New Guidance Document for Safe Feed/Safe Food Implemented
Henry Turlington, director of quality and manufacturing regulatory affairs
Wednesday, March 11, 2015
by: Henry Turlington, director of quality and manufacturing regulatory affairs

Section: Spring 2015

Safe Feed/Safe Food was launched in 2004 with the first facilities obtaining certification the following year. Since the beginning of the Safe Feed/Safe Food program, the number of certifications has expanded to four options. FSC36 Safe Feed/Safe Food is the most popular certification and is considered the core offering of the program. 
AFIA recently updated the requirements of FSC36 Safe Feed/Safe Food with the intent of the certification to support the new requirements outlined in the Food Safety Modernization Act as well as to help drive continuous improvement within a location’s quality and feed safety program. The updated requirements are listed as the FSC36 Safe Feed/Safe Food Guidance Document on the Safe Feed/Safe Food website at
The requirements for FSC36 Safe Feed/Safe Food certification include Current Good Manufacturing Practices for animal feed production as well as the requirements for an effective animal food safety program. The requirements for FSC36 Safe Feed/Safe Food support a risk-based management system that is documented and implemented by a facility (supplier) of feed or feed-related products to control animal food safety.
Feed and feed materials intended for consumption by animals must be produced, processed and handled in a safe and efficient manner. In order to accomplish this, feed processing premises shall be designed to facilitate proper processing, handling and storage of product. The guidance document for FSC36 Safe Feed/Safe Food provides an outline for the guidance on each aspect of the manufacturing process to assist in understanding various requirements. It also details some of the fundamental practices that must be in place to protect the safety and quality of feed.
What is FSC36 Safe Feed/Safe Food? When AFIA aligned with Safe Quality Food Institute, each Safe Feed/Safe Food certification was assigned a Food Sector Code (FSC) number within the SQF database. FSC32 was assigned to AFIA’s Pet Food Certification program. FSC34 was assigned to the new GFSI benchmarked program for animal feed. FSC36 was assigned to AFIA’s existing Safe Feed/Safe Food certification for animal feed. 
Why update the FSC36 Safe Feed/Safe Food Guidance Document? In October 2013, AFIA partnered with SQFI to administer the Safe Feed/Safe Food program. Three certifications were offered. AFIA maintains sole control of the requirements for FSC36 Safe Feed/Safe Food whereas SQFI provides the food safety fundamentals for the FSC32 and FSC34 programs. When AFIA transitioned to SQFI, the requirements for the FSC36 program were raised and the processes for completing certification were changed. These changes proved burdensome for previously certified facilities. The AFIA Quality Committee embraced the problem and updated the requirements and process to obtain FSC36 Safe Feed/Safe Food certification. In addition, the scope of the program was broadened to support compliance with the new FSMA requirements.
What are the major changes to the FSC36 Safe Feed/Safe Food Guidance Document? There have been minimal changes to the requirements to obtain FSC36 Safe Feed/Safe Food. However, the process for completing the certification is now streamlined to create a more user-friendly program.
  • The number of elements has been reduced from 230-plus elements to 77 elements. This should allow the auditors to spend more time reviewing documentation and manufacturing processes.
  • FSC36 is being changed to a “Continuous Improvement” program from a “Compliant” program. In the past, facilities had to comply with the each element in order to obtain certification. The new process will allow the auditor to assess the effort and progress by a facility to comply with the FSC36 Safe Feed/Safe Food Guidance Document. The facility will be scored based on these efforts. The assessment process will provide the facility with better direction for continuous improvement and compliance with FSMA. The continuous improvement process is consistent with the FSC34 and FSC32 programs. 
  • The “self-audit” is being replaced by a “surveillance audit” (or remote audit) by that will be completed by the certifying body (CB). The surveillance audit is an abbreviated version of the on-site audit and covers “mandatory” elements only (see section 2.4 System Elements of the guidance document for a listing of the mandatory elements). The location will work with the CB to ensure compliance with these elements without completing an onsite audit. This is also referred to as a desk audit. There will be a cost associated with the surveillance audit ($300-400), but the process and the quality of the audit will be greatly improved as the CB is more involved with the assessment and the facility provides supporting evidence only. An on-site audit will continue to be completed every two years. 
What is the purpose of the guidance document? The purpose of the guidance document for FSC36 Safe Feed/Safe Food is to 1) assist facilities with designing, developing, implementing and maintaining a quality and feed safety program that complies with the desired requirements and 2) assist auditors with auditing locations seeking certification for FSC36 Safe Feed/Safe Food. There are numerous examples provided within the guidance document to assist facilities with preparation for compliance with the requirements. However, it is not a definitive document and applicable in every situation. Suppliers, consultants and auditors are required to understand animal food safety risks (and quality, where applicable) in the feed industry in order to effectively control those risks. 
The new FSC36 Safe Feed/Safe Food Guidance Document includes the following:
  • Registration and certification process
  • Implementation process
  • Introduction to this guidance document
  • Guidance document for FSC36 Safe Feed/Safe Food 
  • Glossary
  • Logo rules
For more information on FSC36 Safe Feed/Safe Food, or any of the certification programs, contact Henry Turlington, AFIA director of quality and manufacturing regulatory affairs, at (703) 650-0146 or
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