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FDA Answers on Raw Pet Food ‘Study’

Well, at least FDA provided some answers regarding a ‘study’ that just didn’t make sense.

When the FDA released “Get the Facts! Raw Pet Food Diets can be Dangerous to You and Your Pet”, much of the FDA ‘facts’ didn’t make sense.  Why would the FDA attack a particular pet food type (raw pet food)?  How could the FDA make the statement they found only one kibble pet food positive for Salmonella when during the time frame of their testing one of the largest pet food Salmonella recalls in history occurred?  If Salmonella was found in 15 raw pet foods and Listeria monocytogenes was found in 32 raw pet foods, where were the recalls?  This ‘study’ just didn’t make sense.  So, I sent them the following questions….

FDA just announced a study on raw pet food in which they stated they found “15” raw pet foods to be contaminated with Salmonella and “32” pet foods contaminated with Listeria monocytogenes.  Can FDA provide the links to the recall notices of each of these raw pet foods?  If there was no recall for these 47 contaminated pet foods, can FDA please provide a full explanation why these foods were not recalled?  The study doesn’t make sense if such dangerous contaminants were found and no recalls resulted.  Can someone explain?

And the FDA responded with the following…

Hi Susan,
To clarify, all except one of the findings for Salmonella or Listeria was in commercially available raw pet food. There were 38 out of 196 raw products that tested positive for Salmonella, Listeria, or both (9 were positive for both).
This was a surveillance study designed to evaluate the potential for contamination. It was not designed for compliance (enforcement).The purpose of including commercial raw diets in the study was to establish the potential for contamination of these commercially available products with Salmonella or Listeria as more traditional pet food products so that we could make the case for including them in future compliance sampling programs. commercially.
Because the purpose of the study was to establish the potential for contamination of these commercially available products with Salmonella or Listeria, the scientists were blinded to the product names. Therefore, we do not have a list of what products were tested, and no enforcement action was taken. In the interim, we thought it was important to warn pet owners more generally about our findings and the potential risks associated with commercially available raw diets.

So, the reason there was no recall for 38 raw pet foods that were contaminated with Salmonella or Listeria or both was this FDA study was strictly a “surveillance” project.  To “evaluate the potential for contamination”.  Their ‘study’ was not to take any action – even the scientists did not know the names of the pet foods they tested.

The following questions were sent as follow-up to FDA on November 14, 2013.  No response has been received as of this posting.

You stated that FDA “were blinded to the product names”.  I think I read on the FDA website that FDA purchased the products and sent samples to the participating labs.  Is that correct?  If so, was the raw pet food removed from its original packaging?  And then shipped to the participating labs? Were the products thawed (to remove from packaging so scientists would be blinded to product names) and then refrozen?  How did FDA protect the pet food identity from scientists while also preventing contamination from outside sources and during shipment?
Is this type of surveillance study common with FDA?  Can you provide examples of other surveillance studies – especially if there are others in animal food?
Can the FDA provide the numbers of how many pet foods – for compliance (enforcement), not for surveillance – have been tested for Salmonella or Listeria during a similar time frame as this study?  Including the compliance testing performed by participating labs?  Example of what I’m looking for is if 196 pet foods were tested for surveillance – how many pet foods in a similar time frame were tested for compliance?  Raw, kibble, fresh, semi-moist, can – what ever products were tested for compliance (enforcement) by FDA and FDA partner/participating labs for bacterial contamination.  Of those tested for bacteria, how many were positive?  And what types of foods (raw, kibble, fresh, semi-moist, can) were positive?

If the FDA has a limited budget…why go to the expense to surveillance test pet food?  Why not save precious testing funds and test all products for ‘compliance’ – which at the same time gets these products off store shelves?

If the FDA has a percentage of their budget they must spend on surveillance, then perhaps they can study the health conditions (number of visits to a veterinarian other than routine) of dogs and cats fed raw pet food, whole food cooked pet food, kibble pet food and can or semi-moist pet food.  This type of surveillance would benefit pet food consumers much, much more.

