Pet Food Safety

By Amy Fernandez

Consumers cannot be faulted for believing that major safety reforms followed the nationwide pet food recall in 2007. The source was eventually traced to wheat gluten imported from China that had been adulterated with melamine to boost its protein content. By then, the deadly contaminant had found its way into over 150 pet food brands and formulas. Officially, 950 cats and 2,200 dogs died from kidney failure as a result. It highlighted the lack of federal authority over pet food production. Outraged consumer groups, veterinary associations, and politicians demanded stricter safety regulations. Capitol Hill was buried under proposals to widen FDA authority. But after a few months, the issue faded from the news and political agendas.

Media coverage following that watershed incident did raise awareness about pet food safety. Consumers became more cautious and selective about labeling and content. In reality, that was the most significant change to come from that infamous episode in America’s long, interesting history with tainted food. Food safety has been a federal priority for more than a century. We no longer worry about sawdust in our bread, chalk in our milk, or lead in the canned peas. We feel confident that someone, somewhere is busy working to ensure that the products on store shelves are safe and accurately labeled. It’s a reassuring indication of our tax dollars at work, along with the indecipherable pages of regulations that make it happen.

Although volumes of incomprehensible revisions followed the 2007 recall, they boiled down to a single tangible revision in current policy. The FDA is working more closely with manufacturers and related agencies. It was hoped that better interagency communication would translate into more efficient identification of threats and timely public notifications. In other words, everyone agreed that it might help to let us know about this stuff a little faster. This is fine in theory.

We saw the revised policy in action on October 22 when the FDA issued its latest warning about tainted jerky treats. Ironically, they began receiving incident reports about suspected contaminants in Chinese imported dog treats during the melamine recall. A growing number of documented cases linked them to illness ranging from lethargy, vomiting, and diarrhea to gastrointestinal bleeding and sudden onset kidney failure. Reports revealed no geographic pattern to the outbreak, and circumstantial evidence suggested poisoning. FDA issued the first of many warnings and launched one of its most comprehensive investigations. Their Center for Veterinary Medicine analyzed blood and urine samples from poisoned pets, which revealed no answers. They screened over 1,200 product samples for contaminants commonly associated with those symptoms. After ruling out obvious possibilities like salmonella, pesticides, rodenticides, organic toxins, and chemical compounds like melamine, testing progressed to more obscure toxins. Routine product analysis had provided the key to identifying the melamine back in 2007. So far, that testing has raised plenty of other questions about approved content of imported pet foods, but no answer in this case. FDA collaborations with state and international research teams yielded the first concrete development. Last January, two major pet food retailers issued voluntary recalls after New York state agriculture officials detected six unapproved antibiotics in tested products. However, the randomness of content and concentration of this contamination ruled it out as the clear causative agent.

Confirmed cases approached 2500 when the FDA sent field investigators to China in April, 2012. Onsite inspections of several plants that produced this product revealed some surprises about ingredients, equipment, processing, packaging, quality control, sanitation, and record keeping, but no answers. Last week’s official warning reiterated developments since 2007 and again cautioned consumers about these products while requesting more samples for testing. Essentially, they are starting at the beginning in this exhaustive effort to identify and trace this contaminant. Officially, it’s an ongoing investigation. Even though it has been linked to almost 600 deaths, no mandatory recall can be expected unless that happens.

This illustrates how well recent safety reforms have worked in practice. From a more cynical perspective, it’s not surprising considering everything we’ve learned about pet food since 2007. The FDA’s frequent food and drug warning and recalls have given this government agency a perpetually high profile. Consumers cannot be faulted for assuming that they exert a similar level of control over commercial pet foods. However, their regulatory role in this deal is a work in progress. It was initially limited to identifying contaminants in animal feed. Way back in the day, the federal government acknowledged that tainted feed posed potential threats to public health. Later, FDA authority expanded to cover the growing commercial pet food market.

But their role in pet food safety remains primarily damage control rather than prevention. As in this case, they test to pinpoint contaminants and issue warnings and recalls when problems are detected. Pet foods typically don’t require FDA approval before they hit store shelves because most ingredients are deemed safe, or in the case of additives, they have prior FDA approval. Wheat gluten is a good example.

