How Much More Serious Does It Have To Get?

At least four and a half months have passed since serious pet illness and death reports began – believed to be linked to multiple pet food brands. The FDA has said nothing to pet owners, refusing to even provide Freedom of Information Act requests (for more information). No public warning, no update, nothing.

Multiple requests by advocates and consumers have been sent to FDA Center for Veterinary Medicine (CVM) asking the agency to update the pet owning public. All requests have fallen on deaf ears.

Left with no other option, we have filed a Citizen Petition requesting the FDA CVM to properly and promptly update the public.

A Citizen Petition is a legal process for individuals or industry to request the FDA to take action, refrain from taking action, and/or request the agency to make changes to policy. Citizen Petitions are required to follow a specific format, are published publicly on the Regulations.gov website, and the agency is legally required to provide a response within 120 days.

The following Citizen Petition was submitted to FDA on 4/17/24.

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The undersigned submits this petition to request the Commissioner of Food and Drugs to promptly inform the public to current pet food investigations in the same manner the agency has updated the public in the past.

A. Action Requested

Beginning in approximately December 2023, pet food consumers began reporting serious health issues with their pets (cats and dogs) directly related to pet food. To date of this Petition, more than 2,600 pet owners have reported serious health concerns with their cat or dog. Symptoms reported are very similar; bloody diarrhea, bloody vomiting, in many instances seizures. More than 500 pet deaths have been reported by pet owners. One brand of pet food in particular, pet owners have reported 1,679 cat and dog illnesses, 23% of those reports (390) resulted in the death of the pet.

Pet owners themselves have reported serious health issues, similar to the same health concerns their pets experienced. A total of 21 pet owners have reported rectal bleeding, nasal bleeding, and/or chest pain.

In the past four and one-half months since pet owners began reporting these serious pet and human health issues, the FDA CVM has not issued any public alert, the FDA CVM has not responded to FOIA requests regarding adverse events the agency has received, the FDA CVM has not provided the public with any information to their investigation (if any) into these serious animal and human health reports.

We are asking the agency to provide the public with an update(s) to their investigation of this current pet food concern, provide the public with similar information in this current issue as the agency has historically provided the public with past (and other current) issues.

We are requesting the FDA CVM to promptly issue a public notice into their investigation of current and ongoing reports of pets experiencing bloody vomiting, bloody diarrhea, seizures, and death linked to multiple pet food brands. We request the agency to include in this public notice similar information the agency as provided the public in the past with other investigations including:

• the number of adverse events received;
• the symptoms reported;
• the number of pet deaths;
• the number of human illnesses reported;
• the brands reported linked to pet or human illness;
• the testing the agency has performed; and
• encourage the public to report any illness to the agency.

B. Statement of Grounds

In October 2023, the FDA issued a public notice about a “developing investigation” into applesauce products that were linked to four children with elevated blood lead levels. Within days following this initial public notice, the FDA issued another public notice warning consumers “Not to Buy or Feed” one particular applesauce product. Since these first two updates, the FDA has continued to update the public into their investigation of lead contaminated applesauce products 20 more times (a total of 22 public notices within 7 months).

These many public updates involved a total of 519 complaints received by the FDA and CDC, with no reports of deaths linked to the applesauce products.

In 2018, the FDA CVM issued a public notice regarding “FDA Investigation Potential Connection Between Diet and Cases of Canine Heart Disease”. Per this initial FDA notice, it appears the agency made this public announcement based on 8 cases of diagnosed dogs. Following this initial public notice, the FDA issued three more updates to the public regarding the agency’s investigation into this pet food issue. The agency informed the public to the number of cases reported, the names of the brands involved, the diagnostic testing performed by the agency, and urged the public to report any related illness to the agency.

The total number of complaints FDA received during this investigation was 524, including 124 pet deaths.

Beginning in 2011 (we believe), the FDA CVM provided consumers many updates into the agency’s investigation into pet illness and deaths related to jerky treats. In a 2015 update from FDA CVM, the agency informed the public to how many consumer complaints the agency received, the pet symptoms, the testing the agency had performed and urged the public to report any illness to the agency.

Per the 2015 update, the FDA reported more than 5,200 complaints involving more than 6,200 dogs, 26 cats, three people, and include more than 1,140 canine deaths.

As we have evidenced, historically the FDA CVM has issued multiple public statements regarding investigations of various pet food products for multiple causes. Of significance, in the instance of the FDA investigation into diet and canine heart disease and in the instance of the FDA investigation into jerky treats, the agency kept the public informed even though the agency had no confirmed cause for the reports of illness and deaths of pets.

The initial FDA public statement regarding their investigation into a potential link of diet and canine heart disease, the agency alerted the public of their investigation based on only eight cases of illness. As comparison, in the current pet food issue pet owners have documented more than 2,600 illnesses and over 500 pet deaths (as of the date of this Petition) yet the agency has not issued any public updates. Multiple parties have filed FOIA requests with the agency in attempts to be provided with current agency information to the number of adverse events received, symptoms reported, number of deaths, and brands involved. To our knowledge and belief, the agency has not responded to any of these FOIA requests.

We suggest to FDA CVM that that pet food consumers in 2024 deserve to be provided with agency updates in this current pet food investigation just as in other agency investigations. Pet food consumers in 2024 request the FDA CVM to keep them informed in the current pet food concern in the same manner the agency has updated the public in the past, even if the agency has not confirmed a cause for the many illness and death reports (in the same manner the agency has updated the public in the past without a known cause).

C. Environment Impact

There is no known environmental impact of our request for the agency to keep the public updated. However, there appears to be potential environmental impact related to contaminated pet food disposal. Reported by pet owners in Illinois, several truck loads of pet food were disposed of in a rural landfill adjacent to a wildlife preserve. Within days of the dumping, pet owners reported (and documented) 17 dead coyotes in the adjacent wildlife preserve.

Although the coyote deaths cannot be confirmed to be linked to the pet food disposed of in the landfill, it remains a concerning possibility. This concern extends to who/what would be exposed to potentially poisonous pet food when disposed of by pet owners, store owners, and pet food manufacturers.

This potential environmental impact emphasizes the need to properly inform the public.

D. Economic Impact

Not requested to be provided.

E. Certification

The undersigned certifies, that, to the best knowledge and belief of the undersigned, this petition includes all information and views on which the petition relies, and that it includes representative data and information known to the petitioner which are unfavorable to the petition.

Representing pet food consumers,

Susan Thixton
(digital signature)

Susan Thixton
TruthaboutPetFood.com
AssociationforTruthinPetFood.com

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Typically the Regulations.gov website provides the opportunity for public comments on Citizen Petitions. For unknown reasons, our Citizen Petition does not provide opportunity for pet owners to provide comment. But, pet owners are encouraged to submit a comment on the petition directly to FDA by emailing the agency at:

Email: AskCVM@fda.hhs.gov
Subject Line: Docket ID FDA-2024-P-1916-0001

Pet owners are also encouraged to share the Citizen Petition with their elected officials asking your representatives to follow up with FDA to why pet owners have not been updated regarding this current pet food investigation.

And pet owners are encouraged to share the Citizen Petition with their local media, asking media to follow up with FDA to why no public update has been provided.

The Citizen Petition can be downloaded on the Regulations.gov website; https://www.regulations.gov/docket/FDA-2024-P-1916/document.

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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