Raw pet food – regardless of any FDA study – is not going away.  Neither is lightly cooked, or whole food (no supplement) or home prepared.  These are not ‘trend’ pet foods.  They have dramatically grown in popularity for one reason – healthier pets.  I wish the FDA would step into the real future of pet food – do a little surveillance on why whole food pet foods, little to no supplement pet foods, lightly processed pet foods, and USDA inspected and approved ingredient pet foods are so popular (answer:  healthy pets).  Please FDA – support pet/animal health – not the profits of Big Pet Food.


Wishing you and your pet(s) the best,

Susan Thixton
Association for Truth in Pet Food
Pet Food Safety Advocate
Author Buyer Beware, Co-Author Dinner PAWsible

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November 25, 2013

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34 COMMENTS ON THIS POST To “FDA Answers on Raw Pet Food ‘Study’”

  1. Another great job Susan! Sure sounds like raw pet food is getting picked on. This “surveillance” study has so many holes in it. I am exhaustively annoyed that our tax dollars where spent is such a irresponsible manner which resulted in more fear based propaganda.

    • Jeri says:

      Yes, as a raw feeder I’m convinced there’s an agenda afoot which does not support healthy food! I know that Bravo was pressured into going the HPP route because the FDA kept “finding” minute — and it was minute — amounts of salmonella (far fewer than necessary to make an animal or person sick, as I recall) — and they could not afford to continue unless they sterilized everything. I definitely smell a rat because the majority of recalls for salmonella have been for kibble and we get….silence. Just like what the AVMA did in their resolution: ignore the elephant in the room (kibble recalls for foreign matter, salmonella and antibiotics) and decide that “raw food” is the problem. A pox on all of them! It won’t stop this pet family from feeding raw!

  2. Leona says:

    Thanks again, Susan, for looking out for our furbabies!!!

  3. BC says:

    Yes- can we say witch hunt with horrible study parameters??
    And excuse me- but in ALL blind studies, the manufacture of all products are revealed at the end. Blind/double blind/ etc. the product is revealed at the end. They do this when testing for dose strengths, and all kind of stuff.
    Yep I smell a rat.

  4. carole henry says:

    Yes indeed, a great job as usual. As I have been eating whole as much as possible and so have my dogs, I question the motive of the FDA in doing this so called study. Could they have had a little push from the dog food companies……..

  5. Pacific Sun says:

    As already questioned above, why spend money on a “study” when the money could be spent on compliance? And why not “study” particular brands? Isn’t that really the point of being TRULY useful to the consumer? To warn them in advance and to prevent illnesses (which they claim is thei responsibility, as in prevention)?
    For doing the study, which necessarily leads to an eventual future “finding” – could it be that the FDA was getting a major donation or the promise of an increased budget for 2014? Let’s say because the politicians (who control FDA finances) were being lobbied by kibble companies (major corporations?
    Let’s remember the heart of this matter is “raw” versus “cooked” period! So any raw protein (whether hamburger or chicken, etc.) may have, or already has, samonella or worse. That’s a given. Which all consumers understand, otherwise they wouldn’t be cooking human food. More to the point is HOW to study the animals being fed raw, the state of their health, and what effect (if any) that diet already has (not might have) on a household. Further, they could solicit the public for anecdotal examples good or bad. That would make for a long term study, but certainly an insightful one. Problem is, the FDA could never remain objective enough to scientifically back the truth, if raw feeding equalled or (more likely) exceeded commercial kibble!
    So let’s lobby for the truth!!

  6. Gitta says:

    Amazing. Just Amazing.
    Did the FDA hear the internet rumors about thousands of humans are falling victim to contaminated HUMAN foods? That everything from beef to spinach sickens and kills people every single year?

    Did the FDA hear the rumors that our factory farms, feedlots and slaughterhouses are the main causes?

    Did the FDA hear the extreme, routine overuse of antibiotics in factory farms?

    Where are the studies and warnings and recalls (ideally BEFORE an outbreak)?

    Maybe I’m way to cynical, but it does leave a very nasty aftertaste of acting in the interest of traditional pet food manufacturers who are probably feeling the pinch of petsumers not buying their products. If they don’t feel the pinch just yet, they know it’s coming.

