If all the raw pet food recalls have you a little worried, when you learn of the action behind many of the recalls you’ll be even more worried. Fabricated lab results, intentional contamination, refusing to abide by law…and this is the regulatory authorities.
The following information is a combination of interviews (phone and email) with multiple regulatory authorities, multiple pet food manufacturers and multiple independent pet food stores. No brand names or specific states or individuals can be named for the protection of the companies and individuals involved.
FDA and State Department of Agriculture randomly tests pet foods for contaminants such as Salmonella. If it seems like raw pet food has been tested much more than other styles of pet foods – that assumption is 100% correct. Some State Department of Agriculture authorities have openly bragged they are only testing raw pet food for pathogenic bacteria. They have communicated a sense of pride of taking action against the ‘evil’ raw pet foods. (‘Evil’ is my word, not theirs – ‘evil’ was the sentiment they communicated numerous times.)
For any type of regulatory testing of pet food, law requires two significant things. One – every step of the process from collection of the sample to receipt at the laboratory is required to be documented. This is known as ‘chain of custody’. The regulatory authority is required to provide the pet food company with full disclosure to chain of custody documentation should an issue with testing be found. Chain of custody documentation with a raw pet food is significantly important as the product has to remain frozen for accurate results.
Two – the sample taken has to be large enough for the regulatory laboratory to perform their tests, and to provide the pet food company with a ‘split sample’. With raw pet food this means multiple packages of the same lot must be purchased (from a pet food store). Should a pet food test positive (as example) for Salmonella – the regulatory authority is required to provide the pet food company a split sample of the exact lot the agency tested. This split sample is required to be provided to allow the pet food manufacturer with a means to validate or refute the testing results of the regulatory agency.
Though procedure can slightly vary from state to state, standard procedure for when FDA or State Department of Agriculture laboratory testing finds (example) Salmonella in a pet food is…
- Notify the pet food company initial/basic testing was positive for Salmonella. This is known as a ‘presumptive positive’. Initial tests are followed by more detailed testing to confirm the species type of Salmonella and to provide the manufacturer with final positive results.
- Regulatory authorities provide the pet food company with chain of custody documentation and split sample for opportunity to validate or refute the results. The more timely a split sample is provided to the manufacturer, the more timely a recall can occur (if manufacturer testing confirms the result). No regulatory action other than notification to the company should be taken until the split sample is provided and confirmation testing is performed.
- If initial testing was performed by State Department of Agriculture, the FDA is notified of the presumptive positive. Typically FDA contacts the pet food company as follow up.
- Often upon notification of a presumptive positive, a manufacturing plant inspection might be initiated by either FDA or State Department of Agriculture. During inspection, multiple other testing samples can be obtained of pet food product, raw material, and swab sampling of equipment and manufacturing environment.
- If split sample testing is confirmed by the pet food manufacturer, steps to recall the pet food are coordinated between the regulatory agency and the pet food manufacturer. If the split sample testing is not confirmed by the manufacturer (results do not validate agency findings), a deliberation process begins between the agency and the manufacturer.
Again – standard procedure (procedure that other styles of pet food are held to) is that no regulatory action (such as a mandatory recall or stop sale order) is taken until the pet food manufacturer is provided with their right to view/confirm all steps of the testing process performed by regulatory authorities and confirm split sample results.
The system explained above might seem like a time consuming process – especially if you are a pet owner whose pet was sick or died and are desperate for accountability. But to make sure a pet food is properly held accountable for a bad batch OR to protect a company from regulatory bullying – all of the above steps need to be followed. Legally, every ‘i’ needs to be dotted, every ‘t’ crossed.
But this has not happened with raw pet food.
With MANY of the raw pet food recalls over the past several years, the above steps have not been followed. Not even close. With many – if not most – of the raw pet food recalls over the past several years…
- On multiple occasions, FDA has delayed providing the raw pet food manufacturer with their required split sample for weeks. During those weeks of delay, FDA is consistently pressuring the pet food manufacturer to initiate a recall. Many of the raw pet food manufacturers were NEVER provided their required split sample. They succumbed to regulatory pressure and recalled the pet food without opportunity to confirm or refute a ‘positive’ lab result.
- Same thing with State Department of Agriculture. Multiple State Department of Agriculture agencies have delayed and delayed providing the raw pet food manufacturer with their required split sample while continuing to pressure the pet food company to recall. Again, numerous raw pet food companies succumbed to the regulatory pressure and recalled the pet food without opportunity of split sample testing.
