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FDA provides Q&A update to Evanger’s Pet Food Investigation

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  1. Trish

    Sure hope know how to read between the lines. 😞

  2. Jeanette Owen

    I’m not trusting any pet food company, who knows where all their ingrediants come from – right down the line.

  3. Cannoliamo

    Thanks Susan.

    A little feedback …… the following 2 FDA responses seem relatively “lame” for a regulatory agency that doesn’t allow euthanized animals to be included in pet food. Why would FDA allow a food-processing facility to accept euthanized animals in the first place. I would prosecute / fine any food processor that had ANY euthanized animals on their property. I certainly don’t think requiring them to simply “turn up the heat” for euthanized animals and process them in the same facility as their pet food is a very safe or effective practice for preventing chemical poisoning of pets and obviously, in this case, was neither safe nor effective.

    I’m also somewhat concerned whenever a regulatory authority makes statements like “FDA’s understanding is that animal protein ingredient suppliers typically implement practices …..”. It makes me wonder if they understand their own rules and can administer appropriate enforcement actions. It sounds more like “WOW! I didn’t know you guys did that!”


    Q1: Is an on-site investigation of the meat supplier in progress?

    The FDA has concluded its inspection of the supplier and determined that they appear to have systems in place to ensure that euthanized animals are segregated from animal protein going for animal food use.

    Q2: Does the FDA allow the use of chemically euthanized animals in pet food? How common is this practice?

    No. It is not acceptable to use animals euthanized with a chemical substance in pet or other animal foods. FDA’s understanding is that animal protein ingredient suppliers typically implement practices at their facilities to ensure that euthanized animals are either not accepted at the facility, or are segregated from animal protein going for animal food use.

  4. Iva Kimmelman

    I have been reading about this, and the latest issue of PetFood Industry magazine and I feel ill.

  5. Debi

    Really, really interesting.

  6. Laurie Raymond

    It seems to me that the most effective preventive would be for manufacturers to purchase meat and poultry only from suppliers that ONLY run feedlots and slaughterhouses and do NOT collect already dead animals or process any carcasses by rendering. It is turning out to be difficult to find this out, as I am trying to do for the carefully selected brands I stock and recommend. I do know that one of the biggest problems has to be directly related to the meat packing industry consolidation which has taken place over the last 20 years. Only the very biggest players have been allowed to survive. I know that here in ranch country of western Colorado, it has been over 5 years since 2 very reputable ranchers, who invested in state of the art mobile slaughter facilities to avoid having to send their premium grass fed and organic cattle to the giants for processing, have had to wait for USDA approval. We have to realize that in industrial terms, and on industrial scale, the contamination we are so outraged about doesn’t matter at all. In the US it is illegal to slaughter horses, and horsemeat is suspected as having been the vector for this pentobarbital contamination. If the supplier is Canadian, it could handle horse meat, but the animal would have to be slaughtered, not euthanized. So if a euthanized horse was the source, it could have been an accident in a Canadian facility, but horses would only come to a US plant already dead. An error could not occur if meat packing plants were not legally allowed to receive dead animals, or to render them. Industrial meat has a lock on over 95% of the meat raised, slaughtered and butchered in this country, and they have no intention of surrendering any of this profitable supply chain to upstarts who care about farm animal welfare, healthy food, clean air and water, and a decent livelihood for farmers and small “artisanal” vendors trying to do things right. I care about food safety and animal welfare – both the pets my customers love, and the livestock we feed them – and I try every day to get people to upgrade out of awareness that Big Food has no other interest than its own profits. We really need to commit first to making our pets’ meals from whole food, and then we need to broaden our awareness and join the healthy food and regenerative agriculture movements, using the power of our purses and spreading information as widely as we can. I fear we cannot fix the small part of the Leviathan. It must be transformed root and branch. I suggest joining and supporting the Organic Consumers Association, as it has the most coherent and integrated approach to the whole system.

    1. Reader


      You’ve taken the time to write a thoughtful piece, which is appreciated. Because it shows you care. Furthermore, you understand a complicated business. And have access to information the average person doesn’t. As with any thought urging a reaction, I look for my “through point.” And really, most pet owners only want to feed a safe commercial PF. (Because there will come a day, when even a RAW PF company make a big mistake too).

      Being “organically aware” and responsible purchasers, is important for everyone, in a generalized sense. But I don’t get the connection, as related to the Evanger’s problem. “Sourcing” is one issue. (As in, where it comes from). And “handling” is one issue. (As to it’s processing). You’ve also suggested the Industry isn’t going to be changing. Which leaves the point being made …. even more confusing.