    • Linda Messina says:

      I agree with Gitta 100%.

      • Hear, hear. I grew up in a farm-like environment in rural Spain. My grandparents raised chickens in the vast outdoors. They killed them, plucked them, cooked them and ate them. None of this was done in “sanitary” conditions, but the birds were free with lots of room, and eat worms, flies and other insects. No antibiotics were needed or administered. No hormones were injected to make them grow faster and larger. No one kicked them into the death chute. While our hands were washed after plucking them, I’m sure we scratched noses, removed hair from the front of our faces, tugged at our ears, etc. My grandparents lived to a ripe old age without a single incident of “stomach disturbance”, and I’m still here alive and kicking.

        It is the way we raise them and treat them.

        • Karen says:

          Just a reminder: Your grandparents grew up in a very different time before factory farming, mass food production and antibiotic resistance made deadly pathogens so widespread in animal production. Sure they didn’t keep 500 chickens, but they also didn’t order their chicks from a mass supplier. They also likely had healthy adult immune systems, which many people don’t. We can learn from the past but there’s no way to go back to it; we have to go forward.

  7. Debra says:

    The FDA seems to be using vagueness to instil fear in people. I’m still at a loss as how raw food is a threat to me if I follow common sense practices of washing my hands (duh!) They should be more focused on the pharmaceuticals that are causing thousands of deaths every year instead of concocting vague and suspicious “studies”.

  8. Bonnie says:

    You go girl!!!

  9. Shelley says:

    HUH? WOW! More of the same for the FDA…and I’m not surprised. Thanks Susan for all that you do to help us protect out furry families.

  10. teresa bragg says:

    we have been feeding our bulldog, Nigel, a raw meat diet that we make ourselves for 7 years, and other than having hip dysplasia, he is very healthy. we will never change that. we use human grade food and he loves it. Being a pharmacy technician, i know all about the FDA, mainly approving drugs without the proper testing. it’s your typical government agency. i wouldn’t trust anything that comes out of the FDA. my next question to them would be, “why haven’t you banned treats made in China?”

  11. Peter says:

    When I think of the agency that is responsible for administering the provisions of the Federal Food, Drug, and Cosmetic Act has developed “compliance policies” that effectively provide loopholes that enable agribusiness conglomerates to skirt that law… I do not believe that the impetus for “studying” the issue of “raw” pet food diets is accidental. FDA compliance policies make the FDA complicit in injury and death to thousands of dogs and cats; and there is terrible and perhaps even immeasurable human suffering of pet guardians that has also come from that. It is difficult to not be critical of the decision to “study” raw pet food diets… we knew that would just lead to condemnation.

  12. Lilly says:

    Awesome Susan!!! As always you leave no stone unturned. Thank you for your continued pressure on the FDA to provide the truth and justification for their actions. Yes, they are definitely fear mongering and picking on the raw food manufacturers. Could PFI be behind this whole “surveillance” study?…hmmm

  13. Can I also point out that they tested 76 more samples of raw dog food then dry dog food. That is 63% more tests run for raw then dry. That does not seem scientifically accurate. Being that there are more brands of dry dog food on the market then there are raw, why would you test more raw then dry?

  14. Is it perhaps because, by publishing this “study”, the FDA makes it that much more expensive for raw (real) or foods cooked with human-grade ingredients not sourced or processed in China to obtain insurance?
    I have recently started a new company (Beau’s To Go(R)) which sells slow cooked pet food made with human-grade organic and organic-like ingredients, frozen and delivered to people’s homes. As a start-up, it is a tremendous cash drain as everything has to be done a commercial kitchen with high hourly rates and ingredients that are sourced locally. However, by far, the biggest cash drain is the products liability insurance which has been quoted at a minimum of $5K/year. Part of the reason, is because of the recent recall of commercial pet food tainted with Salmonella. But, another and perhaps bigger reason, is because of the FDA’s (and other pet food industry representatives, as well as the vast majority of vets) insistence that raw food or cooked food is detrimental to a pet’s health (i.e., higher insurance claims) and has the added danger of contaminating people with Salmonella (i.e., an insurance with a much higher potential monetary value).

