2013 Salmonella assignment
The FDA's Center for Veterinary Medicine has issued a field assignment to collect and analyze samples of petfood, pet treats and pet nutritional supplements in interstate commerce in the US for Salmonella.
As the moderator for the sessions on petfood safety at the 2013 Petfood Forum, I can say without fear of contradiction that Salmonella control was a very hot topic. Multiple speakers addressed the subject, and the information conveyed to the manufacturers in the audience was indeed timely. Most readers are likely aware of the notable uptick in the number of recalls due to potential Salmonella contamination of petfoods in recent months. This may be due to more reports of contamination as mandated under the Reportable Food Registry as well as increased vigilance and testing by state feed control officials.
Regardless, an announcement by the US Food and Drug Administration (FDA) Center for Veterinary Medicine on its plans to investigate the incidence of Salmonella contamination in petfoods will likely result in even more scrutiny of the industry.
The FDA notice, dated March 22, 2013 (see Sidebar: 2013 Salmonella assignment), indicated that it has issued an assignment to district offices throughout the US to collect an undisclosed number of samples of domestically manufactured petfood products for analysis. The sampling is to include mainstay foods as well as treats and nutritional supplements. Instructions are to collect samples from a wide variety of manufacturers and from different locations; i.e., both from manufacturing sites and from distributors and retailers. The types of petfood to sample are not specified, but since canned foods are expressly excluded from the assignment, it can be assumed that all other types (e.g., extruded, baked, smoked, frozen, refrigerated) are fair game.
The purpose for this assignment appears to stem from FDA's primary concern for public (i.e., human) health. Compared to livestock feeds, petfoods are more likely to be handled by persons in the home, increasing the likelihood of exposure to children, the elderly and others who may be immunocompromised, hence more susceptible to infection by pathogenic microorganisms. The agency cites several incidences where Salmonella infection in humans was traced back to exposure to pet products.
FDA's concern with Salmonella in animal feed, and specifically petfood, is not new. The agency's view that animal-based feed ingredients such as meals found to contain Salmonella are adulterated and subject to enforcement action has been a part of the Code of Federal Regulations for decades [see 21 CFR 500.35]. For almost as long, a Compliance Policy Guide (CPG) has stated that Salmonella-contaminated dry dog food is also considered to be adulterated (see Sidebar: FDA policies for Salmonella in animal feed).
More recently, FDA issued a draft CPG as to its perspective regarding how it intends to address incidences of Salmonella contamination depending on the type of feed (see Sidebar: FDA policies for Salmonella in animal feed). For all animal feeds, items that are not intended for further processing but contain Salmonella serotypes potentially pathogenic to the intended species are actionable. However, for feed items with "direct human contact" (primarily petfoods), those found to contain Salmonella are considered adulterated and subject to enforcement action regardless of serotype.
What will FDA do with the findings of this assignment? It is likely to use the information collected to further refine its policy and priorities. However, FDA made it clear that in the course of implementing this assignment, it intends to take action against any pet product found to be contaminated. Manufacturers of canned foods are out of the target zone at this time, on the premise that product produced in accordance with low acid canned food regulations [21 CFR 113] is going to be commercially sterile and pose no risk. Otherwise, whether you make a dry food, raw product or anything in between, one or more of your products may be tested by FDA in the foreseeable future.
There have been concerns expressed that this assignment and/or recalls based on Salmonella contamination may be unfair to raw petfood manufacturers. It is true that on the human food side, raw meat and poultry products intended for human consumption are allowed to proceed to market with expectation that there will be a certain percentage of Salmonella positives [9 CFR 310.25(b) and 9 CFR 381.94(b)]. Those facilities exceeding a prescribed percentage face significant consequences. Also, in the case of "ready-to-eat" meat and poultry products for humans, regulations demand adequate processing to destroy Salmonella, and products that fail in that regard have in fact been subject to recalls.
In any event, the issue of Salmonella contamination certainly is not "ignored" when it comes to human raw meat and poultry. Regardless, the big distinction between raw meat and poultry products for people and raw petfoods is that the former must bear label instructions for safe handling, including the need for adequate cooking, on the presumption that all product may be contaminated.
On the petfood side, though, the food intentionally is not cooked, so that kill step is of no benefit. While the need for raw manufacturers to take additional non-thermal steps to mitigate the risk may not be equitable, for FDA to make a distinction in enforcement based on how the product is intended to be fed would appear to run contrary to its objectives in issuing this assignment.