Good and Ridiculous
The FDA announced they will have a zero tolerance policy with regard to Salmonella in pet foods. That’s the good. The ridiculous is at the same time FDA is enforcing zero tolerance for Salmonella, the agency continues to be completely tolerant of any waste material not fit for consumption into pet foods.
The FDA announcement was issued as ‘Guidance for FDA Staff‘, instructing inspectors in the field to take action if Salmonella is detected in any pet food. Shouldn’t there always have been a zero tolerance for such a dangerous bacteria in pet food?
“FDA maintains a zero-tolerance policy for Salmonella in pet food because it can pose risks to human health when people who are “at-risk” (children, the elderly, and individuals with compromised immune systems) come into direct contact with contaminated pet food.”
“The association between human outbreaks of salmonellosis and Salmonella-contaminated pet foods is well established. The Centers for Disease Control and Prevention reported that from January 1, 2006 to October 31, 2008, 79 human cases of salmonellosis were linked to Salmonella Schwarzengrund in dry dog food manufactured by a company in the United States. Health Canada reported that in 2005, cases of salmonellosis in Canada and the United States caused by Salmonella Thompson were linked to pet treats contaminated with Salmonella Thompson. In addition, Health Canada informed FDA of Canadian outbreaks of human salmonellosis that were linked to Salmonella Newport in beefsteak-patty dog treats that were manufactured in Texas in 2002 and to Salmonella Infantis in pig-ear dog treats that were manufactured in Canada in 1999.”
Lot’s of talk about humans getting sick, very little discussion of pets getting sick.
Now for the ridiculous. Let’s step away from the above zero-tolerance policy for Salmonella in pet food a moment and look at federal law.
Federal law defines “food” as: (Section 321. Definitions; generally) “(f) The term ‘‘food’’ means (1) articles used for food or drink for man or other animals,…”
No grey area – pet food would be included under the federal law definition of food.
Federal law defines an “adulterated food” (prohibited by law) as: (Section 342. Adulterated food) “A food shall be deemed to be adulterated- (a) Poisonous, insanitary, etc., ingredients (1) If it bears or contains any poisonous or deleterious substance which may render it injurious to health;…”
No grey area here either. Existing federal law would have deemed a food/pet food adulterated (prohibited) if it contained a poisonous or deleterious substance such as Salmonella. So again, why is FDA just now issuing guidance to staff to have a zero tolerance of Salmonella in pet food when it should have had a zero tolerance all along?
The only possible answer is because too many people were getting sick from handling pet food.
The FDA’s outlook on pet food has historically been ‘it doesn’t matter, it’s pet food’. To give you a clear example of this FDA belief system, we need to look at one more quote of federal law. Federal law also defines an “adulterated food” (prohibited) as: (Section 342. Adulterated food) “(C) (5) if it is, in whole or in part, the product of a diseased animal or of an animal which has died otherwise than by slaughter;”
But disregarding federal law and acting as ‘it doesn’t matter, it’s pet food’ – the FDA has (long ago established) Compliance Policies that instruct staff to ignore the above federal law. These compliance policies freely allow pet foods to contain the remains of diseased animals or an animals that have died other than by slaughter. Direct violation of federal food safety laws. (See CPG Sec. 675.400 Rendered Animal Feed Ingredients and CPG Sec. 690.300 Canned Pet Food)
To the FDA, it doesn’t matter – it’s pet food. Any waste material is welcome. Who cares if it isn’t proper nutrition and who cares if those pet foods and treats violate federal law…just make sure people don’t get sick.
It’s great FDA is taking a zero tolerance with Salmonella in pet food, but at the same time it’s ridiculous the FDA does not enforce many other federal laws with our pet foods. It DOES matter, it’s our pets.
Wishing you and your pet(s) the best,
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