What's With All The Dog Food
Recalls?
Carlotta Cooper
If you buy dog food – and most people
reading DOG NEWS probably fall into that category – then you've
probably noticed that there have been a lot of dog food recalls in
the last few months, especially over concerns about Salmonella.
In fact, there has been a notable increase in Salmonella
investigations in dog food recently. I've heard lots of dog owners
speculating that they can't trust any dog foods now. People seem to
be becoming rattled by the frequent voluntary recalls issued by
various dog food companies. It would probably sound like nonsense if
I told you that increased recalls over this issue were a good sign,
right?
Actually, there have been some things
going on behind the scenes in the world of the Food and Drug
Administration and dog food companies that should make you feel
better, even if it's temporarily resulting in more recalls.
For one thing, the U.S. Food and Drug
Administration (FDA) Center for Veterinary Medicine announced plans
in March to investigate the incidence of Salmonella
contamination in pet foods – which has meant increased scrutiny of
the pet food industry. They made a similar announcement in November
2011: http://www.huffingtonpost.com/2011/11/02/pet-food-salmonella-fda_n_1071850.html
In March the FDA indicated that they had given an assignment to all
of their district offices throughout the country to collect an
undisclosed number of samples of domestically manufactured petfood
products for analysis. The samples do not cover imported products in
either import status or domestic imports. This sampling includes both
petfoods as well as treats and nutritional supplements. The
instructions were to collect samples from a wide variety of
manufacturers and from different locations. Samples are collected
from manufacturing sites, from distributors, and from retailers
around the country. Canned foods are excluded from the assignment but
all other kinds of foods are included – extruded, baked, smoked,
frozen, and refrigerated. Inexpensive as well as super premium foods
are included. The FDA doesn't care how much the food costs.
Note that the American Pet Products
Association (APPA) http://www.americanpetproducts.org/newsletter/issue.asp?id=721#article5735
, a marketing survey group, reported at the time of the FDA's press
release that 300 official samples would be collected. This
information is not on the FDA site and I can't verify where it came
from. According to APPA each district is supposed to collect six
official and six investigational samples from non-canned petfoods.
The sample foods will be foods for ALL PETS. They will collect five
official and five investigational samples from pet treats; and, three
official and investigational samples from vitamins, minerals and/or
other nutritional supplements. The sampling will continue until
September 30, 2013.
Again this information comes from the
American Pet Products Association and they attribute it to the FDA.
However, it is not found on the FDA site or with other information
about the program.
The FDA seems to primarily be concerned
about public health – human health. Petfoods are much more likely
to be handled by humans than other animal feeds. Children, the
elderly, and people who might have a compromised immune system can
handle petfoods, leaving them susceptible to pathogenic
microorganisms. There have been cases where Salmonella
infection in people was traced back to exposure to pet products.
The FDA's concern about Salmonella
in petfood isn't new. The agency has taken the view that animal feeds
that contain Salmonella are contaminated and subject to
enforcement action for decades. It's part of the Code of Federal
Regulations. There is also a Compliance Policy Guide (CPG) that
states that Salmonella-contaminated dry dog food is considered
to be adulterated.
Once the findings for this assignment
about Salmonella are collected, the FDA will probably use them
to make further policy decisions regarding petfood. However, the FDA
has made it clear that in the course of collecting their samples they
will take action against any pet products they find to be
contaminated. That's what's been happening in the last few months
with the voluntary petfood recalls. The FDA agents have been
collecting their samples and, if they find evidence of Salmonella,
FDA “suggests” to the company that they issue a voluntary recall
to take care of the problem. (FDA can do more than suggest if the
company is not compliant. Most companies prefer to issue a voluntary
recall.)
As mentioned, canned foods are not
being examined at this time because these products are presumably
produced in accordance with low acid canned food regulations so they
are commercially sterile and don't pose any kind of risk to the
public. However, the kibble, raw food, and treats you buy your dog
that are manufactured in the U.S. are subject to testing by the FDA
for Salmonella, at least for the near future. So, there may be
some more recalls but at least you will know what the FDA is doing.
There
could be another reason for an increase in recalls lately. The
Food and Drug Administration Amendments Act of 2007 (Pub. L.110-085),
section 1005 directed the FDA to establish a Reportable Food Registry
for Industry.
http://www.petfood.aafco.org/RFRReportableFoodRegistry.aspx
The
Reportable Food Registry (RFR or the Registry) is an electronic
portal for Industry to report when there is reasonable probability
that an article of food will cause serious adverse health
consequences. The Registry helps the FDA better protect public health
by tracking patterns and targeting inspections. The RFR applies to
all FDA-regulated categories of food and feed, except dietary
supplements and infant formula. It
is the company's responsibility to determine if the food has a
reasonable probability of causing a severe adverse health consequence
or death to humans or animals. Once this has been determined to
exist, the company must
notify the FDA using the RFR system within 24
hours of
the determination. So, it's possible that in some cases a petfood
company may be notifying the FDA about possible serious health
consequences due to something in their food.
There
may also be increased vigilance and testing by state feed control
officials which are leading to more recalls.
And
there's more. All of this testing by the FDA, as well as the
Reportable Food Registry, could be to help support a proposed rule on
Preventive Controls for Animal Food that will implement part of the
Food Safety Modernization Act (FSMA). The proposed rule is expected
to closely mirror the proposed rule for Preventive Controls for Human
Food published in January of this year.
http://agfdablog.com/tag/food-safety-modernization-act/
According to the FDA, the “Food Safety Modernization Act (FSMA),
the most sweeping reform of our food safety laws in more than 70
years, was signed into law by President Obama on January 4, 2011. It
aims to ensure the U.S. food supply is safe by shifting the focus
from responding to contamination to preventing it.” I think it's
safe to say that one reason petfoods are taken so seriously in these
regulations is because of the 2007 petfood recalls.
So, to sum up, the FDA is currently
taking samples of petfoods and actively testing for Salmonella.
This is a good thing. It doesn't mean that dog food companies are
making worse food than they used to make or using worse ingredients.
It means there is more testing. It also means there are going to be
more regulations concerning petfoods. I know everyone is tired of
recalls and worried about what to feed their dogs but the end result
should be safer petfood.
In case you're curious, here's the FDA
web site listing of the petfoods that have been recalled so far in
2013:
http://www.fda.gov/animalveterinary/safetyhealth/recallswithdrawals/default.htm
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