Paul Industries designs and installs cleaning and sanitation systems across Missouri. Plants making both human food and animal food are subject to two preventive controls rules, 21 CFR Part 117 for human food and Part 507 for animal food, and many run two parallel systems as a result. They frequently do not need to. Where a facility is required to comply with subpart B of Part 507 and also with subpart B of Part 117, it may choose to comply with 117 for its animal food instead, and the same election is available for subpart C, provided the food safety plan addresses the animal food hazards requiring a preventive control.
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One system instead of two
A facility that makes both human and animal food faces an obvious administrative problem: two rules, written separately, covering the same building, the same people and frequently the same equipment. Running both properly means two sets of procedures, two training regimes, two document structures and two internal audit trails, and the practical result is that one of them is maintained well and the other is maintained when somebody remembers.
The regulation anticipates this. Where a facility is required to comply with subpart B of Part 507 and is also required to comply with subpart B of Part 117 because it handles both human and animal food, it may choose to comply with 117 subpart B for the animal food instead. The equivalent election exists for subpart C, on the condition that the food safety plan also addresses hazards for the animal food, where applicable, that require a preventive control.
The practical consequence is that a dual plant can run a single system built on the human food rule, provided the hazard analysis genuinely covers the animal food side. That is not a loophole and it is not a lowering of standards, because 117 is generally the more demanding of the two. It is a consolidation, and it removes the failure mode where two systems exist and one quietly decays.
What it means for engineering is less about equipment and more about how the plant is scoped. If one system is going to cover both, then cleaning validation, monitoring, recording and verification have to be designed to satisfy the human food rule across the whole facility rather than being applied at one standard in one area and another elsewhere. In practice that usually means the animal food side is brought up rather than the human food side being relaxed.
The decision is the client’s and their regulatory adviser’s rather than ours. What we would say from the engineering side is that designing a plant to one standard throughout is simpler, cheaper to operate and considerably easier to evidence than maintaining a boundary between two regimes inside one building.
What running one system changes
| Two systems | One system under 117 | |
|---|---|---|
| Procedures | Two sets, maintained separately | One set, applied throughout |
| Training | Two regimes; staff cross between them | One regime |
| Cleaning validation | Different bases in different areas | One basis across the plant |
| Recording | Two document structures | One |
| Typical failure | One system decays quietly | Fewer places to hide a gap |
| Engineering effect | A boundary to design and police | One standard to design to |
| Cycle profile | Per cycle | 300 cycles a year |
|---|---|---|
| 40 kW for 1 hour | $3.15 | $944 |
| 80 kW for 90 minutes | $9.44 | $2,833 |
| 150 kW for 2 hours | $23.61 | $7,083 |
The cleaning problem in a pet food plant is fat
Whichever rule governs, the physical cleaning challenge in this sector is consistent and it is not the one most food plants face.
Pet food carries a high fat content, much of it applied after extrusion as a coating, and fat at temperature behaves differently from the soils that dominate dairy or beverage plants. It films rather than dissolving, it polymerizes on hot surfaces into a hard deposit that ordinary caustic struggles with, and it carries into places water-based soils do not reach because it moves as an aerosol and a film rather than as a liquid.
The practical consequences are that temperature matters more than concentration for the initial removal, because fat has to be brought above its melting point before chemistry can act on it; that hot surfaces need attention before the deposit polymerizes rather than after; and that dry areas of the plant carry fat films on surfaces nobody thinks of as soiled, including overhead structure and the outside of equipment.
The part that catches plants out is the interaction with the dry side. A pet food plant after extrusion is a low-moisture environment, so wet cleaning is restricted for the reasons set out on our Wisconsin and Utah pages. Fat, however, is difficult to remove dry. That tension, a soil that wants hot water and an environment that does not want water at all, is the genuine engineering problem in this plant, and resolving it means deciding in advance which areas accept wet cleaning as a planned event with a drying regime, and which are dry-cleaned only.
Standards referenced: EIA electricity price data · 21 CFR 117 · ASME BPE
Frequently asked questions
Do you install cleaning systems for Missouri plants?
Yes, across the pet food and animal health corridor and statewide: CIP where enclosed systems justify it, parts and equipment cleaning, hot water systems sized for fat removal, dry cleaning provision for low-moisture areas, and the utilities and controls around them.
Do we need two food safety systems?
Frequently not. Where a facility is required to comply with subpart B of Part 507 and also with subpart B of Part 117 because it handles both human and animal food, it may choose to comply with 117 for the animal food instead, and the same election exists for subpart C, provided the food safety plan addresses the animal food hazards requiring a preventive control.
Is that a lowering of standards?
No, generally the reverse. Part 117 is the more demanding rule, so consolidating onto it usually brings the animal food side up rather than relaxing the human food side. What it removes is the failure mode where two parallel systems exist and one is maintained well while the other decays.
What does that mean for engineering?
That cleaning validation, monitoring, recording and verification are designed to one standard across the whole facility rather than at different standards in different areas. Designing a plant to a single standard throughout is simpler, cheaper to operate and much easier to evidence than policing a regulatory boundary inside one building.
Who makes that decision?
You and your regulatory adviser, not your contractor. What we contribute is the engineering consequence: tell us which way you are going before the design is fixed, because a plant built to two standards with a boundary through it is a different building from one built to a single standard.
Why is fat the main cleaning problem?
