Sadly, there have been a rash of pet food recalls in the US recently, and it’s probably not lost on anyone that, aside from J.M. Smucker’s Gravy Train dog food, most of the products recalled have been raw pet foods. This is certainly not a new phenomenon; it’s happened in previous years since the Food Safety Modernization Act (FSMA) was signed into law in 2011, and the Food and Drug Administration (FDA) has made no secret of its view on the safety of raw pet foods, issuing several documents and warning statements over the years.
In fact, FDA posted another warning on its website on February 22 of this year: “Avoid the dangers of raw pet food.” Nothing ambiguous about that!
Raw pet food is a small but quickly growing category, and even FDA concedes its popularity among a segment of pet owners. So why does the agency focus so much concern and scrutiny on these products?
Actually, FDA’s policies make you wonder if they think any pet food is safe, though raw pet food gets special attention. Let’s review: shortly after passage of FSMA, FDA declared a zero-tolerance policy for Salmonella in all pet foods, citing mainly the risk to human health, especially for immune-compromised people who might handle contaminated pet food. And indeed, some Salmonella outbreaks in humans from handling pet food have occurred, including rather significant ones in 2008 and 2012.
Yet it’s important to remember that neither FDA nor the US Department of Agriculture (USDA), which oversees meat-based food products, has a zero-tolerance policy for Salmonella in human foods, even though people often handle raw meat, produce and other food items that can (and sometimes are) contaminated. Not to mention that zero Salmonella is virtually impossible; there are more than 2,200 serotypes of the pathogen, and it’s essentially everywhere in the environment. And, finally, that the number and frequency of pet food recalls is very low compared to those in human foods.
Nonetheless, FDA followed up in 2013 with a formal “Compliance Policy Guide for Salmonella in Food for Animals,” affirming the zero-tolerance policy. That has led to higher numbers of recalls of all types of pet food products out of an abundance of caution on the part of manufacturers.
Also in 2013, the agency seemed to hone in on raw pet foods. First, a number of recalls of such products cropped up in a short time span, similar to what has happened to date this year. In November 2013, FDA released results of a two-year study on the presence of Salmonella and Listeria monocytogenes in several categories of pet food products, showing a higher incidence of both pathogens in raw pet foods. According to FDA, there was only one other instance of Salmonella present, in a dry cat food; no other products outside of the raw category had either pathogen. (Independent researchers have also found a higher incidence of pathogens in raw pet foods.)
In 2015, FDA stepped up its game: it assigned field staff to collect samples of raw pet food to be analyzed for Salmonella, Listeria monocytogenes and E. coli. While that apparently was a special “sweep,” historically FDA has relied on state departments of agriculture (DOAs) to collect samples, test them and report the results, according to Nick Ceppi, senior VP of marketing, nutrition and regulatory affairs for Bravo Pet Foods, which specializes in raw diets.
“The state DOAs have the funding to do the sampling/testing, FDA does not,” concurred Cathy Alinovi, DVM, executive director of the Next Generation Pet Food Manufacturers Association (NGPFMA).
And that’s what’s happening now; most of the recent recalls — several in Nebraska, Michigan and Colorado each, plus at least one in Minnesota — occurred after a state official bought retail samples and tested them. That sampling is definitely focused more on raw pet foods than other formats. “There is a long-standing bias by FDA against the inherent risk of raw diets,” said Ceppi, speaking on behalf of Bravo. “At the same time, as FSMA continues to roll out, states are being urged by FDA to up their enforcement efforts. No question, there are more frequent inspections of brands in the raw diet category.”
Yet, he added, other pet foods are also affected: “We believe FDA is taking a step-by-step implementation and increased enforcement under the intent of FSMA. Raw diets (in fact, any food, human or pet) that run the risk of a possible pathogen contamination are being scrutinized.”
Indeed. After all, despite FDA’s own study data showing nearly no incidence of pathogens in pet foods other than raw diets, the pet food recall list over the past several years proves that no type of pet food is immune, particularly to recalls related to Salmonella because of the zero-tolerance policy. In many instances, the pathogen isn’t found in the product itself, only in the facility or environment. (Because again, it’s essentially everywhere.)
Like all pet food companies, ones specializing in raw diets do follow safety protocols, including manufacturers that have had product recalls. For example, Steve’s Real Food, one of the recently affected companies, stated that it had tested samples from the batch that the contaminated product was found in, and held the batch for distribution until test results were back.
Yet a statement on the company’s website also indicates that currently Steve’s does not believe in using one of the most effective ways known to control and kill pathogens in raw pet foods, high press pasteurization, or processing (HPP). The company’s voluntary recall notice hints at why: “As you may know, Salmonella is often present in raw meat and poultry and the most effective way to remove pathogens is to heat the food to 160° or higher; however, doing this or other common pathogen removal processes will denature the food and remove the enzymes which help with digestion and promote a healthy pet.”
While I was on that page, a small survey popped up, asking, “Do you prefer your raw dog food to be high pressure pasteurized?” So perhaps the company is considering this as a next step in its safety program.
“While the rap on HPP is that it may denature the raw, it is the best in-hand solution that has acceptance by FDA as a best practice,” Ceppi said. “So if we can deliver 90 percent of the same benefits (as an untreated or minimally treated raw diet) with none of the downside, that seems like a good compromise of risk reduction and benefit to the pet.” Bravo does use HPP and a variety of other pathogen-kill steps, he added, and they test and hold samples prior to product release.
“Our association does not take a stance on how a manufacturer should do his/her process,” said Alinovi of NGPFMA. “The marketplace is large, there is room for everyone in the playing field. Different safety techniques allow for niche differentiation, which keeps the pet food playing field diverse.” Each of its members does use a HACCP program or is developing one to meet FSMA requirements and deadlines, she added.
NGPFMA also responds to the current FDA policy by trying to influence it, or at least other regulations related to pet food. “Our stance is to support our manufacturers in the regulatory arena — something they’ve not had before,” Alinovi said.
Ceppi boiled the situation down to the base facts: pet food is held to a very high standard not imposed on human foods — zero tolerance — yet also to its own commitment to provide safe, healthy products to its customers and their beloved pets. It’s in every pet food company’s best interests, financial and values-wise, to avoid recalls.
“Let’s bottom line this,” Ceppi said. “Our business survival depends upon meeting the requirements of the law (FSMA) as written. Recalls are very expensive in terms of dollars and cents, and even more so to a company's reputation. So, we at Bravo (and all of the raw diet industry) are making a maximum effort to find a reliable solution to pathogen control. We look to do the best we possibly can to offer a safe, species-appropriate diet that truly benefits the pet.”
Note: A call to FDA for further information was not returned.