    If we can’t afford insurance, or if the cost of insurance is so high that our product is no longer affordable, the industry has effectively run us out of business.

    I’m not one to ascribe to conspiracy theories, but ???

  15. lynn says:

    I do not feed raw I home cook but a friend of mine uses orijin and swears by it.

  16. CSollersa says:

    Our dogs eat raw and will continue to do so regardless of what the FDA says. IMHO, their statements are paid for by big money anyway.

  17. Pattyvaughn says:

    Whenever a study is designed to prove something, it is biased and any information gained from it is unreliable. The FDA themselves said the purpose of their study was to prove that commercial raw foods are contaminated.

    I am perfectly capable, on my own, without the help of the goverment, to figure out that I need to treat any raw meat in my house like raw meat, regardless of who is eating it. Do they seriously think we are going to plop it down on the counter top and then plop it down on the floor and not take appropriate measures? If that’s the case, they better HPP every item in the grocery store, because we’re too stupid to have chicken for human consumption in the house. Good Grief!!

    • Jeri says:

      I completely agree with you. Furthermore, I’m not at all convinced — despite their protests to the contrary — that either the AVMA or the FDA TRULY are concerned about human exposure through raw food. It should be pretty clear to everyone over the age of 5 what this is about and who’s behind the push to find “commercial raw” food a problem….

  18. Susannah says:

    Hi, Susan,
    Thank you for writing this! I’m new to the raw diet trend and am currently in the research phase.

    You state “[raw food diets] have dramatically grown in popularity for one reason – healthier pets.” Is that from a different study? Any information in support of raw diets would be helpful provided the source is legitimate. Could you please point me in the right direction?

    Thanks again!

    • Susan Thixton says:

      No – I’m not quoting from any study. Though Answers Pet Food did perform a year long study you can find that here: My comment was from years of speaking directly to thousands of pet owners and veterinarians. Research is expensive – and many of the smaller pet food companies using whole foods – don’t have the money to perform research and feeding trials (they spend their money on ingredients). I’m sure Answers Pet Food would put you in touch with the veterinarian that performed their study – and Just Food for Dogs (though not a raw food) recently did a feeding trial for their lightly cooked foods – all of the study was on pets in their own homes too. I’m sure they would be willing to share info with you as well. And let me know if you have any other questions.

      • Susannah says:

        So helpful, Susan, thank you so much! I’m more focused on researching raw diets rather than lightly cooked foods, so I’ll follow up with the Answers link you provided. Much appreciated!

    • Jeri says:

      I would recommend a few sites: Dr. Karen Becker’s newsletters (free) are wonderful sources for information that has recently been published. You can also do a search for info. about diets there. Her “Healthy Food for Cats and Dogs” is our raw-feeding manual! The site is
      You also might be interested in a vet’s private “study” of feeding raw on her own dogs:

      Lastly, you might be interested in Dr. Jean Dodds’ info. on raw feeding (

      Susan is correct. NO big pet food industry commercial kibble will EVER sponsor a 6 month study (and certainly never longer!) which ran the risk of showing their product to be sub-par against a more species-appropriate diet which people could easily do themselves. (And keep in mind that consumers have been brainwashed into believing that those “studies” and “feed trials” somehow last the life of the animal and prove that the food is superior. They are only for 6 months and show no such thing, of course, since it would take at least a year on sub-par food for anything to show up in the blood work of an animal. It would be a rare animal who could not survive on a given food for 6 months! Our furbabies have learned how to compensate for the poor diets that most pet parents feed them, but thankfully many are now waking up to what is at stake and are getting informed!

  19. Jeri says:

    Oops! Saw that Susan quoted Dr. Amy’s study. Sorry for the “repeat”!

  20. Jeri says:

    Sorry, again. Yes, I’m familiar with both sites, but got the names mixed.

  21. Michelle says:

    Note that the raw foods used were purchased ONLINE!

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