. As one of Australia’s largest food manufacturers, we employ around 4400 people at 40 sites in Australia, including eight factories. Our business spans a diverse range of products and some of Australia’s best known brands, including: Confectionery: Chocolate bars and blocks, medicated confectionery (eg Soothers), sugar confectionery (eg Allen’s lollies) Snacks (eg Uncle Tobys muesli bars, nut bars) Baking Chocolates (eg Plaistowe) Condensed milk, baking milks (eg Carnation) Beverages containing cocoa (eg Milo, Nesquik), both powdered and ready-mixed Breakfast cereals (eg Uncle Tobys) Sauces and recipe mixes (eg Maggi) Instant noodles (Maggi) Coffee (eg Nescafé, Nespresso) Bottled water and carbonated drinks (eg San Pellegrino) Infant formula, infant food (eg Nan, Cerelac) Toddler formula (Nan) Medical nutrition products (eg for use in hospital and aged care settings) A wide range of food products for use in professional food service, including recipe bases, soup mixes, beverage products etc Pet food and accessories (Purina) Skin care products Most of the products we sell in Australia are manufactured locally. We source ingredients locally where practicable, but we also purchase internationally, including through regional and global sourcing teams. 1 Nestlé Purina PetCare In Australia, Nestlé Purina PetCare makes wet and dry pet foods for cats and dogs, including brands such as Pro Plan, Supercoat, Felix, Fancy Feast and Purina One, at its factory in Blayney in central western NSW. The majority of our pet food products are nutritionally complete. We also make incomplete or complementary foods for cats and dogs. We do not sell raw or fresh pet food. More than 80 per cent of the ingredients we use at the Blayney factory are sourced locally, including meat and grains. In 2017, over $32m of pet foods left the Blayney factory for export, including to Japan, Malaysia and New Zealand. Meeting both Australian standards and those of export markets are critical to our business. In addition, Nestlé Purina PetCare imports finished pet food from the United States, France, Thailand and New Zealand. Approaches to ensure the safety of pet food With Purina pet food sold in 78 countries, Nestlé Purina PetCare has experience in operating in a wide range of regulatory frameworks. We have noted public comment in Australia about the quality and safety of pet food with concern. This does not reflect our experience as a manufacturer, or the focus that we put into providing high quality products. Safe pet food requires both food safety, and, where appropriate, nutritional completeness. Nutrition: Our primary focus is on creating nutritionally complete and balanced, high quality pet food, designed to meet a cat or dog’s entire nutritional needs, while making sure that pets also enjoy the taste. Our research into animal nutrition, coupled with following research around the world, helps us continue to deliver high quality products. To deliver this, all our pet foods are carefully formulated by pet nutritionists who understand nutrient profiles of ingredients, how different nutrients and processes work together, and what biological effects ingredients will have on an animal’s body. This is then balanced to provide a food that provides 100% complete and balanced nutrition, tailored to the pet's life stage or life style. To ensure that the product delivers this, we test our ingredients to ensure each batch delivers consistent nutritional balance, despite naturally occurring variation in ingredients. Food Safety: Nestlé Purina PetCare has a strong focus on food safety through the value chain, from raw material sourcing, through to manufacture and distribution. All Nestlé Purina PetCare factories globally: Are certified annually by Global Food Safety Initiative (GFSI)-accredited independent certifying bodies against internationally recognised human food safety scheme ISO 22000 Food Safety Management Systems (more here: http://www.mygfsi.com/) 2 ISO 22000 establishes foundational use by the factory of the HACCP (Hazard Analysis and Critical Control Points) hazard and risk-based food safety process and implementation of Good Manufacturing Processes/Pre-Requisite Programs Ensure that the manufacturing environment is consistent with hygiene and sanitation standards required to prevent physical (foreign body), chemical, or biological cross contamination of ingredients, semi-finished goods and finished food Includes warehousing of raw materials, warehousing of finished products, and traceability requirements. Our factory at Blayney runs around 3500 quality and food safety tests every day, with oversight by our quality team. Testing includes raw materials through to finished product. We also require that raw ingredients be free of foreign material, with multiple filters, magnets, and other equipment and processes throughout our facility to ensure that only the intended ingredient goes into the final product, and that the product meets the standard the pet owner rightly expects. As part of our quality program, we also work with suppliers to ensure that their focus on quality matches ours, and that they understand the impact that issues in their supply chain can have on pets and the people who care for them. It has been encouraging to see suppliers improve their standards over time as a result of this. Where suppliers will not work to maintain the standard we require, we will cease purchasing from them. Nestlé Purina PetCare also has a long history of working with the industry, notably the Pet Food Industry Association of Australia (PFIAA), with the goal of ensuring the health and wellness of cats and dogs in Australia. For this reason, we have been aware of developments in the regulation of the pet food industry in recent years. This has included the 2007 introduction of the Industry Code of Practice, developed as a guide on good manufacturing practice and food safety as it pertains to pet food, and the 2011 introduction of the Australian Standard Australian Standard for the Manufacturing & Marketing of Pet Food (AS5812), followed by its revision in 2017. We also note additional standards and regulations that have contributed to improving the quality of the ingredients we buy, including meat and grains. Nestlé Purina PetCare holds the view that the standard to which pet food is made in Australia is high, and that pet owners have every reason to be confident in the quality and safety of foods sold in Australia which has been made to meet the relevant standard. a. the uptake, compliance and efficacy of the Australian Standard for the Manufacturing & Marketing of Pet Food (AS5812:2017) The Australian Standard for the Manufacturing and Marketing of Pet Food (AS5812:2017) (“the Standard”) covers manufacture, labelling and nutrition requirements for pet food manufactured and/or sold domestically in Australia. The original Standard was published in March 2011 following Pet Food Safety Committee meetings in 2009 and 2010, and was developed with the involvement of stakeholders including state and federal government, the Australian Veterinary Association, the RSPCA, and pet food industry 3 representatives. It was subsequently reviewed by the same organisations, with the revised edition published in September 2017. The Standard covers areas such as manufacturing, labelling, nutrition and marketing, as well as guidelines on pet food ingredients. It also covers areas that are of concern to some pet owners, such as product recall procedures, irradiation, and food additives. Certification to the Standard is conducted independently. The process, while operated by industry association PFIAA, is audited annually by the Department of Agriculture and Water Resources (DAWR) under the terms of the Letter of Exchange Agreement between PFIAA and DAWR. Almost all the manufacturing members of the PFIAA and all exporter members are now accredited to the Standard. This is estimated to cover more than 95% of the pet food sold in Australia. Nestlé Purina PetCare is certified to the Standard. Strengths of AS5812:2017 The Standard itself is robust. It gives sound direction for what constitutes a quality pet food for domestic cats and dogs, covering a comprehensive range of pet food types. Pet foods produced and marketed to the Standard will be of high quality and fit for purpose. The Standard was both developed and reviewed with the input of key stakeholders: the pet food industry was involved, but not dominant. The government remains involved in the standard, with the certification process assessed annually by the Department of Agriculture and Water Resources. Pet food made to this standard is accepted by a wide range of export markets, including Japan, Malaysia, Indonesia, Singapore, Korea, Hong Kong and NZ The Standard is a cost effective and simple way to ensure pet food is made and marketed appropriately. The Standard is scheduled for review every five years by the same stakeholder groups involved in its development. Equivalent international standards are also recognised, allowing for simpler import and export. Shortcomings of AS5812:2017 It is not mandatory or enforceable. It also lacks a complaint mechanism. It lacks transparency.