A Few Responses

FDA’s response to the Chapman University Study finding 38% of pet foods tested possibly mislabeled, a brief response from the publisher of the Chapman University Study, a response from FDA regarding rancid fat pet food test results linked to the death of 12 animals and a response from Purina and FDA regarding their new product making ‘human grade ingredient claim’.

Chapman University’s study found that 38% of the pet foods they tested contained a meat ingredient not listed on the label or did not contain a meat ingredient that was promised to be included in the pet food. The following questions were sent to FDA regarding this alarming university study…

Chapman University just released a report on research performed at the University that found 20 of 52 pet foods tested to be mislabeled. This is 38% – a significant portion – of foods tested were found to contain a animal protein source not listed on the label. Of additional concern, due to the PED virus, “pork was the most common undeclared meat species.” Link to Chapman University report: http://blogs.chapman.edu/press-room/2014/09/16/chapman-university-research-on-meat-species-in-pet-foods-shows-not-all-brands-follow-regulations/

What assurance can FDA provide consumers their pets are safe from eating mislabeled foods? What action will FDA take to protect pet food consumers from pet food fraud? Can FDA provide consumers with assurance pets are not at risk to a PED type virus that could spread to cats and dogs?

We hope FDA will take swift action to stop pet food fraud.

FDA responded with…

Susan, Thank you for sharing this article. FDA welcomes new information and encourages those with concerns about a particular pet food product to submit a report to the Safety Reporting Portal: https://www.safetyreporting.hhs.gov/fpsr/WorkflowLoginIO.aspx?metinstance=B4B8DBDBB6CD79D2ED83195A812D1E7D9C329501. Pet food does not require pre-market approval; however, all ingredients are required to be listed on the label. FDA has the authority to inspect pet food manufacturing facilities and takes action when it finds violations, including not including an ingredient on the label or substituting one ingredient for another ingredient. Please see here for a recent warning letter issued for this violation: http://www.fda.gov/ICECI/EnforcementActions/WarningLetters/ucm255000.htm.

PEDv is transmittable only among pigs and cannot be transmitted to other animals or human beings.

Response (not sent to FDA): It appears the FDA is saying they can take action, FDA has the authority – but in this case they are not going to do a thing. FDA provides “a recent warning letter issued for this violation” seeming to imply the agency has recently investigated pet food fraud. The FDA warning letter turns out to be Evangers Pet Food from back in 2011 – three years ago. Since that FDA investigation – two studies have been published finding numerous instances of pet food fraud. The 2012 ELISA Technologies study finding almost 50% of foods tested were mislabeled due to an undeclared meat protein or lack of meat protein listed on the label. And the 2014 Chapman University study finding 38% of foods tested were mislabeled due to the same circumstances.

It is clear the pet food industry has a problem with mislabeling. What a shame the FDA doesn’t recognize the problem and take action to protect pet food consumers. I hope the FDA reconsiders.

Questions were sent to Dr. Rosalee Hellberg the publisher of the Chapman University study asking if the University had plans to release the names of the foods tested and if they tested the unidentified meat proteins for dog or cat DNA. Her response…

Thank you for your interest in the pet food study. In response to your question, we did not test the nonspecific meat ingredient for dog or cat DNA.  There are a variety of other meat species that could have been present and we limited our testing to the species named in the study.  Also, it was not our intention to single out pet food brands, but rather to investigate the issue as a whole. Therefore, we will not be releasing the names of the brands that were found to be potentially mislabeled.

A few weeks ago, TruthaboutPetFood.com shared a heartbreaking story of the death of 12 animals (7 dogs, 5 pigs) who consumed a Pedigree dog food. The consumer reported the food and the animal deaths to FDA and to Texas authorities – no one investigated. In numerous back and forth emails with FDA, I finally received a statement from the agency. The FDA shared they did not show a report was filed on this dog food and asked that the incident be reported (again). I continued to push for a response from FDA to the lab results of the dog food – finding a high level of rancid fat in the food (the consumer had the food tested). FDA finally told me…

Rancid fat should not be in food and most commonly happens from improper handling or storage of the finished product. FDA has not set action levels for every hazard or contaminant, including rancid fat; however, the agency could take action if rancid fat or rancidity was found during the inspection of an animal food manufacturing facility.

Response (not sent to FDA): Again we have the issue of ‘inspection’. To my knowledge, pet food manufacturing plants are rarely inspected (every ten years or so) unless there is a serious concern found in the food. Such as Salmonella. If a pet food or treat is tested to contain Salmonella, it is common for FDA inspectors to inspect a plant for days (at the expense of the manufacturer). Salmonella could kill a human (that came in contact with the pet food), rancid fat could kill the pet. Both are serious concerns. However it appears that ‘inspection’ is only priority if the food is a risk to humans (not the pets).

And TruthaboutPetFood.com recently reported that a Purina pet food ‘topping’ product makes the claim it is “made with real, human-grade ingredients”. Questions were sent to FDA asking if Purina is being held to the same requirements as some of the smaller pet food manufacturers using human grade ingredient claim.

Background – pet food manufacturers that use human grade (USDA inspected and approved human edible) claims in their advertising or on product labels are forced to obtain what is known as a ‘Letter of No Objection’ from FDA. Individual states are refusing to allow products to be sold within their borders with the human grade claim without the FDA ‘Letter of No Objection’.

Does Purina have this ‘No Objection’ letter from FDA? FDA wouldn’t tell me. I was told I would need to file a Freedom of Information Act request for the information.

Purina stated…

Dear Ms. Thixton,

Thank you for contacting Nestle Purina PetCare Company and for your interest in our new Purina® Pro Plan® – Savor® – Additions™ for Dogs.

To answer your question, Purina is in compliance with the FDA as it relates to the human grade ingredient language used to promote this product. The ingredients we use in this product are fit for human consumption and meet the U.S. regulatory standards for human edible grade ingredients.

Our Purina® Pro Plan® – Savor® – Additions™ for Dogs are produced by a co-manufacturer. Every co-manufacturer of Purina products must meet our strict standards for ingredient specifications, product safety, sanitation and good manufacturing practices.

Again, thank you for contacting us to learn more about our new product.

Response (not sent to FDA or to Purina): In previous experience with Freedom of Information Act (FOIA) requests to FDA, even though it is required by law for the agency to respond within a set time frame, that doesn’t always happen. I’m still waiting on a FOIA request from FDA sent well over a year ago. What a shame they couldn’t just provide the information as an effort in pet food transparency.

And with Purina, though it is a baby step – I find it encouraging that one of the largest manufacturers of pet food in the world is taking a baby step towards a ‘food’ ingredient pet product (versus a ‘feed’ ingredient pet product). Can we expect more pet ‘food’ products from Purina?

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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