Because it behaves unlike the soils that dominate most food plants. It films rather than dissolving, polymerizes on hot surfaces into a hard deposit that ordinary caustic struggles with, and travels as an aerosol and a film into places water-based soils never reach, including overhead structure and the outside of equipment.
What removes it?
Temperature first, then chemistry. Fat has to be brought above its melting point before cleaning chemistry can act on it, so temperature matters more than concentration for initial removal. Hot surfaces need attention before the deposit polymerizes, because once it has, the cleaning required is substantially more aggressive.
How does that fit with a dry plant?
Uncomfortably, and that tension is the real engineering problem here. After extrusion the plant is a low-moisture environment where introducing water creates its own hazard, but fat is difficult to remove dry. Resolving it means deciding in advance which areas accept wet cleaning as a planned event with a drying regime, and which are dry-cleaned only.
Does Missouri energy cost affect cleaning design?
Very little. At 7.87 cents per kilowatt-hour against a national average of 8.13 (EIA, 2024), Missouri sits just below the midpoint, and a demanding cycle run three hundred times a year is about $7,083. Since fat removal needs temperature, that is a case where the energy is doing necessary work rather than being a candidate for trimming.
How do I get a quote for a Missouri cleaning project?
Use the form on this page or call 201-450-8280. Useful inputs are whether the plant makes human food, animal food or both, which rule you intend to operate under, where the dry and wet areas sit, your current cleaning approach on fat-bearing equipment, and your hot water capacity.
How is a cleaning event linked to both the human food and animal food rules in records?
By recording each cleaning against the line and product it protects, with the procedure stating which rule's requirement it satisfies, so that one record serves both frameworks without duplication. A single programme with dual references is simpler for the plant and clearer for an investigator than two parallel programmes.
What is a sanitation preventive control under Part 117 and Part 507?
A sanitation procedure identified in the food safety plan as necessary to control a hazard, such as allergen cross-contact or environmental pathogen contamination. It carries monitoring, corrective action and verification requirements that ordinary good manufacturing practice sanitation does not.
Why does hot fat residue resist ordinary cleaning?
Because fat that has been held hot has partly polymerised into a varnish that alkaline detergent alone does not lift, and each cleaning that fails to remove it leaves a layer for the next batch to build on. Removal needs the right chemistry, temperature and contact time chosen for the polymerised state.
What does the coating drum's cleaning circuit have to do that a normal circuit does not?
Keep the cleaning solution out of the dry zone, drain completely to a point outside it, and dry the equipment fully before production resumes, all within a schedule that does not leave the drum wet overnight. The circuit is designed around containment of water as much as removal of fat.
Can the extruder and preconditioner be cleaned in place?
The preconditioner and die assembly are normally cleaned by disassembly and wet cleaning in a separate area; the extruder barrel is cleaned by running through with a cleaning material. Wet cleaning at the extruder itself is confined by a physical boundary from the post-extrusion dry zone.
Where does allergen control apply in a plant making both human and pet food?
Human food allergen rules apply to the human side; the pet food side has its own cross-contact considerations for species-specific ingredients. Shared equipment between the two sides is the design question, and dedicated lines are frequently the simpler answer.
How should the sanitation schedule differ between the wet and dry zones of a pet food plant?
The wet side before extrusion runs a daily wet clean like any food plant, while the dry side after the dryer is cleaned dry on a schedule set by residue build-up and environmental sampling results rather than by the calendar. Running one schedule across both zones either under-cleans the wet side or introduces water where it does harm.
What about cleaning animal feed and premix equipment?
Feed and premix carry medicated and nutrient ingredients where carryover between batches is the control. Flushing and sequencing are the usual methods, with wet cleaning reserved for defined intervals and followed by complete drying.
What should an FDA investigator be able to trace in a combined human and animal food plant?
The written sanitation control, the cleaning records for each line, the verification results, and the corrective actions, with each linked to the line and the rule it satisfies. A combined system is defensible when the records show which requirement each cleaning event met, not merely that cleaning happened.
Should human and animal food be cleaned with different chemistry?
Not necessarily. Chemistry follows the soil and the equipment, not the customer. Where the same soils and equipment occur on both sides, the same validated cleaning applies, which is part of the case for one system.
How do you verify cleaning on a dry pet food line?
By environmental monitoring for the organism of concern, ATP or protein swabs where they are meaningful, and inspection of the locations where fat and fines accumulate. The record shows the plant's control is working over time.
Does the animal health sector in Missouri need CIP as well?
Yes. Veterinary pharmaceutical and biologics plants in the Kansas City corridor clean to pharmaceutical standards with validated CIP and, for biologics, inactivation. That is a different regime from pet food and we design for both.
How should chemical storage and dosing be arranged?
Central storage with proportioning to the stations, segregation of incompatible products, and dosing that records concentration. In a plant with two product types the same central system serves both, which is one of the practical benefits of running one programme.
Can an existing Missouri plant consolidate its two systems without an audit gap?
Yes, with a transition plan: the food safety plan is revised, the election is documented, procedures are merged, staff are trained on the single procedure, and records switch on a defined date. Done in that order there is no period without a valid system.
What is the commonest finding in Missouri plants running two systems?
The animal food side maintained less carefully than the human side, with cleaning verification that was done for one and assumed for the other. Merging the two is usually how the weaker side gets fixed.
Planning cleaning work in a Missouri plant?
Tell us whether you make human food, animal food or both, and which rule you operate under. Call 201-450-8280 or use the form below.
