Raw Pet Food Pathogen Control Readiness
Start from FDA's any-serotype position for pet food, then show in writing how each pathogen hazard is controlled and handled.
In Short
- Any Salmonella in pet food matters.
- Hazard analysis must be written.
- Corrective actions are written.
The Pet Food Manufacturing Guide
Balanced formulas. Safe ingredients. Every bag traceable.
- Which rules reach your product
- Supplier to silo
- Premix, extrude, test, release
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The Pet Food Manufacturing Guide
Balanced formulas. Safe ingredients. Every bag traceable.
Raw pet foods are sold without a cooking step at the plant, and FDA's compliance policy treats pet food contaminated with any Salmonella serotype as warranting regulatory action. This guide links that policy to the written hazard analysis, preventive controls, corrective actions and verification in 21 CFR 507 Subpart C. Orientation, not legal or veterinary advice. Sources checked 4 Oct 2026.
FDA's Salmonella position for pet food
Compliance Policy Guide Sec. 690.800 (July 2013) is non-binding guidance for FDA staff.
More on fDA's Salmonella position for pet food
It says FDA considers animal food that may be injurious to health because of Salmonella to be adulterated under section 402(a)(1) of the FD&C Act, and that regulatory action is warranted for pet food contaminated with any Salmonella serotype, because people handle pet food directly. Pet food in the guide includes treats and chews. Animal feed for other animals is treated differently, with action tied to serotypes pathogenic for the species.
A Written Hazard Analysis
Section 507.33 requires a written hazard analysis for each type of animal food, whatever its outcome. It must consider biological hazards, including environmental pathogens and other pathogens; chemical hazards, including nutrient deficiencies or toxicities; and physical hazards.
Hazard analysis entry (507.33)
| Field | Example |
|---|---|
| Hazard | Salmonella from raw meat ingredients |
| Type | Biological |
| Severity and probability | Assessed for animals and people handling the food |
| Needs a preventive control? | Decision and reason recorded by PCQI |
- Hazard
- Example
- Salmonella from raw meat ingredients
- Type
- Example
- Biological
- Severity and probability
- Example
- Assessed for animals and people handling the food
- Needs a preventive control?
- Example
- Decision and reason recorded by PCQI
More on a Written Hazard Analysis
Each identified hazard is evaluated for the severity of illness or injury to humans or animals and its probability without preventive controls. For raw products, the people handling the food at home are part of that severity assessment, which is the point the compliance policy makes.
Preventive controls without a cooking step
Under 507.34, hazards requiring a preventive control must be significantly minimised or prevented by written controls, at critical control points where there are any and elsewhere as appropriate. Process controls state the parameters and the minimum or maximum values that control the hazard.
More on preventive controls without a cooking step
If your process includes a pathogen reduction step, it is managed as a process control with its parameters and limits. If it does not, the hazard analysis must show how the hazard is otherwise addressed. Section 507.36 sets narrow cases where a downstream customer's control can be relied on with written disclosure.
Testing, Monitoring and Corrective Action
Section 507.42 requires written corrective action procedures, appropriate to the hazard and control, including for a pathogen or indicator organism found by product testing or environmental monitoring. Section 507.49 requires verification that preventive controls are consistently implemented and effective, through activities appropriate to the facility and food.
More on testing, Monitoring and Corrective Action
The detailed paragraphs of 507.42 and 507.49, and the environmental pathogen evaluation in 507.33(c)(2), should be read in full; this guide summarises their opening requirements only.
Lot Trace and Hold Decisions
When a product or environmental result comes back positive, speed depends on records already in place: which raw material lots went into which production lots, which lines and dates, what was tested, what is on hand and where each lot was shipped. People decide what to hold, what further sampling is needed, what the corrective action is and whether a recall is warranted.
Worked Example: Lot RP-0915 Positive Swab
- Day 0Environmental swab near filler positive
- Day 0Team places affected lots on hold and starts corrective action
- Day 1Lot genealogy and shipments pulled for review
- Day 3People decide disposition and record evidence
More on lot Trace and Hold Decisions
Keep each decision, who made it and the evidence used, linked to the lots.
Questions
Is the Salmonella policy a regulation?
No. CPG Sec. 690.800 is non-binding guidance for FDA staff describing when FDA considers regulatory action warranted; the adulteration provision it applies is in the FD&C Act.
Must the hazard analysis be written even if no hazards need controls?
Yes. Section 507.33(a)(2) requires a written hazard analysis regardless of its outcome.
What happens when an environmental swab is positive?
Follow your written corrective action procedures under 507.42; people decide on holds, further sampling and product disposition.
Does 507 apply to every pet food maker?
Applicability and exemptions are set elsewhere in Part 507 and were not reviewed here; confirm your facility's status.
Practical orientation, not legal advice. Rules differ by jurisdiction; your quality and compliance team decides what applies.
Keep reading
Pet Food and Animal Food cGMP Readiness: 21 CFR 507
BSE Feed Rule Readiness: 21 CFR 589.2000 and 589.2001 for Feed and Pet Food
Pet Food Labels: 21 CFR 501 and AAFCO Model Requirements
21 CFR 507 Animal Food Guide: CGMP, Food Safety Plan, PCQI and Supply-Chain
Salmonella Pet Food Environmental Monitoring Readiness Guide