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Some Answers to two Pentobarbital Recalls

Two pet food recalls, same manufacturer, one manufactured in December 2015 – the other manufactured in June 2016, both recalled due to contamination of a lethal drug. There have been many misleading things said about these recalls. Let’s get some facts straight…

Two pet food recalls, same manufacturer, one manufactured in December 2015 – the other manufactured in June 2016, both recalled due to contamination of a lethal drug. There have been many misleading things said about these recalls. Let’s get some facts straight…

This recall was voluntary, right?

Yes, most pet food companies willingly recall a pet food when they learn the food is the cause of pet illness or death. But…the voluntary part is a little misleading.

In most cases for a pet food manufacturer to ‘voluntarily’ recall a pet food, the company has been provided with evidence their food is at fault – such as test results (examples: lab results the food is vitamin/mineral deficient/excess or lab results the food is contaminated with risky bacteria or drug). In most cases the evidence test results are provided to the company by a regulatory authority (FDA and/or State Department of Agriculture). The testing of the pet food could be from random testing by regulatory or it could be part of an investigation that was initiated by a consumer or veterinarian complaint. The pet food company is presented with the evidence and asked by FDA to voluntarily recall.

If a company doesn’t volunteer to recall their pet food, the outcome could be worse than a recall. Here are a couple of examples of what regulatory authorities have done when a company does not volunteer to recall…

In 2012 when Nature’s Deli Jerky treats refused to recall one batch of treats (other batches were recalled), FDA issued a press release stating Do Not Feed Nature’s Deli Dog Jerky Treats. In other words, the FDA forced the issue with a very public warning against the company. And notice the FDA didn’t warn about just the one un-recalled treat – their warning was against the entire company. If a company doesn’t volunteer, they are at risk of FDA wrath.

In 2008 the FDA inspected a Petco warehouse finding it infested with rodents and birds. Petco was asked to ‘voluntarily’ clean up the facility. A month later FDA returned finding the facility had not been properly cleaned. Next, the FDA obtained a warrant and sent in US Marshalls to seize all of the products in the warehouse. Again, FDA forced the issue when the company did not do as FDA requested.

So yes, recalls are stated as voluntary – but in most cases pet food companies are voluntarily recalling because the alternative is a worse outcome.

How do I know if my pet food was made at Evangers?

Evangers Pet Food co-packs (manufactures) for many private label brands. Consumers are fortunate in this instance that Evangers has a very unique lot code/date stamp; the information is printed on the can curved (instead of a straight line). Below is a picture of the curved stamp unique to Evangers manufactured pet food.

Evangers/Against the Grain meats are human grade, is the human food chain is at risk too?

First – because the Evangers/Against the Grain manufacturing facility is a pet food facility and not a human food facility, regulation does not allow the company to state ‘human grade’ on the label or the website (a company website is considered an extension of the label).

Regardless to regulation, the Evangers website states “Evanger’s utilizes human-grade USDA inspected meats” and the recall notice (first recall) stated “All Evanger’s suppliers of meat products are USDA approved. This beef supplier provides us with beef chunks from cows that are slaughtered in a USDA facility.” (The second recall – Against the Grain – did not make this claim.)

What some pet food companies do is source meat ‘from’ a USDA facility, but the meat was not processed under USDA inspection. Often these pet food companies tell unknowing consumers – ‘yes, our meat comes from USDA inspected facilities’. But…unless an animal is slaughtered and processed under constant USDA inspection, it is not deemed human edible/human grade. Meat coming from a USDA facility does not guarantee the consumer the meat is human grade. Some meat for pet food is processed after hours – after the USDA inspector has left the building. This meat comes from a USDA inspected facility, but the meat itself is not USDA inspected and approved. The meat processed after the USDA inspector left the facility could be sourced from healthy slaughtered animals or it could be sourced from animals that were rejected for use in human food. Only meat that is certified USDA inspected and approved is human grade/human edible.

Actually Evangers and Against the Grain could put consumers mind at ease themselves. The pet food company could post on their website copies of the bill of ladings or invoices to the meats they purchased – providing the proof that USDA inspected and approved meats were purchased. Until the public receives this proof, we speculate.

