Preventive controls for animal food are FDA's FSMA requirements at 21 CFR Part 507: current good manufacturing practices for every covered facility, plus hazard analysis and risk-based preventive controls for facilities that need a written food safety plan. The rule covers pet food, livestock and poultry feed, and human-food by-products sent to animals.
This is the rule people skip because the word "animal" reads as someone else's problem. It is not. If you make pet food or treats, mill feed, or run a human-food plant that ships spent grain, trim, or whey to a farm, Part 507 applies to you. It was built to mirror the human-food rule, so a plant already fluent in preventive controls for human food will recognize almost every part. This post covers who is covered, the CGMP foundation, the preventive controls layer, the special handling for human-food by-products, and how Part 507 lines up against Part 117.
What are preventive controls for animal food?
Preventive controls for animal food are a two-layer system. The first layer is current good manufacturing practices (Subpart B), baseline sanitation, personnel, plant, equipment, and process requirements that every covered facility follows. The second is hazard analysis and risk-based preventive controls (Subpart C), a written food safety plan in which a facility identifies hazards, applies preventive controls to significantly minimize or prevent them, and verifies the controls work. A supply-chain program (Subpart E) covers hazards controlled by a supplier.
The logic is prevention over reaction: find the hazards reasonably likely to occur, control them by design, monitor the controls, correct deviations, and verify the whole system, rather than testing safety into finished product. Until FSMA, animal food had far lighter federal requirements than human food. Part 507 closed most of that gap, and it did so on purpose using the human-food template, so the concepts transfer directly.
Who must comply with Part 507?
Part 507 applies to facilities that manufacture, process, pack, or hold food for animals and are required to register with FDA as food facilities. "Food for animals" is broad, it includes pet food and treats, livestock and poultry feed, feed ingredients, and human-food by-products diverted to animal use. The obligation splits by activity and size: nearly all covered facilities must follow the CGMPs, while the preventive controls requirements apply to facilities that are not otherwise exempt and that need a food safety plan.
There are exemptions and modified requirements, for certain very small businesses, for some on-farm activities, and for facilities solely storing certain products, and business size sets the compliance clock. The safe move is to confirm your status against the rule rather than assume the animal-food label lets you off. Feed mills and pet food plants that once operated with minimal federal oversight are squarely inside this rule today.
What are the animal-food CGMPs?
Subpart B is the foundation, and for many facilities, especially those handling feed with well-understood, low hazards, the CGMPs are the main event. They cover personnel and their hygiene, the plant and grounds, sanitation, water and utilities, equipment and utensils, and the manufacturing process and controls needed to produce safe animal food. They were written with flexibility for the diversity of the industry, from a small mixing operation to a large extrusion plant, but the intent is constant: keep contamination, including chemical and physical hazards, out of animal food.
The animal-food CGMPs echo the human-food ones almost line for line, sanitary operations, pest exclusion, personnel practices, equipment design, which is why a plant that has built GMP compliance for human food already has most of the muscle memory. The difference is scope, not philosophy.
What preventive controls are required?
Facilities that need a food safety plan build it around a hazard analysis, then apply preventive controls to the hazards that require them. The control categories track the human-food rule:
- Process controls parameters at a step that controls a hazard, such as a validated thermal kill step for Salmonella in extruded pet food, with monitoring and critical limits.
- Sanitation controls where sanitation is needed to significantly minimize hazards like environmental pathogens or allergen carryover between products.
- Supply-chain controls where a hazard is controlled upstream by a supplier, verified through the Subpart E supply-chain program.
- Other controls and a recall plan any control the hazard analysis calls for, plus a written recall plan for hazards requiring a preventive control.
Each applied control comes with management components: monitoring, corrective actions, and verification, all documented. The plan has to be prepared, or its preparation overseen, by a preventive controls qualified individual (PCQI), the animal-food counterpart to the human-food role covered in PCQI. Hazards for animal food include the ones that make the target animal sick and, critically for pet food, the ones that endanger the humans handling it, which is why Salmonella looms so large, as covered in pet food safety.
