FDA Drops the Ball on Pet Food Recalls and Early Warning Notification System!

Whatever Happened to the Food and Drug Administration’s Animal Feed Safety System?

On the heels of the 2007 pet food scandal the shamed-faced FDA scrabbled to regain its composure by attempting to develop animal feed safeguards. As a result, in November of 2007 the FDA released its Food Protection Plan, aptly named the Animal Feed Safety System, or AFFSS. Unfortunately, rather than take responsibility the FDA offers us a spoonful of pabulum by referring to America’s previous safety record for animal feed. Conversely the FDA’s only mention of what really prompted their action is, “the public became alarmed last year when imported feed ingredients, contaminated with melamine and related compounds, were used in pet food, which resulted in sick dogs and cats.”

That is of course an understatement. Dogs and cats did not just become ill, they died! And America’s track record for animal feed safety may be “good” compared to third-world countries but this is America and Americans expect and demand higher safety standards. It could be said that it took the death of thousands of innocent American pets to get the FDA to take action on imported and domestic pet food products.

Supposedly the FDA Food Protection Plan’s intent is to identify potential food hazards before damage occurs. Here is the FDA’s own definition of the Animal Feed Safety System’s directive:

A risk-based, preventive animal feed safety program [that] will require producers and distributors of animal feeds to take into consideration hazards, whose presence in or introduction into their feeds pose an unacceptable risk to animal or human health and to develop a plan to prevent or eliminate, or reduce to an acceptable level, those hazards.

However, FDA bureaucracy enjoys adding more acts, programs, and titles, just to keep things complicated. So, not only is there an AFSS but the FDA Amendments Act of 2007 was passed to put the pressure on the FDA itself to “improve the safety of pet food and ingredients¹.” Title 10 of this act requires the FDA to establish, “by regulation, ingredient standards and definitions, processing standards, and labeling standards—including nutritional and ingredient information—for pet food. It also requires the FDA to establish an Early Warning Surveillance and Notification System to identify adulteration of the pet food supply and illness outbreaks and to notify veterinarians and other stakeholders of pet food recalls.²”

Confused by all the abbreviations, programs, titles, and acts? You are not alone! It’s no wonder that it takes a whole team of people to keep up with it all. This team is the Center for Veterinary Medicine (CVM), also part of the FDA. In April 2008 the CVM filed its 3rd version of the AFSS Framework Document. The idea was to identify and plug in any gaps found in the original framework document. The bottom line is, what have Americans received thus far? Revisions and more revisions — all with the idea of improving the initial AFSS food protection plan.

Currently, there are still no enforceable regulations to protect pets from food contamination. Yet, it is well over a year since the deaths of thousands of America’s pets that spurred the FDA to set up the AFSS in the first place. Never mind that the tainted pet food in early 2007 resulted in a 24 million dollar lawsuit. Or that there is still no early warning notification system in place. So when will regulations for ingredients, processing, and standardization of feed labels be introduced? And, when will an early warning notification system be in place? Your guess is as good as the FDA’s!

¹2008 - Volume XXIII, No. III, FDA Newsletter

²2008 - Volume XXIII, No. III, FDA Newsletter

Phillipine Customs Keeps an Eye on China-made pet food

As reported on Saturday-Sunday, October 25-26, 2008

Manila Standard Today

By Joel E. Zurbano

CUSTOMS personnel have been put on the alert for pet food and animal feeds from China after reports said that some 1,500 dogs in Northeast China died after consuming melamine-tainted feed.

Animal feed comes as the latest addition to the growing list of China-made products and goods that the Customs bureau has been closely watching in the wake of a melamine scare that gripped the world over the past few weeks.

In a memorandum, Customs director Jairus Paguntalan told intelligence officers were assigned at the Manila International Container Port, Ninoy Aquino International Airport, Port of Manila and all Customs Intelligence and Investigation Service offices nationwide to “monitor and be alert for all shipments of pet food and animal feeds made/manufactured/processed/exported from China.”