      I still don’t understand why “food” ingredients need to be “just good enough” for (or this much shy of not killing) pets. Which means it’s certainly not fit for humans. And (as Susan says so frequently) why should companion pets be a landfill waste solution anyway? Now there IS a big gap between food that’s “second quality” (not fit for retail sale) meaning ascetically unappealing. Which, if handled and stored properly, is meaningful PF material. And the opposite end of the spectrum, where expired meat is collected, and dumped, without proper storage, and never separated from packaging. So because expired meat does have potential ….then the “corrective action” would actually be to enforce appropriate safe handling regulations! If these retail merchants want their refuse taken away (or resold for profit) then it needs to be responsibly re-processed. Period!

      That’s NOT my responsibility. But it IS the PF manufacturer’s, to ensure correct supply chain handling, from point A to Z !!!

      I suggest “our” energy (and purchasing power) be pointed in that direction. Meaning, in order to support the manufacturers of commercial PF (like those products you want to vouch for in your store) they are going to have to back accountability up the tree! And only do business with their own responsible providers. Etc., etc.. The Evanger’s mistake was created exactly because they failed in that regard.

      1. Jeanette Owen

        Exactly – Evanger’s mistake……

    2. shepsperson

      It is my understanding that horse slaughter is not illegal in the US. However, horses here are not raised for the intention of eating. Therefore in their lifetime they are given meds for various reasons that clearly state on the labels “not for use in horses intended for consumption”. I don’t think there’s been any testing as to the withdrawal time of various drugs.
      The Evanger’s recall is not the result of horse meat anyway. It is beef. Beef is cattle. I don’t recall seeing it anywhere that horses have anything to do with the food.

      1. Christine

        That’s incorrect actually. They told us (retailers) that they suspected horse because horses are more often euthanized, cattle are generally not. They decided to test it in their independent lab results, and
        told us that contrary to the USDA’s findings the results came back positive for the presence of equine DNA as well as bovine (beef),

  7. Laura

    Notice that they don’t even answer all of their own questions, but dance around the topic, like when they point the finger at the pet food company and say,”It’s YOUR fault! WE shouldn’t have to do our JOBS that we’re paid by taxpayers to do!”

  8. B Dawson

    According to FDA, their testing showed less than 2% horse and pig DNA in the samples which is why their report said only bovine DNA was found. They indicated that this small amount is consistent with typical cross contamination in plants that process more than one species.

    My math is far too long unused to do conversions from ppb/Kg dry food to mcg and then account for wet food as opposed to dry. But could there logically be enough pentobarbital in less than a 2% contamination volume to have caused the death of a 20 pound dog? I’m thinking the amount in that can had to far exceed the 50 mcg fed in trials without adverse affect since it was fed only as a topper and split between multiple dogs. Each pug would have eaten less than 2 ounces as the owner still had some left in the open can to take along to the vet. We’re talking a couple of spoonful each.

    This just doesn’t add up for me. I’m eagerly awaiting the final FDA reports.

    1. GG

      Cut and pasted directly from necropsy:

      Both laryngeal saccules are everted. The trachea contains a moderate amount of light brown fluid throughout its
      entire length; this fluid is also present in the mainstem bronchi. The lungs are partially collapsed, mottled red to

      3. Lung – Alveoli are diffusely dilated with eosinophilic amorphous material with increased number of
      intra-alveolar macrophages (pulmonary edema). Several airways contain fragments of skeletal muscle and
      brown granules mixed with basophilic bacteria (stomach contents); there is no accompanying inflammation.

      If the pug didn’t die from aspiration pneumonia why are stomach contents found in the lungs and a moderate amount of brown fluid in the trachea?
      You choose to simply ignore the medical facts, because they don’t support your narrative. Presence of pentobabrbital is there, but not shown or proven beyond your narratives that it had anything to do with the death. If you two are so sure, post the e-vet reports, which both of you continue to fail to mention exists, that would have been written by a neutral party who actually saw, dealt with and treated all the dogs vs your own biased stories. Their treatment notes would make it clear exactly what the medical issue was. Don’t forget, there is arsenic in apple juice and in rice, people don’t die from drinking apple juice or from eating rice.

      1. Susan Thixton Author

        GG – I cannot even believe you can be so callous. So naive. So blind to symptoms of poisoning. It is beyond belief.

        1. Sharon Bilotta-Testa

          There’s ALWAYS a few that just don’t get it Don’t waste your time on them not worth it! Glad I switch to raw 2 months ago thanks to reading your awesome info I even stopped feeding feeding kibble which I left out 24/7 Keep up your informative information so many of us appreciated it Susan!!!!

      2. B Dawson

        Here’s a thought, GG…..nobody dies from AIDS. They die from complications brought on by the viral infection. Yet the medical community acknowledges without doubt that AIDS is the causative factor. The death certificate may say “complications from pneumonia” but it was the virally depleted immune system that allowed the pneumonia to kill.