- FDA and multiple State Department of Agriculture agencies have delayed and delayed providing a raw pet food manufacturer with chain of custody documentation. In some cases, pressuring a manufacturer to recall with NEVER providing the required documentation. In some cases, when documentation was ultimately provided – the laboratory in receipt of the sample noted the raw pet food was received thawed.
- On multiple occasions, FDA and State Department of Agriculture have pressured a raw pet food company to recall based solely on initial basic testing (presumptive positive). Presumptive positive testing is not legal foundation for a recall, they can easily be a false positive (which is why follow up testing is always required). However, both FDA and numerous State Department of Agriculture agencies have pressured raw pet food companies into a recall based solely on presumptive positive results.
- Raw pet food samples are most often purchased from independent pet food stores. There are numerous instances of a State Department of Agriculture taking the pet food from a independent pet food store without paying for the product. When questioned about payment for the pet food, the regulatory authority told store owners ‘get payment from the pet food company’.
- On multiple occasions, a State Department of Agriculture representative entered an independent pet food store looking for a specific brand and lot number of raw pet food – stating to the pet store employee or store owner ‘this food is adulterated and will be recalled’. When questioned about the adulteration, the State Department of Agriculture representative admitted ‘they’ (the agency) had not tested the pet food yet – but insisted (prior to testing) the raw pet food was adulterated. (Personal opinion – this is evidence that outside parties such as Big Pet Feed is testing raw pet food and providing results directly to regulatory authorities. Perhaps even fabricating results.)
- And one store owner who questioned a State Department of Agriculture representative in their store – which was not well received by the regulatory authority – within weeks received an audit notice from the IRS. (Coincidence?)
- Though not as solid as evidenced above, there are also numerous reports of manufacturing facility cross contamination issues during a pet food inspection. Regulatory authorities entering protected areas of a plant refusing to wear protective clothing and cross contaminating the facility (prior to their swab sampling of the manufacturing environment).
With certainty, some of the raw pet food recalls we’ve seen over the past several years are legitimate recalls. But with equal certainty, some (if not most) of the raw pet food recalls we’ve seen over the past several years were NOT legitimate recalls. Some if not most of the raw pet food recalls were the result of regulatory bullying; regulatory working in partnership with Big Pet Feed to stop the growth of raw pet food industry.
If you are a raw pet food consumer, what can you do?
Ideally, we need raw pet food manufacturers to initiate a lawsuit against regulatory authorities for their violations in inspection/testing/recall procedures. But if you could stand in their shoes just for a moment, you’d see that is a very scary thing to consider. Regulatory authorities wield great power – and they throw that power around quite a bit. They have the ability to destroy a business in the blink of an eye. The same holds true for independent pet food stores. State regulatory authorities have the power to destroy a struggling independent pet food store in the next blink of an eye.
But…we consumers can take some action on behalf of raw pet food manufacturers and independent pet food stores by asking questions of our regulatory authorities – without fear of reprisal.
We can…
- Email or call your State Department of Agriculture (locate your representative here: https://www.aafco.org/Regulatory) and ask for the records of all testing done on pet food over the past two years for pathogenic bacteria. You’ll probably be shocked at what you receive; a significant majority will show testing was performed mainly on raw pet food. Share your state’s results online with other pet food consumers.
- If the testing documentation provided shows a clear bias against raw pet food, file a complaint against your State Department of Agriculture with your state’s attorney general.
One more thing…
This post is not intended to defend all or any raw pet food company in particular. If a pet food – any style of pet food – is contaminated with any toxic substance (toxic to the pet or human handling the product), regulatory action should be taken and the pet food should be promptly removed from the marketplace. And this post is not intended to condemn any particular regulatory authority. But what we are seeing – what we have certain evidence of – is a regulatory bias that is a collective effort to destroy the fastest growing segment of the pet food industry (raw pet food). What we are seeing is all other toxic pet food issues ignored (including direct violations of federal law) while the attack on one segment of pet food is pushed forward directly by regulatory authorities.
What all pet food consumers deserve is consistent, non-biased regulatory enforcement of all pet food. Law must be abided by – with all styles of pet food. Consumers can be the constant squeaky wheel to demand all law is enforced in all pet food.
Wishing you and your pet(s) the best,
Susan Thixton
Pet Food Safety Advocate
Author Buyer Beware, Co-Author Dinner PAWsible
TruthaboutPetFood.com
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Mrs. Elinor McCullough
May 3, 2018 at 4:35 pm
Is there absolutely nothing about all the Government alphabet agencies that is not totally corrupt? Thank you Susan for all the energy and time you so generously spend on the information you so expertly present.