How are human-food by-products handled?
This is the provision that pulls human-food plants into the animal-food rule, and FDA wrote it to be light-touch. A facility that produces human food and diverts by-products, spent grain, whey, trim, culls, bakery scrap, to use as animal food does not have to comply with the full Part 507 preventive controls or the animal-food CGMPs for those by-products, provided it is already subject to and in compliance with the human-food CGMPs of 21 CFR Part 117 Subpart B and applicable human-food safety requirements. What it must do is hold and distribute those by-products safely under 21 CFR 507.28 and 117.95: protect them from contamination, use suitable containers and equipment, and identify them accurately.
The design is sensible. A brewery sending spent grain to a dairy farm should not have to stand up a second full food safety system; it should keep the by-product clean and labeled on the way out the door. But the exemption is conditional, it holds only while the human-food side stays compliant, so a human-food plant that lets its Part 117 program slip can lose the by-product shortcut and back into full animal-food obligations.
How does Part 507 compare to Part 117?
The two rules are siblings, published under FSMA within the same era and built on the same skeleton: CGMPs plus hazard analysis and risk-based preventive controls, a PCQI, a supply-chain program, and a recall plan. If you know one, you largely know the other. The differences are in scope and a few specifics:
| Element | Human food, Part 117 | Animal food, Part 507 |
|---|---|---|
| Covers | Facilities making human food | Facilities making pet food, feed, and animal-food by-products |
| CGMPs | Subpart B | Subpart B (parallel, industry-flexible) |
| Preventive controls | Subpart C, PCQI-led plan | Subpart C, PCQI-led plan |
| Allergen control | Explicit food allergen preventive control | No allergen control (animals differ), but cross-contamination still managed |
| Key pathogen focus | Listeria, Salmonella, E. coli by product | Salmonella, incl. human handling of pet food |
| Supply chain | Subpart G | Subpart E |
How do you build an animal-food safety plan?
The build sequence mirrors the human-food plan, tuned for Part 507:
- Confirm coverage and register. Determine your status and exemptions under Part 507 and register the facility with FDA.
- Stand up the CGMPs. Put Subpart B sanitation, personnel, plant, equipment, and process controls in place as the foundation.
- Assign a PCQI and analyze hazards. Have a qualified individual lead a hazard analysis of biological, chemical, and physical hazards for each product and process.
- Apply preventive controls. Set process, sanitation, and supply-chain controls for hazards requiring them, with critical limits where relevant.
- Add management components. Define monitoring, corrective actions, and verification for each control, plus a written recall plan.
- Handle by-products correctly. If you divert human-food by-products, confirm the 507.28 / 117.95 holding-and-distribution path or accept full coverage.
- Document and reanalyze. Keep the plan and records current, and reanalyze at least every three years or on any significant change.
The numbers worth pinning
Part 507's dates and structure come straight from FDA, cite the rule and its guidance:
- The animal-food rule is codified at 21 CFR Part 507 and summarized in FDA's FSMA final rule for preventive controls for animal food.
- Larger facilities have followed the animal-food CGMPs since September 2016 and preventive controls since September 2017 with staggered later dates for small and very small businesses.
- Human-food by-products diverted to animal food need only holding-and-distribution controls when the facility is Part 117 compliant, 21 CFR 507.28 with 117.95.
- A food safety plan must be prepared or overseen by a preventive controls qualified individual and reanalyzed at least every 3 years (Part 507 Subpart C).
Like every FSMA plan, this one is judged on records, monitoring logs, corrective actions, verification, supplier documents, and by-product holding conditions. Paper systems make those easy to skip and slow to retrieve; capturing checks at the point of work keeps the plan honest between inspections and turns audit prep into a query. That is the digitize-the-paper move Harmony runs for production and quality logs (see how CLS did it), and it connects the animal-food plan to environmental monitoring and the same HACCP-based discipline behind the human-food side.