Twenty-one weeks. That’s how long it took to trace a deadly Vitamin premix. (And we don’t even know if it has been fully traced.)
FDA investigation of Vitamin premix supplier:
Hill’s investigation of contaminated products:
The cost of the failures:
The lives of our pets.
When a pet food manufacturer learns there is a problem with their pet food (such as internal testing for excess Vitamin D after consumer complaints), they are required by federal law to report the issue to FDA within 24 hours.
Side note: A recall is NOT required within 24 hours. Often – even with deadly issues such as the excess Vitamin D – a recall notice to warn the public could take a week or more AFTER the legal requirement to report the problem to FDA. Often it can be FDA themselves that delays the public recall notice.
What the FDA does after receiving the report of a pet food problem from a manufacturer – depends on the severity of the pet food issue AND how strongly FDA believes the manufacturer has properly responded to the problem. With the deadly issue of excess Vitamin D, we can safely assume the FDA initiated a full investigation by sending representatives to the pet food plant that reported the problem.
In this case, the first excess Vitamin D recalls happened on November 2, 2018 from two different pet foods; Natural Life Pet Food and Nutrisca Pet Food. Four days later another recall from Orlando Pet Food. And 1 week after the first 2, another brand was recalled – Natural Life Pet Food.
The next recall wasn’t announced until a full 25 days AFTER the first two recalls; on November 27, 2018 Sunshine Mills announced the recall of multiple brands. The two following days resulted in two more recalls; November 28, 2018 from ANF Pet Foods, and November 29, 2018 from Elm Pet Foods.
Only considering the excess Vitamin D pet food recalls that occurred in 2018, precious time was wasted. Below is a daily timeline of just the 2018 recalls.
With a serious issue as excess Vitamin D, the FDA goes to the pet food manufacturing plant to perform an inspection, initially to validate the pet food issue. Part of the FDA’s investigation – the most significant part – is to assist the pet food manufacturer with trace forward and trace backward investigation. The ultimate responsibility to trace forward and trace backwards the pet food problem is with the pet food manufacturer. The Food Safety Modernization Act laws include strict requirements of pet food manufacturers to maintain proper records (for trace forward and trace backward investigations). However, FDA often oversees this process to assure it is done properly – especially in a deadly situation as excess Vitamin D.
Trace forward is to investigate where the contaminated pet foods went – such as to distributors and retailers. The pet food manufacturer is required to document every detail of every lot of pet food sold; where it shipped (who received it). A trace forward investigation should be simple when proper records are kept.
Trace backward is required to find the original source of the adulteration, in this case the Vitamin Premix supplier. Then further investigation at the Vitamin Premix supplier would trace forward the premix to determine each pet food manufacturer that received the adulterated product.
While the trace forward and trace backward investigation should proceed quickly, the pace of the investigation could be influenced by three things:
- Quality record keeping (which is legally required) will enable investigators to quickly trace the adulteration. Poor record keeping will slow the investigation.
- Cooperation or lack of cooperation of the manufacturer with FDA can speed up or slow down an investigation. Such as, if a manufacturer or ingredient supplier is not forthcoming with records, the FDA must become almost a private investigator to trace forward and backward.
- Or the investigation could be slowed by poor investigative skills of FDA authorities. If the agency does not promptly start the investigation, if the agency does not request proper documents from the manufacturer, and in this case if the agency does not promptly investigate the Vitamin Premix supplier – valuable time is lost.
The timeline of all (recent) excess Vitamin D recalls – in weeks – now looks like this:
We can somewhat understand the delay in recalls between week 3 and 4. It could be that the manufacturer or Vitamin Premix supplier cooperated during this time frame making the FDA task of trace forward and backward easier. And it simply took two weeks to investigate and prepare the recalls.
But…there is NO excuse for the 14 weeks (weeks 7 through 14 and weeks 15 through 20) of delay in these deadly recalls. Was the Vitamin Premix supplier not properly providing records to FDA?
Or, did the FDA drop their investigation of the trace forward? The government shutdown occurred over weeks 9 through 12 diagrammed above. But, even if the government shutdown played a role (it shouldn’t have), there is no sound reasoning for the second set of 7 weeks between the two Hill’s Pet Food recalls.
Regardless who is to blame, this was a deadly failure. An unknown number of dogs were sickened and died because of the weeks of delay tracing the adulterated Vitamin D. Inexcusable.
Wishing you and your pet(s) the best,
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