It took six months for the Center for Veterinary Management (sub-division of the FDA) to respond to Spex CertiPrep’s testing of pet food. Their response, tries to minimize the severity of the lab results. Tries, but fails.
Spex CertiPrep is an independent company that tests a product line every couple of years to promote their business. This past year, they tested pet food for heavy metal contaminants. The results were shocking, finding significant levels of heavy metals in pet food.
In January 2011, I wrote the FDA asking for a response to the pet food testing. I received their response July 8, 2011. The response was an email apologizing for the delay and an attached letter from Daniel G. McChesney, Ph.D. Director Office of Surveillance and Compliance Center for Veterinary Medicine to the Editorial Director of Spectroscopy Magazine. Dr. McChesney’s letter was not friendly – in closing statements he reprimands the magazine for publishing SpexCerti Prep’s testing of pet food. (By the way, Dr. McChesney was the FDA official that avoided my questions of illegal FDA Compliance policies at the AAFCO winter meeting.)
Click Here to read the full letter from Dr. McChesney to Spectroscopy Magazine.
Basically, Dr. McChesney discounted the entire pet food testing done by SpexCerti Prep. He states the authors of the study made “three critical mistakes”. Here’s what Dr. McChesney says and another view…
“The first mistake was the use of Environmental Protection Agency (EPA) Reference Dose and/or World Health Organization (WHO) Permissible Tolerable Daily Intake values … were indicative of safety concerns for the long term health of dogs or cats.” Dr. McChesney suggests that SpexCertiPrep should have used the National Research Council (NRC) ‘Mineral Tolerance of Animals Second Revised Edition 2005’. He goes on to say that the FDA uses this resource “to help determine whether concentrations of specific minerals in pet foods pose a threat for animal health and safety.”
Well, what Dr. McChesney didn’t say was that the FDA has NEVER established maximum levels of heavy metal levels specific to pet foods; existing maximum levels apply to all animal feed (cow feed, horse feed, duck feed, dog food, cat food and so on). Only now, right about the same time this paper was published, did the FDA finally initiate a program to determine maximum heavy metal levels in pet food (it is expected to take several years for this to be compiled).
What Dr. McChesney didn’t say was that maximum levels of heavy metals in animal feed differs from what is said on the FDA website than what is listed in the AAFCO (American Association of Animal Feed Control Officials) Official Publication (OP). As example, the FDA website states – arsenic – animal feed should have a maximum of 2 ppm (parts per million) and the AAFCO OP states 50 ppm; selenium – FDA 0.1 ppm – AAFCO 2 ppm. (crazy isn’t it?) Thus it appears that either the FDA or AAFCO (or both pet food regulatory agencies) aren’t following guidelines established by the NRC.
Dr. McChesney’s second complaint – “critical mistake” was “lack of any scientific basis for setting the amount of food consumed by the reference-size dog and cat”. He states the testing used over-feeding amounts for dry food and under-feeding amounts for wet foods “to provide daily calories for adult maintenance”.
What Dr. McChesney didn’t say was that pet food labels themselves have extremely varied pet food feeding recommendations and because AAFCO has yet to approve caloric statements on pet food labels (representatives of Big Pet Food have asked for “20 years” to change their labels providing calorie information to consumers), pet owners aren’t told what the daily calorie intake from the pet food is. Perhaps one of the reasons SpexCerti Prep (and millions of pet parents) over feed their pets is because of pet food regulations – or lack of regulations.
And lastly, Dr. McChesney states that SpexCerti Prep did not correct “for the difference in moisture contents of dry versus wet products, especially prior to making comparisons of mineral contents between these two types of products.” Not a huge error Dr. McChesney, and it was only in making comparison of dry to wet food – not in the results of their testing.
Most of what SpexCerti Prep found in pet food is very close to maximum according to AAFCO maximum levels (which appear to be significantly higher levels of acceptable heavy metal levels than those found on the FDA website). However – and this is significant – the maximum levels as stated on the FDA website and in the AAFCO OP are for “feed” – meaning all animal food. It is doubtful that each animal within the FDA’s “feed” consuming category (such as cattle, horses, pigs, dogs, cats, birds) would be affected at the same level for each heavy metal.
How much is too much for your pet? We don’t know. The FDA has never bothered to set a maximum level specific to dog food and cat food (although pet food is a multi-billion dollar industry). Are pets consuming close to ‘feed’ maximum levels of heavy metals (per SpexCerti Prep findings) day and day out from pet food being poisoned over time? Again, we don’t know. From what I was told, it will take up to five years for the FDA to complete their pet food maximum heavy metal requirements.
And as for Dr. McChesney’s reprimand of the Spectroscopy Magazine for publishing SpecCerti Prep’s pet food testing…Dr. McChesney isn’t this the pot calling the kettle black? Spectorscopy Magazine and SpecCerti Prep did nothing illegal or violated any Federal laws. The FDA on the other hand allows any pet food manufacturer to violate the Federal Food, Drug, and Cosmetic Act via FDA Compliance Policies. Thanks to your FDA Dr. McChesney – unknowing pet parents can purchase illegal dog food and cat food without their knowledge.
Needless to say, I felt Dr. McChesney’s letter – FDA’s response – to be another miss. For human grade chicken to be tested at 3.2 ppb (parts per billion) and pet food maximum to be tested at 5900 ppb of lead – human grade chicken 4.4 ppb, pet food max 290 ppb of arsenic – human grade tuna 89 ppb, pet food max 560 ppb – there IS NO EXCUSE.
Thanks again to SpexCerti Prep for having the courage to take on this pet food testing and to Spectroscopy Magazine for having the courage to publish it.
Wishing you and your pet(s) the best,
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