The Food and Drug Administration of the United States came up with an advisory directing the recall of pet food due to melamine content and the news report of melamine-tainted feed that killed 1,500 dogs in Beijing, China.

“Even if the reports are only about dog food, our monitoring will cover the pet food and animal feeds but it will be a case to case basis. It will cover processed meat products for dogs, cats, and the like,” Paguntalan said.

“We will hold the shipment, take samples and conduct tests,” said Paguntalan, director of the Customs Intelligence and Investigation Service.

While the shipment is on hold, Paguntalan said, they will check on the agency that has the proper authority to examine and to give clearance.

He explained that dog food usually comes from leftover carcass of cows and carabaos which is then grinded.

Salmonella: The new bane of the pet food industry?

What’s a Pet Parent to Do?

Salmonella has reared its ugly head again, this time in the Hartz Mountain Rawhide Chips. I am not a big advocate of feeding dogs rawhide or pig ears: They are indigestible, some occurrences of intestinal blockage have been reported, and some dogs (when left unsupervised) have choked on them. In addition, some of these products use animal parts from Asia or other third-world countries. These countries do not regulate pesticides, chemicals, or sanitation. Even if the hides are from the United States the chews could be processed in a foreign country. Arsenic is just one of the harmful substances used in rawhide processing, another is bleaching solutions (to make the hide white). Unfortunately, dog owners are blissfully unaware of this and they continue to give Fido these treats. It’s not that dog parents want to give their four-pawed pals something harmful, it’s just that most people believe these products wouldn’t be on the market if they were dangerous. And yet, time and time again the pet product industry breaks this trust.

You might recall that back in August another outbreak of Salmonella turned up in pet food. This time it was the Mars Petcare US company. The Centers for Disease Control and Prevention (CDC) discovered a link between Salmonella Schwarzengrund, pet food, and an outbreak of Salmonella that affected sixty-six people and spanned 18 states. As it turns out, these people were affected by the exact same strain of Salmonella discovered in the Mars Petcare brand of Red Flannel Large Breed Adult Formula and the Krasdale Gravy kibble. The Pennsylvania Health Department also discovered traces of the strain at the Pennsylvania factory where the food was produced.

Mars was quick to act, recalling the food within a week of this discovery. Then once again in September another Mars Petcare US pet food recall was made. Again it was over “potential” salmonella contamination. This time a variety of their brands were affected and products in 31 states were pulled from the shelves.

No doubt about it, Salmonella is on the rise. In fact, the CDC reports that there are about 40,000 cases of Salmonella poisoning in the United States each year. That’s just the ones that are reported — milder cases are rarely reported — so it is difficult to state with certainty exactly how many cases actually occur each year. The problem is that Salmonella is highly transferable. That is, a person handling contaminated dog food can get it on their hands and accidentally ingest it. Another problem is that drug-resistant strains of Schwarzengrund Salmonella are increasing. And if a person contracts a drug-resistant variety they will require prolonged hospitalization. In some cases it results in death. As is usually the case with disease, the elderly and young are more likely to become victims. Furthermore, Schwarzengrund Salmonella can create multiple problems, even after a person recovers. One is Rieter’s Syndrome, an arthritis-like disease that causes painful joints, eye irritation, and painful urination.

On the whole, the frequency of Schwarzengrund Salmonella outbreaks is alarming. It reminds us to be cautious when handling all food products, including pet food. Certainly we need to take care in washing feeding bowls, utensils, and measuring cups. In addition, we want to caution small children about playing with pet food. Finally, as pet parents and consumers we want to educate ourselves about the food we are feeding our dogs and cats. Being enlightened will help us select the best quality of dog food or cat food for the four-pawed members of our family. It’s not just about our pets, Salmonella involves the human members of our family too. Let’s all wise up about pet food, take the time to investigate and research — after all, you wouldn’t put anything harmful into your baby’s mouth would you? By the same token, no loving pet parent would want to place harmful food into their furry baby’s bowl.

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