Jeff White
May 3, 2018 at 4:44 pm
Hi Susan,
The “Deep State” also exists in the pet food system. From the major dry food manufacturers through the regulatory system, the system is designed to be undisturbed. In effect, no one can come between the profits and or careers of the participants. Common sense be damned.
As a former rep for a raw product, I can attest to the two sided regulatory system….one for dry….another for raw.
I would suggest that until the government is reigned back in and gets back to its responsibility of protecting the public….the public will have to use their own common sense in feeding their animals.
Unfortunately, pet food is not the only way in which the government fails in their responsibility…..human food is subject to the same types of conflict as pet food…..and with much higher dollars at stake.
In any event, keep up the good work.
J White
Audree Berg
May 3, 2018 at 5:09 pm
Thank you for articulating what many of us in the industry have been saying amongst ourselves. The public needs to be made aware that this is a deliberate effort to de-legitimize the raw industry
Hope
May 3, 2018 at 5:35 pm
First, I continue to think that you are amazing Susan! Your reporting on issues that need to be brought to the attention of the pet loving public is informative, insightful and risky making me realize that your priority of pet health is always foremost in guiding your work. Thank you from the bottom of my pet loving heart. Second, I’m growing my own awareness of the increasing volume of humans who think/realize that the FDA is usurping human rights and law compliance, not to mention progress, in all that they do in exchange for political power by a few, large corporate conglomerates. I just came from a stem cell presentation and one of the notes made by the presenter is how FDA is standing in the way to allow health insurance providers to cover this innovative, amazing work being brought to the whole public so that the pharmaceutical industry can figure out how they can profit from this non-drug, regenerative, very low risk therapy. If they can. I’ve fed raw to my dogs and cats for over 15 years. And I don’t need a paternalistic government agency making decisions for me when they are driven by big bucks and power and the abundance of arrogance that comes with all that you wrote about above. Thank you for keeping out pets foremost in your work. And please know that there is a growing revolution of which you are one of the leaders. Stay safe as you do your good work!
chuck linker
May 3, 2018 at 7:06 pm
No surprise about that.
Unfortunately the power of the commercial pet food industry continues to establish their
marketing ploys to naive consumers.
Pet Owner
May 3, 2018 at 11:52 pm
Another great great article and demonstrates Bad Actors run amok. Certainly for clarity sake, testing other food formats is critical. Especially Endotoxins in canned PF!! And, while they’re at it, making sure what’s on the label, is really inside the product!
That said, I do believe there is greater risk in feeding raw PF. I feed raw and recommend it to others. But people have to be smart about it. And since we can’t convince the average PF consumer of bad food to begin with, I don’t have faith in the average consumer feeding raw. And I don’t think the FDA or a Vet does either. I want that raw food tested and reported.
barbara m
May 4, 2018 at 3:27 am
Since you state in your second paragraph that “No brand names or specific states or individuals can be named for the protection of the companies and individuals involved.”, how am I to further research your claims of misdeeds by big government? If you have any documents, that would be helpful. If necessary, you can redact the names and states. From what I understand, the FDA is only targeting raw pet food brands that do not have a “kill step” and that are more likely to have infectious pathogens.
The meat and poultry destined for the human food chain is riddled with fecal matter and abscesses, etc. That said, you can imagine the quality of the meat that is destined for pet food.
Peter
May 7, 2018 at 6:53 am
PFI defines the “kill step” as “(a) cooking process to ensure the product reaches an appropriate temperature to fully eliminate bacteria and pathogens.” By that standard, it would not be “raw.”
Pet Owner
May 4, 2018 at 10:09 am
You are kidding right … that you need names … to further research claims of government misdeeds? Do you watch the news? Is there any doubt of government misdeeds? The point of the article is to say, nearly every notable brand of raw PF has been targeted with a recall. But not necessarily verified though the “Split Sample” agreement. My Pet Supply store carries about 10 brands, all sitting in a row of freezers. And each one (at one time or another) has been recalled. And I know that Northwest Naturals (which does use a kill step) among the others, was also targeted. The real point of the article is THIS. If the government can stand by it claims, then it should be more than willing to do so through a “clean” split sample procedure. Then they would be serving everyone’s best interest. But think about it …. do you think the government cares about YOUR best interests??
barbara m
May 7, 2018 at 12:44 pm
Well, actually Yes, Pet Owner, I am glad that the gov is looking after me, being elderly. I haven’t yet been thrown to the wolves. I feed my 6 cats raw, BTW.