With certainty, if meat is/was sold labeled as USDA inspected and approved for human consumption that had not passed inspection, it would be recalled. As example – in 2014 nearly 9 million pounds of beef was recalled due to lack of full USDA inspection. Numerous similar recalls of human grade meats have occurred over the years. In other words, it is unlikely that a pentobarbital euthanized animal would ever enter the human food stream. If it did, for certain there would be a full USDA investigation and more than likely a USDA inspector would face criminal charges for allowing illegal product (and a very dangerous illegal product) into the market.

Does the FDA have sufficient regulation in place over euthanized animals in pet food?

Federal law – the Federal Food Drug and Cosmetic Act – states a food is adulterated (illegal) if (in part) “(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;” A euthanized animal IS an animal that has died otherwise than by slaughter – a euthanized animal in a pet food would make the pet food adulterated/illegal.

Federal law defines a food as: “(f) The term “food” means (1) articles used for food or drink for man or other animals, (2) chewing gum, and (3) articles used for components of any such article.” Pet food falls under the legal definition of food.

Yes, a pentobarbital laced meat in human or animal food – even the tiniest portion – is a direct and clear violation of federal law.

Even though federal law says no, FDA tells pet food manufacturers yes…FDA through use of Compliance Policies tells pet food manufacturers (specific to canned pet food) “Pet food consisting of material from diseased animals or animals which have died otherwise than by slaughter, which is in violation of 402(a)(5) will not ordinarily be actionable, if it is not otherwise in violation of the law. It will be considered fit for animal consumption.”

While we (consumers) challenge the legality of FDA Compliance Policies (click here and here to learn more of our fight with FDA), the FDA policy specific to canned pet food includes a very significant statement (bold added): “CVM will also consider regulatory action against canned pet food on the basis of use of decomposed animal tissues or use of tissues containing violative drug residues.” Pentobarbital is certainly a ‘violative drug residue’. FDA (illegally) allows pet food to source meat from animals that have died otherwise than by slaughter, but the agency does not allow ‘violative drug’ contaminated meat in pet food.

But FDA allows/allowed pentobarbital contaminated rendered meats, why are these canned pet food containing pentobarbital being recalled?

In 2002 the FDA published a stunning admission – dry dog foods do contain pentobarbital, do contain euthanized animals. The FDA report – Risk of Pentobarbital in Dry Dog Food – provided the following test results (dry dog food only): 44 of 90 dog foods tested positive for pentobarbital.

Almost 50% of the dog foods tested contained pentobarbital…
50% of the dog foods tested contained an illegal euthanized animal.

Almost as shocking as the results, the FDA decided that the levels of pentobarbital in the dry dog foods was not dangerous for pets to consume. “For the purposes of CVM’s assessment the scientists assumed that at most, dogs would be exposed to no more than 4 micrograms/kilogram body weight/day based on the highest level of pentobarbital found in the survey of dog foods. In reality, dogs are not likely to consume that much. Thus, 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.”

As hard as it is to understand how the FDA Center for Veterinary Medicine (CVM) could tell consumers that their pet would not experience any ill effects from consuming a pet food sourced from euthanized animals…for the answer to why was the Evangers and Against the Grain canned pet foods recalled we have to look beyond this FDA absurdity. The answer – we can very safely assume – is the level of pentobarbital found in the canned pet food. The level of pentobarbital found in FDA testing of dry pet food was “low levels”, CVM felt there was no risk – there was no recall of these 44 dog foods. We can only assume that the level of pentobarbital in the canned Evangers and Against the Grain dog foods was higher. We will will have to wait for FDA to confirm this assumption.

Is this a meat supplier issue or a manufacturer issue?

It could be that the meat supplier provided Evangers with multiple shipments (one in 2015 and one in 2016) of pentobarbital contaminated meat from a euthanized animal – without Evangers knowledge. But…ultimate responsibility of a safe pet food lies with the manufacturer. A pet food manufacturer MUST dot every ‘i’ and cross every ‘t’ – with every single batch of pet food. They must know their suppliers intimately and they must check, double check and triple check the safety of their ingredients.

Evangers has claimed in a video statement to the publicwe didn’t even know about pentobarbital until this past Sunday” (video published 2/7/17). If this statement is true, it shows this pet food company was not aware of a very well known risk; euthanized animal meat is very common to pet food (per FDA testing). If true, it also shows this pet food company trusted their meat supplier way too much – it shows they did not check, double check and triple check the safety and quality of their ingredients.

