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Pet Food Regulations

Complete Failure

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:

FAIL

Hill’s investigation of contaminated products:

FAIL

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.

And a week later, December 5, 2018, two more excess Vitamin D recalls were announced; Abound Pet Food from Kroger’s, and Abound Pet Food from King Soopers.

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.

The Failure.

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:

  1. Quality record keeping (which is legally required) will enable investigators to quickly trace the adulteration. Poor record keeping will slow the investigation.
  2. 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.
  3. 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.

Two more excess Vitamin D recalls occurred, both from Hill’s Pet Food. The first was announced on January 31, 2019 and an expanded recall was announced on March 20, 2019.

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,

Susan Thixton
Pet Food Safety Advocate
Author Buyer Beware, Co-Author Dinner PAWsible
TruthaboutPetFood.com
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17 Comments

17 Comments

  1. Lynn Felici-Gallant

    March 26, 2019 at 1:19 pm

    Who produced the vitamin mix?

    • Susan Thixton

      March 26, 2019 at 1:25 pm

      No one has released that information yet.

      • John Nasekos

        March 26, 2019 at 2:28 pm

        What’s the big secret I not releasing the source of the pre mix? Those companies know where it came from. I wonder what other products it is in?

        • Susan Thixton

          March 26, 2019 at 2:30 pm

          I completely agree. It should be disclosed and this entire investigations should have been handled a lot better.

    • Louise

      March 26, 2019 at 10:10 pm

      That would be really good to know, I am guessing it is made in China . . .

  2. Linda Creager

    March 26, 2019 at 1:40 pm

    I am PLEADING with the FDA to make store bought dog food safe immediately!!! This has got to STOP!!!

  3. ~Pet Owner~

    March 26, 2019 at 1:50 pm

    I don’t understand. All we need to know is the name of the Supplier and who they supply to.

    I received a Vitamin supplement from a VERY well known seller. Only gave my dog a bit of it (to introduce it gradually). That’s when his stools got loose again, and would spit up bile. So everything was promptly returned it to the company. Who knows from where they were getting their Vitamin D portion of the mix.

    That’s what’s so frustrating about NOT KNOWING THE NAME OF THE SUPPLIER!!! How many other brands could be affected. The secrecy is exactly what protects these mistake-makers! It’s just crazy irrational!

  4. Donna

    March 26, 2019 at 3:11 pm

    One has to wonder how often this happens and how it might possibly be hidden from consumers. In 2007 a pet food company (not a giant) had product on the shelves that had small chunks of black and white substance in the kibble. Consumers sent samples to the pet food company. They told each consumer they ‘were the only complaint’ the company had received. The President of said company told said the chunks were vitamin/mineral pre-mix that was not ground properly. He said they were aware of the problem and working on it. The product was never recalled. No warning or notice was ever published to consumers. There were sick pets, not certain if the pre-mix was the issue or something else.
    At the very least, one can assume that the product was not “balanced”. One will never know if there were issues such as the current Vitamin D concerns. Twelve years later our pets are still at risk.

  5. karlshrader

    March 26, 2019 at 5:26 pm

    I will NEVER feed any pet of mine food purchased in a store or vets office ever again.

  6. Diane Rise

    March 26, 2019 at 6:22 pm

    I am on a class action lawsuit information email list. There is currently an active class action against Hill’s….it will never bring a beloved furry family member back, but maybe the more people who sign on, it may send a message to the pre-mix supplier from Hill’s having to pay for the deadly product they supplied to them. Go to the Hill’s website and see if you should become a part of the class.

    • Concerned

      March 26, 2019 at 7:41 pm

      IMO – They need to sue the veterinarian clinics besides Hills……then the vets will put the pressure on Hills for better accountability and communication since most clinics push Hills and do not have deep pockets or hopefully settle individually by agreeing to dropping the Hills product line.

      • im3ly

        March 27, 2019 at 6:10 am

        As a CVT/RVT, the thought of all of the thousands of general practice clinics with less than 20 employees getting sued is terrifying. Now, if you’re going after corporate to drop Hills (Banfield, VCA), it’s gonna cost you for a much better lawyer.

  7. Cannoliamo

    March 26, 2019 at 7:24 pm

    To anyone in CVM who may read this comment, …. Vitamin D toxicity in dogs and cats is not rocket science. The indications of exposure to excessive concentrations in the pre-mix should have triggered a comprehensive assessment of the extent of the problem and alerts should have been issued by FDA far in advance of any company recalls. A lot of pets depend on your agency for their lives and their health and allowing the pet food companies, their suppliers and their distributors to compound and extend the toxicity problem to an epidemic level requiring mass recalls falls somewhere between careless oversight and professional negligence. If you don’t possess the administrative controls to manage the resultant issues, at least make us aware of the risks involved so we can assume the necessary responsibility of caring for and properly protecting our pets.

  8. S Kovacs

    March 26, 2019 at 11:23 pm

    Both charts indicate a late october 2018 date when the FDA was notified of a pre mix problem re vitamin D. Is that confirmed, is there documentation of that? That the FDA was told a pre mix had excessive vitiamin D levels? I understand that there is an assumption that may be the problem. I was not aware the FDA had been notified there actually was a problem with the pre mix.

  9. Sandy B

    March 28, 2019 at 12:02 pm

    Excellent review. I happened to buy a case of Hill’s food, my first of this kind, before their recall, and it turned out to be the type listed in the second recall, chicken and barley for adults+7. I called Hill’s to complain they should have captured all the contaminated food in their first recall, and the new safety practices they said they were initiating SHOULD have been standard practice already. I was told the additional recalled products were a result of their (I understood it to be Hill’s) additional testing. I asked how I could be certain the product I bought wouldn’t be in yet another recall. I was told they had finished all testing on product with the deadly premix and potentially with the premix. When I asked if my food was one of those tested, I was told that information was not available. I told the rep that it should be available. That would give owners certain knowledge that their food was not affected. She then asked for the date and code on the food I had bought, and based on that (I think the date was especially important), she assured me my purchase was not manufactured with the poison premix. So, if anyone wants more info from Hill’s, I suggest asking them to check the code and date on the product you do have, just in case. Incidentally, I learned of the recalls from this web site. So, thanks again. Both my dogs have serious health issues already. They wouldn’t have survived this deadly premix.

  10. Peter

    March 31, 2019 at 8:53 am

    My recollection is that traceability is supposed (required) to be “1-step forward and two-steps backward,” to ensure that information is available should it be needed.

    The real question to me is why these issues, when not only the health, but the very lives of the consumers–the animals– aren’t regarded as an “emergency” as they should be.

  11. Jayachandra Pai

    June 4, 2019 at 7:55 am

    I (my pet Lab) has been recomended Hill’s “Metabolic” for liver/ heart/weight issues.Four times costlier than home made food!and a lot of information on overdose of lead,Mercury etc content.I have decided to continue with home made food rather than risk the above potential situation.

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