As to the issue of “targeting” or “regulatory bias” of raw PF by FDA, an investigation usually begins when there is a serious consumer complaint. Case in point: a woman’s kitten died, she took it to her vet, who did testing and then she filed a complaint to FDA. They took her seriously, investigated and then tested the food that turned out to contain Salmonella. This company, Darwin’s, also had multiple complaints from other pet parents over a 2 year period, and many pets became ill. Still raw pet food enthusiasts will insist that the FDA investigation of Darwin’s failures is part of a malevolent scheme to throw all raw pet food manufacturers under the bus.
As to filing complaints – Many folks don’t go this extra step. It is so important for consumers with a sick or dead pet to file a complaint with the FDA, whether or not you believe the FDA is part of a giant conspiracy of some sort. If a pet food is dangerous, whether raw, kibble, or canned, it needs to be reported.
Northern Naturals, that you mentioned, was recalled by the FDA because it had the “potential to be contaminated with Listeria”. Listeria is serious stuff and nothing to ignore. Pathogens can be difficult, even with the most perfect system of processing and testing of samples. It can sneak in through cross-contamination.
As to : “Split samples / Chain of custody / Presumptive positives”… Again, it would be good to see some documentation. It would take a team of forensic experts to back up these claims.
Susan Thixton
May 7, 2018 at 1:19 pm
No Barbara – it doesn’t take “a team of forensic experts to back up” what was stated in this post. They are not “claims” – they are fact. Documentation can be obtained by filing Freedom of Information Act requests with multiple State Department of Agricultures and requesting the documentation of each recall. Specifically requesting the split sample documentation, chain of custody documentation and all test results and correspondence between the pet food company and the agency. If you bother to request (and in many cases pay the fee to obtain) the documents, and if the agencies will provide you with the documentation (they don’t always – especially if it means the agency will get caught) you’ll see there are gaping holes and certain regulatory bias. Not in all of the raw recalls – but certainly many. I’m very surprised you would even consider the thought that any information on this website is fabricated – which it appears you are saying about me.
Jeff W
May 7, 2018 at 1:37 pm
Barbara….I’m glad that the government is looking out for you….that leaves them less time to look out for me. The level of sheer malevolent behavior and incompetence from quite a few government employees is quite astounding. In accusing Susan of fabrication, you seem to overlook the facts that are stated in the article. She’s done the research and if you want to refute them it’s up to you to do the research required. The FDA, state Ag departments do not give up the evidence easily. And I believe that it’s a reasonable assumption that Susan does not have as much to lose as the players in pet food that she describes.
Also, I commend you on your choice to feed raw. I do believe that the answer for most raw feeders is to forgo as much manufactured food as is possible for ones own personal situation….the fewer hands that are put on your pets food, the better.
barbara m
May 7, 2018 at 7:00 pm
I wasn’t intending to accuse you, Susan, of fabrication. I just wanted to read the documents. It seems like you have already done all the hard work by digging them up. So thank you for this information.
Pet Owner
May 7, 2018 at 9:22 pm
In response to Barbara M:
COMMENT #1
It is difficult to figure out why these comments are being made. (1) Your original comment says, without the naming of brands and states how can claims of government misdeed be researched? (2) But the next statement says, if the documents are provided the names and states can be redacted. (3) The third statement is untrue, the FDA has tested many raw PF brands, regardless of their version of HPP (curing). Of course, a true “kill step” would be high heat processing, which doesn’t apply in this case, and doesn’t even work for canned PF, given that endotoxins survive. Once again, any product is only as good as it’s original sourcing and chain of custody. A failure at any point may or may not be intentional. And what’s the bell weather test for that? Does Evanger’s come to mind? An accurate, timely split sample is only good rationale, keeping in mind contamination can happen at any time.
COMMENT #2
The government is NOT looking out for you or anyone else (out of benign kindness). The government is in place to tread a thin line between individuals (who matter) making as much profit as possible, and avoiding outright killing people. Do not forget (as an example) the Burger King Beef E-coli incident, which actually did. But was settled out of court, the records sealed. (FOOD, INC.). Currently there’s a deadly problem with Romaine Lettuce, which the government is having a lot of trouble pinpointing. The CDC’s instruction is don’t eat ANY romaine (or mixed bagged) lettuce. And yet (today) there are SHEVLES and SHELVES FULL of Romain Lettuce at my local WinCo.