The FDA has asked Congress for enhanced statutory powers, but they are not the only player in this game. Since 2007, pet food consumers have made it their business to decipher the hieroglyphics on labels and familiarize themselves with AAFCO nutritional panels. The Association of American Feed Control Officials dates from 1909 when the feds first acknowledged the spiraling nightmare of conflicting, inefficient safeguards running rampant in the animal feed industry. In response, a voluntary corporation of industry reps, scientists, and veterinarians began developing model regulations for nutritional requirements, production standards, and labeling. In 1956, they appointed a committee to formulate commercial pet food policies, long after these products were routinely available to consumers. More than a decade later, in 1966, they published their first pet food production and labeling recommendations. Today, AAFCO guidelines also reflect feedback from a large advisory panel, which finally included a consumer advocate in 2008. Get the picture?

The AAFCO never accomplished its original goal of unifying interstate pet food safety. Perennial inconsistencies have made this so-called safety net more comparable to a regulatory rat’s nest. Federal, state, and local agencies share responsibility for tracing and containing risks posed by tainted pet food. Problems can occur anywhere along the line from raw ingredients to manufacturing, packaging, shipping, and retail distribution. The gaps, overlaps, and conflicts in this system posed substantial challenges long before the USDA first permitted pet food imports from China in 2003. Since then, this market has kept pace with all the other Chinese stuff that Americans cannot get enough of. In 2011, we imported 86 million pounds of pet food that fell within FDA guidelines.

Consumers are more attuned to potential risks of imported pet foods, but warnings focusing on ingredients and current labeling regulations don’t consistently identify the source of imported ingredients. Products manufactured domestically can contain components imported from countries that don’t maintain comparable safety standards. Random import inspections can allow problems to remain undetected until unsuspecting consumers make the unhappy discovery.

If there is such a thing as good timing for this stuff, the latest jerky treat warning coincides with recent announcements about the FDA Food Safety Modernization Act. When Congress approved the plan in 2011, it was heralded as the biggest overhaul of food safety regulations since 1938. Essentially, it changes their focus. Rather than reacting to situations after contaminated food enters the market, the FDA will be in charge of proactive preventative measures. Part Five of this gigantic plan, Preventive Controls for Food for Animals, proposes to implement unified standards for manufacturing, processing, packaging, and safety analysis of commercial pet foods. Even if these regulations are completed soon, they will not have any impact on pet food safety until 2015 at the earliest.

This slow, piecemeal response typifies the glacial pace of bureaucracy, but in this case it’s only half the problem. Historically, the FDA has been internationally acknowledged as the lead regulator for food safety. Their ineffective response to the rapidly changing global food market mirrors the fiscal constraints that have drained their supervisory authority over domestic food safety regulation. Their ability to get up to speed looks increasingly doubtful considering the scope of legislation that is currently needed to strengthen production standards and address issues that now compromise safety in this increasingly complex global supply chain.

For lack of anything else, many manufacturers began conducting their own inspections or commissioning third party audits to ensure quality control. It was better than nothing, but these measures weren’t internationally recognized. More than a decade ago other groups began taking on the task of certifying commercial pet food safety, such as the Global Food Safety Initiative. Founded in 2000, this European non-profit organization has no statutory power over retailer or supplier policy or enforcement. Its only purpose is to develop precise, rigorous, model regulations to control food pathogens and unify food safety management for all aspects of international trade.

Auditors approved to do GFSI certifications regularly test products throughout every phase of production and distribution, which is basically what the new FDA program will do when it’s up and running. However, GFSI certification has already gained wide acceptance in the pet food market as a guarantee of food safety. Since 2007, that has included eight national retailers that distribute much of America’s pet foods. More likely, programs like this will be the future of pet food safety regulations.

Click here to read the complete article from the Canine Chronicle The Annual 2013-14 Issue, Vol. 39 Number 1.

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Posted by Alex on Jan 3 2014. Filed under Current Articles, Featured. You can follow any responses to this entry through the RSS 2.0. Both comments and pings are currently closed.