        As to your laughable comment about naturally occurring trace toxins in food I will quote you Paracelsus: “Poison is in everything, and no thing is without poison. The dosage makes it either poison or remedy”.

        Before you claim other’s are ignoring facts, you should perhaps refresh your knowledge about biologic functions.

        Poisoned individuals often vomit. It is one of the most common symptoms as the body attempts to remove offending substances in an effort to preserve the organism. Further, as body functions begin to fail, sphincters lose their ability to contract, allowing fluids to move erratically. Add in a brachiocephalic breed and aspiration is almost unavoidable.

        There are more questions than answers about this case right now.

        Are we to believe that this supplier had a single contaminated carcass that went only to Evanger’s? Statistically, what are the chances of that? Inspection of the suppler suggests they have procedures in place to prevent euthanized animals from entering the pet food line. Yet the drug was undeniably found in Evanger’s food. Hmmmmm.

        FDA says that other potential complaints have been filed consistent with ingestion of pentobarbital yet no other company has been asked to recall food by FDA. Hmmmmm.

        Evanger’s repeatedly faults the quality of FDA’s inspection, offering ludicrous justifications. For instance, they flatly deny that there was any condensation in one sentence and then explain that condensation is to be expected due to their steam processing. It appears Evanger’s excels at double speak. Hmmmmm.

        This is a complex and confusing case which is far from being explained. It is established that there was pentobarbital in the food and the pug’s stomach. Testing of closed cans sampled at the Evanger’s plant contained pentobarbital. How it got there needs to be ascertained and those responsible taken to task. Even if no dog died, it is ILLEGAL for any amount to be in pet food.

        Have I missed the amount of pentobarbital found in both the owner supplied can and the ones tested by USDA labs? I have not seen numbers, only “large amounts” and “positive results” respectively. Having specific quantities would go a long way to answering some of the questions.

        1. GG

          Again from the necropsy:

          The stomach contains partially digested kibble along with chunks of carrots and meat mixed with black gritty particulate material. The duodenum contains a scant amount of gelatinous material that becomes mucoid distally. There is a small amount of formed feces in the descending colon.

          Were other “chemicals” tested for from the stomach contents? The stomach contained a lot of things. Might they have ingested something like xylitol? It would produce the exact symptoms described by the owner in the same exact time frame or possibly was something toxic consumed earlier. Reasonable doubt?

          1. Susan Thixton Author

            GG – reasonable doubt was out the window when the Evanger’s unopened can tested positive for pentobarbital. You are grasping at straws trying to protect a company that in no uncertain terms is guilty of putting an adulterated product into interstate commerce.

  9. Christine

    This is the most interesting part of the whole document, in my opinion: “Does the FDA allow the use of chemically euthanized animals in pet food? How common is this practice?

    No. It is not acceptable to use animals euthanized with a chemical substance in pet or other animal foods. FDA’s understanding is that animal protein ingredient suppliers typically implement practices at their facilities to ensure that euthanized animals are either not accepted at the facility, or are segregated from animal protein going for animal food use.

    The detection of pentobarbital in pet food renders the product adulterated. It is the responsibility of the manufacturer to take the appropriate steps to ensure that the food they produce is safe for consumption and properly labeled.
    Is there any acceptable level of pentobarbital in pet food? No. There is currently no set tolerance for pentobarbital in pet food and its detection renders the product adulterated.”

    These seem like strong words from the FDA, considering they said in 2002 that despite finding pentobarbital in almost 1/2 of the foods they tested, that “the results of the assessment led CVM to conclude that it is highly unlikely a dog consuming dry dog food will experience any adverse effects from exposures to the low levels of pentobarbital found in CVM’s dog food surveys.” and that it would not be actionable.

    The FDA using this stronger language this week makes me really interested in how it will be going forward. It seems like their language would predict stronger enforcement if pentobarbital is ever found in a pet pet food, (any enforcement at all would be stronger of course), but with the anti-regulation climate of the govt, and protection of giant corporations as a top priority, will this pan out? It is interesting right now that the public now knows more about this issue, and will hopefully demand accountability going forward. I was shocked to hear Evanger’s say repeatedly that they’ve never even heard of pentobarbital before, as did another can manufacturer I spoke to. (!) I train my employees about things like this in their first month of employment – it seems awfully incredible to me that this could be true (that you’ve never heard of this risk) if you work in the pet food industry in any way. I know I’m not the only retailer that is grilling my suppliers again (we grill them a lot, but in the light of this incident, it’s time again) and seeing if they have random testing for species used and presence of pentobarbital. I hope that most retailers are putting the pressure on their suppliers, as we dictate what we carry, so I would hope it would hold weight and let them know we’re watching. I hope that the future holds more independent testing by consumer advocates – I wonder would happen if we keep funding tests like the one TAPF did once before to test for it and other contaminants – if it were found, would FDA follow through with penalties? I wonder how the big giants in pet food that rely on ingredients like Meat and Bone meal, Animal Fat, (which the FDA says are the most likely ingredients to contain it) will go forward – will they test for it occasionally themselves now? If they find it will they recall? Will FDA require occasional testing? I believe that some new regulations are in place for safety standards (and that the biggest companies were supposed to comply in 2016?) though I don’t recall the details, or what the standards are. What would the pet food companies even do with all that waste they use? It could really be a turning point for food vs. feed issues, and Susan has always pressed them on it, to enforce their own rules. What will the next AAFCO meeting hold?? Very interesting indeed….

