A pet food maker's food safety plan falls under FDA's animal food rule, 21 CFR part 507, which works like the human food rule with one addition worth knowing. The written hazard analysis covers the usual biological, chemical and physical hazards, and also nutrient deficiencies and toxicities: the rule names excessive vitamin D in dog food and too little thiamine in cat food as examples. For a fresh cooked dog food, that gives the plan its shape. Raw beef and chicken can carry Salmonella, so the cook is a critical control point. Cooked food cooling slowly lets survivors grow, so cooling is another. And the vitamin and mineral premix, weighed into each batch, is a preventive control of its own, because a doubled scoop of premix is a doubled dose of vitamin D. A qualified facility, such as a very small business, follows lighter requirements, but pet store chains often ask for the plan either way. In the example below, a Kentucky fresh dog food kitchen writes its plan.
The short version
- Pet food is animal food under 21 CFR part 507.
- The hazard analysis is written, and includes nutrient deficiencies and toxicities.
- Fresh cooked food: the cook is a CCP for Salmonella and other pathogens in raw meat.
- Cooling is a CCP: cooked food reaches cold quickly so survivors don't grow.
- The vitamin and mineral premix is weighed and recorded for every batch.
- Qualified facilities follow modified requirements; buyers may still ask for a plan.
- TaroStack keeps each batch's cook and cooling readings, and its premix lot, on its batch record. More below.
The rules
| Rule | Where |
|---|---|
| Hazard analysis | For each type of animal food: biological, chemical and physical, including nutrient deficiencies or toxicities such as excessive vitamin D in dog food; written regardless of outcome (21 CFR 507.33) |
| Preventive controls | Written; CCPs if there are any; process controls with parameters and limits (21 CFR 507.34) |
| Qualified facility | Not subject to those subparts; modified requirements instead (21 CFR 507.5(d)) |
State feed laws handle registration and labels; the license side is in pet food license, the costs in dog food business plan, and baked treats in how to start a dog treat business. This is general information, not legal advice.
An example: the hazard analysis
Paddock Pet Kitchen, a made-up fresh dog food maker in Lexington, Kentucky, cooks beef and chicken recipes in a shared kitchen and freezes them in 1 lb packs for monthly plans and two pet stores. Its beef recipe:
| Step | Hazard | Reasonably likely? | Control | CCP? |
|---|---|---|---|---|
| Receiving beef and chicken | Salmonella, E. coli | Yes | Destroyed at CCP 1 | No |
| Receiving premix | Wrong premix, or a supplier error in the vitamin levels | Yes | Supplier's certificate of analysis for each lot | No |
| Weighing premix | Too much or too little vitamin D and other nutrients | Yes | Premix weighed per batch and recorded, a second person checks | No, a process control |
| Cooking | Pathogens surviving | Yes | Cook to the validated temperature | CCP 1 |
| Cooling | Growth of survivors and spore-formers | Yes | Cool to the validated time and temperature | CCP 2 |
| Portioning and packing | Contamination from equipment | No | Sanitation SOP | No |
| Frozen storage and delivery | Growth if thawed | No | Freezer log, prerequisite program | No |
The plan
| Control | Limit | Monitoring | Corrective action | Verification |
|---|---|---|---|---|
| CCP 1 Cooking | Every kettle reaches the validated temperature (example: 165°F) | Probe three spots in each kettle | Keep cooking and re-probe | Thermometer checked daily; records reviewed weekly |
| CCP 2 Cooling | From 135°F to 70°F and then to 41°F within the validated times (example: 2 hours, then 4 more) | Probe at the start and each hour | Reheat and re-cool within the limits, or discard; find the cause | Records reviewed weekly |
| Premix | The recipe's premix weight for the batch size, within its tolerance (example: 180 g for a 100 lb batch, ±5 g) | Weighed on a checked scale, signed by two people | Hold the batch; discard if the premix can't be confirmed | Scale checked weekly; certificates of analysis on file |
The example limits are placeholders; your own validation and your nutritionist's formula set the real ones.
A week of records
| Date | Lot | Control | Reading | Limit | OK? | Action |
|---|---|---|---|---|---|---|
| Oct 5 | BF-1005 | Premix | 181 g | 175 to 185 g | Yes | |
| Oct 5 | BF-1005 | Cooking | 168°F | 165°F or more | Yes | |
| Oct 5 | BF-1005 | Cooling, 2 hours | 68°F | 70°F or below | Yes | |
| Oct 7 | BF-1007 | Premix | 360 g | 175 to 185 g | No | Two scoops weighed in; batch held and discarded; premix now pre-weighed by the batch |
| Oct 7 | CK-1007 | Cooking | 163°F | 165°F or more | No | Kept cooking 10 minutes, re-probed at 167°F |
The doubled premix is the reason the weighing has a second signature: nothing about the finished food looks different.
Get the worksheet
Download the pet food HACCP plan worksheet. Four sheets: the hazard analysis, the plan with a place to sign, a monitoring log that checks each reading against its limits, and a read-me. It's a worksheet to organize your own plan, not a plan to copy. It's an ordinary Excel file with no macros, and it works in Google Sheets, LibreOffice and Numbers.
Where this stops working
Every batch has a premix weight, a cook and a cooling curve, two recipes share a kettle, and a pet store wants to know which packs to pull if a premix lot is recalled.
How TaroStack does it
TaroStack keeps each batch's readings, its premix lot and where its packs went.
Readings on the batch. Fields of your own on the batch record hold the cook and cooling temperatures and the premix weight, and printable batch-record forms carry a sign-off, with a field of your own for the second person's initials.
Batches record their lots. Each batch records the beef and premix lots it used, so a supplier's recall of a premix lot leads to every batch it went into.
Where it went. Each store's order and each plan delivery records the lots it got, so one recall report shows who has them.
| The job | Binder | In TaroStack |
|---|---|---|
| Premix weight for a batch | A signed sheet | A field on the batch record |
| Which premix lot went into a batch | Not recorded | Lots on the batch |
| A batch on hold | A note on the freezer | A hold until released |
| Which customers got a batch | Invoices and routes | One recall report |
Recipes, batches, lots and recalls are on every plan, from $49 a month. The first 30 days are free, with no credit card. If you'd like a hand setting up, ask, and we'll do it with you.