If the supplier misled Evangers – and this could be the case – the pet food company was still responsible for the quality/integrity of the meats purchased. Consumers need all pet food manufacturers to be diligent in sourcing safe, quality ingredients.

 

I’m sure I’m joined by many consumers starting to become impatient waiting for news from FDA on this issue. While we certainly want the FDA to perform a thorough investigation, we deserve some answers…and soon.

We also deserve some answers to our Citizen Petition sent to FDA on October 27, 2016 asking the agency to finally and completely put an end to diseased and non-slaughtered animals being processed into pet food/animal feed.

The FDA Compliance Policy on canned pet food states “the Center for Veterinary Medicine (CVM) is aware of no instances of disease or other hazard occurring from canned packing house offal or the tissues of animals that may have died otherwise than by slaughter.” Well FDA…you can’t make that claim anymore. Now you are aware of an instance of disease and serious hazard (the death of a little dog named Talula) from canned tissues of animals that died otherwise than by slaughter. FDA – end these ridiculous Compliance Policies and enforce the law. No pet…no animal…should be consuming the carcass of a euthanized animal.

 

Wishing you and your pet(s) the best,

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

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31 Comments

31 Comments

  1. Reader

    February 16, 2017 at 3:43 pm

    No where else will you find such a thorough explanation on the status of this investigation. It takes Susan a countless number of hours (days) to research and present these messages!

    Thank you, Susan so much for your incredibly hard work!

    • Jeri

      February 16, 2017 at 4:28 pm

      I was about to post the same thing. Thank you, Susan! Your VERY thorough explanations leave nothing to be desired. Evanger’s may not have crossed all their “T”s or dotted all their “I”s, but you sure did! We are blessed to have you working on our behalf.

    • jodi cohen

      February 16, 2017 at 4:36 pm

      Couldn’t agree more – thank you for all your work, Susan!!

  2. Bethany

    February 16, 2017 at 4:14 pm

    Yes, thank you Susan for all your work and dedication! You are an invaluable resource for both consumers and their companion animals.

    It seems like other pet food manufacturers can have similarly tainted beef in their pet food and not know it. I reached out to Pure Bites regarding their beef treats but got the usual song and dance from a sales and marketing representative. I want an answer from those in the know. This is so worrisome since it is not being addressed at the source and can easily happen again.

    • Sara

      February 16, 2017 at 4:54 pm

      Hi Bethany.

      I feed Pure Bites treats and am not worried after reading your comment. Is there a recall or known health issue?

      Thanks in advance.

  3. Marley Rowelyn

    February 16, 2017 at 4:24 pm

    This information needs to be widely circulated among the pet-parent community.

  4. Boyhous

    February 16, 2017 at 5:03 pm

    Agree. THANK YOU Susan for all that you do!

  5. MrsK

    February 16, 2017 at 5:10 pm

    Yes thank you for posting that. I will be following this to see if the “interesting” people post like they did the last time. Keep up the good work you are doing.

  6. Susan DeLeon

    February 16, 2017 at 5:58 pm

    Not all Evangers have the curved line. Our store still has evangers in 6 oz cans of several flavors (supplemental feeding) and they all have a straight line on the bottom of the cans.

    • Woofielover

      February 17, 2017 at 1:19 am

      That’s because they stamp their large cans in a roller. Smaller volume cans are produced differently. Usually, it’s safest to look at what they produce in large cans and automatically stay away from their smaller cans too.

      • Peter

        June 26, 2017 at 7:12 am

        5.5 oz cans of certain Wild Calling brand cat foods have the curved date stamp. I have cans bearing a Sept. 2019 BBD, so they are very recently produced.

        • Woofielover

          June 26, 2017 at 10:56 am

          Good to know, I’ve not seen the circular stamp on small cans before. If they were one of the 3 “exotics”, WC was still having those made at Evanger’s until Feb. Most cans have a 2 year best by/expiry date.

          • Peter

            June 27, 2017 at 8:09 am

            On the WC website, the company trumpets that they are a “Wildly Different!” company, but they aren’t, they just use co-packers like every other pet food business. We really can’t even use the word “manufacturer” any longer because it has lost its meaning. WC claims that “we took our time with the formulations to make sure we got it right. After all, we’re not just tossing out some product to make money” and “…plain and simple. We do what we want, the way we want…” But as a consumer, I’d suggest that simply contracting out to a business like the Sher’s is enough to convince me to avoid their products entirely. Their decision has led me directly to lose faith in WC, just as any other brands that would do business with Evanger’s. It just demonstrates a lack of oversight that is not excusable on any level.