  10. Point Blank

    GG doesn’t care about Evangers anymore than the pet owner affected by the situation. He’s sending up trial balloons to test for the strength (or weaknesses) of a lawsuit. Meaning which side has the stronger claim so far. And who’s going to believe what. Absent of a Jury, only an accurate and direct correlation needs to be made to satisfy a Judge, in terms of answering whether or not Evanger’s food “directly” killed the dog. If not, then the official record can never read: “a can of Evangers pet food killed a dog.” That’s the shred of doubt the company is struggling to preserve. Because in the end people will only remember …. if yes, it did, ….. or no, it was never proven!

    Otherwise, here’s how this lawsuit is going to go:

    EVANGERS: Your Honor, we’ve been in business for 82 years. Except for the criminal activity we’ve been accused of by the authorities, our reputation is without blemish. The proof is that we’ve never produced any product bad enough to kill a dog. We (as in ownership) were literally out to lunch one day. And the Supplier’s Truck (who we’ve known for 40 years) dumps a load rendered cattle meat for processing. Of course we always test everything. We document those test results. Unfortunately the guy responsible for all the paperwork has been fired. His general work wasn’t up to quality. So he’s gone. And, as we’ve been in the process of auditing all his record keeping, many papers were missing. We are shocked and frustrated!

    SUPPLIER: Your Honor, we’ve been delivering the ingredient of beef to Evangers for 40 years. Been picking it up from the ABC Rendering Plant for over a decade. None of that material (to the best of our knowledge) has ever been bad enough to kill a pet. It would mean the end of our business if a mistake like that was made on our watch. So we’re careful to depend upon ethical rendering plants, like the “ABC Renderer” business.

    ABC RENDERING PLANT: We contract with Ranchers and facilities to process expired livestock. All the people we do business with “swear” their meat has expired naturally. While it’s not suitable for human consumption of course., it’s certainly “good enough” for pet food. And it’s never been reported back to us, that the material from our plant has actually killed a pet! I can give you the names of the Ranchers we do business with on a regular basis. And they’ll vouch for our understanding of these transactions.

    RANCHER #1 (of 9 more like them): Your Honor, me and my dad (being in the business for decades) have sent all our expired cattle to the ABC Rendering plant for as long as we can remember! None of our cattle has ever been euthanized. If we can’t get it to the stockyards, then it just dies right out there in the pasture. But if we DO have an animal on the property, requiring euthanasia, then our Large Animal Vet, Doc Patterson, is the best in the business. The man knows what he’s doing! And he hasn’t (to the best of our knowledge) ever injected the wrong animal on our property.

    DOC PATTERSON: Your Honor, that’s exactly correct. If I made a mistake like that (injecting the wrong animal), I could lose my license! So there’s a report for every case I handle. Cattle aren’t euthanized, because they just die of old age or because they’re sick. Or in rare cases they get stunned. It’s just too expensive to use this drug on livestock. Occasionally a horse will be “downed” if required. But there’s never been a problem disposing of a horse carcass versus cattle carcasses, geez, just for as long as I can remember.


    GG: Maybe the scenario above will expedite your thinking process.

  11. G Willie


    GG……….what are you wearing ?

    Anybody else picking up an odd scent in the ‘room’….?


    Geeeeeez………..could it be ‘Eau de Sher’ ?

  12. MaryTX

    Has anyone been able to confirm or debunk the list of all pet food brands manufactured at Evanger’s plants? I’ve seen reports of these in several forums: Addiction US, Au Jus, Canidae, Canine Caviar, Dave’s, Great Life, Holistic Select, Party Animal/Cocoliscious, Weruva Kobe, Wild Calling, Wysong…

    1. MaryTX

      And Bravo

      1. Christine

        Actually, Bravo cabs are manufactured at Precision

        1. Christine


    2. Christine

      Wild calling was just manufacturing two flavors at evangers, rabbit and Buffalo, which they switched to two different canneries, then recently discontinued the Buffalo.

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