(4) So in reality it seems there’s an issue with Darwin’s in particular. The “Giant Conspiracy” (which I never read in print) although “bias” does apply, means that testing is not being done by established protocol. And, as you well know, salmonella is just a risk of raw PF. I also know a dog that became ($500 worth of hospital care), sick from raw PF. So the kitten and the dog (and perhaps too many others), just have a predisposition to succumbing to that pathogen. Sadly, anecdotal examples are not scientific proof of one PF’s trend towards carelessness, nor intentional neglect. If it were, given that an Evanger’s product actually killed a dog, then the “E” brand would (and should) be removed from the marketplace. But in fact only a few weeks after that tragedy, my Pet Supply store proudly displayed “Hunk of Beef” canned PF on their highest shelf. Because they KNOW they have a market for it.
How many (and which) companies are forced into documenting corrective & prevention procedures! And publishing it to the public?? And yet, a company (like that) only real incentive for correcting business practices is knowing that the public won’t forgive “three strikes and the they’re out.” So let’s discuss the nature of “bias” one more time. How many brands of non-raw PF are in the marketplace creating havoc with your pet’s health? And HOW MANY workarounds do you have to put inti place (considering convenience and economy) to protect your pet from an ENTIRE INDUSTRY? It’s just sad. Susan is hardly making any claim, that doesn’t further justify our legitimate suspicion of big business, at the expense of innocent, living creatures. Should 20 raw food companies be scrutinized into the ground, or a thousand brands of non-raw PF be PROACTIVELY EXAMINED (with the results AND corrective measures documented and published to the public?). The answer is both, if we want all our pets safeguarded.
(5) It’s Northwest Naturals that had the “potential” for Listeria, and am well aware of the consequences. There was a serious Listeria infected Cantaloupe recall a few years back. The issue isn’t so much of what’s happening, but HOW things are handled when it does. That’s where the FDA can do a lot more (not less). Timely testing, immediate feedback, mandatory notifications, store recalls, consumer communication, and stores required to post (yes, human food) recall notices (just like they do for baby goods.). Ever see all that stuff at Walmart?
(6) The information revealing a lack of integrity regarding “Split samples / Chain of custody / Presumptive positives” exists. Imagine any website author tackling a subject without the resources to backup claims? (7) Another sentence says, but it “would take a team of forensic experts to back up these claims.” If so, then what’s the purpose of “further” documentation, or any for that matter, making it sound like a litigation matter instead.
I didn’t perceive it at first, but yes, there an onus being put on Susan for suggesting these are unreasonable claims, without support. And additionally, leveraging that kind of an accusation, in order to force the issue of supplying) documentation (most likely, as a convenience). Truly, it is an unworthy provocation, considering Susan has put a DECADE of effort and learning, into dissecting the difference between criminally worthy behavior of the PFI, and which PF companies are trying … in earnest … to provide alternatives. If Darwin’s has a legitimate problem, then it should be explained, and they ought to be supported in their effort to rectify. Just as Evanger’s (and count them on your fingers) number of other BIG, big PF brand name companies have been allowed to survive in spite of their own recalls and scandals. Clearly government is treating the Darwin situation, as a method to discourage raw PF consumers … rather than spending a whole lot of their own resources …. to actually protect and educate them.
The government does NOT have your best interests in mind, not in the least. What people are learning in the News is only the tip of the iceberg, because we’re only focused on the PFI.
Erica
July 3, 2018 at 7:37 pm
Forgive my ignorance , but why is government so keen on protecting Big Pet food but so relentless on raw pet food manufacturers?? How do they benefit from it?
Mrs. Elinor McCullough
July 4, 2018 at 7:01 am
Since Big Pet Food (4-D dog food) is a multi billion $ industry I am sure there are a lot of “graft” payments at all levels of the political (“industry”) to so-called “look the other way” and eliminate the competition by any means necessary which would include contaminating the opposition’s food manufacturing process or the food itself before it is processed into high value food for your pets. I absolutely and completely eliminated all processed food (which includes the 4-D dog food in bags) from my own diet as well as my (now 2-1/2 yr old) puppies diets. We are all the better for my choice(s) and as well avoid Veterinarians at all costs and the puppies are doing fine. After loosing 8 dogs to Vet over-vaccination (I did not know at that time how dangerous that was) and the 4D dog food I got on the internet and learned from Dr. Wil Falconer (Vital Animals blog) what I should have been doing and what I now do. Thanks to God for the internet or I’d have never learned what I was doing to my dogs (and myself as well). I feed the two puppies raw and they thrive with boundless energy and vitality. 4-D dog food stands for: Dead, Diseased, Dying, Disabled and you could also add euthanized. It’s really time for everyone to learn just how much corruption exists in Government at all levels and in the food manufacturing industry.