          • Woofielover

            June 27, 2017 at 10:56 am

            Peter, the reality is that almost no pet food company owns their own cannery. its ridiculously expensive so usually it’s only Big Pet Food that owns their own. A couple years ago, Fromm bought a local green bean cannery to convert to be able to control the production of their own cans. It’s pretty standard in the industry and the human food industry as well. Lots of Big Label canneries do copacking for other smaller companies in human food as well.

  7. T Allen

    February 16, 2017 at 7:32 pm

    “Some meat for pet food is processed after hours – after the USDA inspector has left the building. This meat comes from a USDA inspected facility, but the meat itself is not USDA inspected and approved. The meat processed after the USDA inspector left the facility could be sourced from healthy slaughtered animals or it could be sourced from animals that were rejected for use in human food.” That is absolutely what happens (although it’s unlikely healthy animals are slaughtered for pet food) and the only thing missing is that rejected products from the USDA inspection process, meaning diseased, contaminated animals and parts, will be utilized by the after hours operations for pet food.

    • Reader

      February 16, 2017 at 10:48 pm

      Well I think you meant to say …. “and the only thing missing (in terms of prevention) is that rejected products from the USDA inspection process, meaning diseased, contaminated animals and parts WON’T be utilized by the after hours operations for pet food.” Meaning there is nothing to prevent the use of that rejected material for the purpose of PF.

      For long time Followers of TAPF (and the PF issue) this is probably the most profound statement to be made in a very long time! I suggest everyone read it again. How else does sub-standard protein get into PF, to create, as Anthony Hepton has studied …endotoxins in canned PF?

  8. Naomi

    February 16, 2017 at 8:04 pm

    “Well FDA…you can’t make that claim anymore. Now you are aware of an instance of disease and serious hazard (the death of a little dog named Talula) from canned tissues of animals that died otherwise than by slaughter.” Sorry no proof has been provided to support that Talula died ” from canned tissues of animals that died otherwise than by slaughter”, rather it has been reported it died from aspiration pneumonia, with no relationship to the food specifically. The stomach also contained kibble and carrots, which are not found in the canned product. Until the owner releases the medical treatment reports, you have provided no definitive proof as to the cause of death.

    • Susan Thixton

      February 16, 2017 at 8:10 pm

      I simply do not understand how anyone could be so naive. Your allegiance to a pet food company that testing has confirmed the presence of pentobarbital in is astounding. The FDA has the definitive proof. There would not have been a recall (two recalls) without it.

    • Mollie Morrissette | Poisoned Pets

      February 16, 2017 at 10:24 pm

      Wow. That is truly stunning that you believe that Naomi. The toxicology report stated clearly that sodium pentobarbital was found in significant amounts in the stomach contents of Tulula and in the Hunk of Beef canned dog food Ms. Mael’s dogs ate. Should you wish, I suggest you read the toxicology report in its entirety at http://www.poisonedpets.com/euthanasia-drug-found-evangers-dog-food-causing-illness-death-dogs/.

    • Reader

      February 16, 2017 at 10:35 pm

      Wait a minute. You’re criticizing an article said to be without merit, yet without submitting facts to the contrary. Before going forward, obtain the official medical report of what led to the dog’s cause of death. Plus reports on the other 3 dogs that didn’t die.

      What’s side tracking your thinking, are social media comments, but with no basis. The suggestion is that “other” food in the dog’s stomach might’ve been responsible. Even if that is the assumption, why would it be any less significant? Meaning the entire point is being missed. Surely if Evanger’s required the same kind of assurance for itself (to disprove responsibility) they would’ve accessed the complete analysis from official sources. [ Think about it ].

      By the way, Susan isn’t responsible for providing “you” or anyone else “proof” of anything. That the Company’s job. That’s the FDA’s job. Which I suggest you contact directly. The same agency Susan consults before writing her articles. [ This is far from her first Rodeo! ]

      The statement you quote is a true one. Certainly a “hazard” at the very least, but food making 4 dogs sick. It is a statement to which the FDA is ….and has been …. due to Compliance policies… already well aware of, regarding PF containing protein obtained other than by slaughter. The latest case is simply an instance of that, which has now become publicized. Through a series of proper steps all taken. It’s turned into a revelation, new better positioned, to make the original point in the first place.

      With a total lack of sympathy for the dog’s family, I suggest spending as much time as has been spent on social media, obtaining all the facts required (in your mind) from objective third party and relevant sources. THAT would be energy well spent. Instead of feeding off of useless rumors.

    • Woofielover

      February 17, 2017 at 1:36 am

      Why would ANY pet parent defend or subscribe such staunch allegiance to any manufacturer? Your allegiance should be to your animal. Period. Why risk it? Why take a chance or give the benefit of the doubt? One only need look at the vast history of issues, lies, guilt and wrong-doing that has been repeatedly practiced by this manufacturer and which has been documented and is public information. Regardless, even if you loved the food, the company or were related to the owners, the information provided should give you pause to reconsider that allegiance, especially if you’re a pet parent. The proof falls upon them to prove it ISN’T true.

      • Woofielover

        February 17, 2017 at 1:37 am

        This is reminiscent of Blue Buffalo’s problems when they got caught lying about their ingredients. They too tried to blame it on their supplier. Turns out it cost them $33million to settle with the consumers to whom they lied. Will it change anything? Yeah, sure. Blue Buffalo is building their own plant so they can keep their sources private and under their control. Maybe they need to look at Evanger’s. Both manufacturers have blamed their suppliers. Both manufacturers are at fault, no matter what. Their brand, their responsibility.

        • Peter

          February 23, 2017 at 1:51 pm

          Sadly, those types of “settlements” provide little to no relief to affected consumers, and really are just an ordinary cost of business for pet food manufacturers.

      • Jeri

        February 17, 2017 at 1:20 pm

        Very well stated. Today’s statement from the FDA confirms that 1) pentobarbital was found in UNOPENED cans 2) the beef was NOT USDA inspected (so much for “human grade” claims) 3) They have concerns which they did not specify in BOTH the Wheeling and Markham facilities. Evanger’s OWNS this. http://www.fda.gov/AnimalVeterinary/NewsEvents/CVMUpdates/ucm542265.htm

  9. JRM

    February 16, 2017 at 8:15 pm

    “Almost 50% of dry dog food tested positive for pentobarbital “. This is astounding. A dog eating this bag of dog food day after day ingesting this drug day after day is deemed to be OK? If this one thing isn’t enough reason to stop feeding this stuff I don’t know what it will take.

  10. mickey

    February 18, 2017 at 10:54 am

    How can I find out what brand of dry dog food contains pentobarbital.

    • Pet Owner

      February 18, 2017 at 2:57 pm

      The point of the report was to indicate a “minimum” threshold of pentobarbital is present in kibble, as of the report. There is no “list” of PF free of it. But the better protection is to confirm ALL the protein used is only USDA Inspected and Approved (passed) for human consumption. PF fit for human consumption (via ingredients and processing facility) is a good indication. Make sure, even when speaking to these companies by phone, that they follow up their “statement of assurance” in WRITING. If there comes a time, they can be caught lying, just as Evanger’s was.

  11. seeingeye2

    February 18, 2017 at 3:36 pm

    What about all the other products of Evangers? Are they being recalled too?

  12. Sara

    February 20, 2017 at 7:46 pm

    FYI…. From petful.com email

    “Exclusive: Another recall coming soon, pet food company says

    Petful
    to me
    1 hour agoDetails
    Important news from Petful (formerly Pets Adviser)
    View this email in your browser

    Another pet food recall is imminent.
    Because you signed up for recall alerts from Petful (formerly Pets Adviser), we wanted to tell you right away about a new pet food recall.

    Petful has learned that any Evanger’s pet food made with “chunk beef” will be recalled soon over concerns about potential pentobarbital. This is an extension of the previous recall announced earlier this month.

    Click over to our site to read the full details now:

    http://www.petful.com/food/evangers-another-recall/

    Also, in case you missed it, we published a story earlier today that discusses this pet food maker’s troubled history leading up to the shocking recall. Those troubles go back more than a decade. Pentobarbital, as you have probably heard by now, is a drug used for euthanasia — and it has no reason being in pet food.

    If you didn’t read our article earlier today, do yourself a favor and read it now. Prepare to be completely grossed out.

    http://www.petful.com/food/evangers-citations/

    Please share! Thank you.

    — From your friends at Petful”

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