We don’t know. FDA isn’t telling pet owners where contaminated ingredients went.
The FDA issued a Warning Letter to JBS Souderton/MOPAC on April 23, 2019 regarding the animal feed/pet food suppliers continued distribution of pentobarbital contaminated animal fat (tallow).
The FDA Warning Letter stated:
“Your firm failed to examine raw materials and other ingredients to ensure that they are suitable for manufacturing and processing into animal food (21 CFR 507.25(b)(1)). Specifically, our investigation found that you failed to identify and exclude raw materials and ingredients containing pentobarbital.”
Before we discuss more of the Warning Letter, consider what FDA stated in the above quote. The agency is expecting a rendering facility to “examine” a load of dead animals to “identify” which dead animal was euthanized with pentobarbital.
This is an absurd and impossible request by FDA.
This pet food/animal feed ingredient supplier was initially investigated by regulatory authorities ONLY AFTER a television station (WJLA in Washington DC) performed testing on pet food and found pentobarbital in Gravy Train dog food. AFTER the story broke on WJLA in February 2018, FDA performed an inspection at the manufacturer of Gravy Train dog food, which led to an inspection at JBS Souderton/MOPAC discovering that the pet food/animal feed supplier sold pentobarbital contaminated tallow/animal fat to multiple manufacturers including Smuckers Gravy Train and Champion Pet Food.
Quoting the April 2019 FDA Warning Letter to JBS Souderton/MOPAC (bold added):
“Our investigation revealed that you continued to distribute adulterated products after you received formal notification of pentobarbital contamination from your customer on February 13, 2018, and after formal notification of positive pentobarbital samples from the Pennsylvania Department of Agriculture on or about April 5, 2018.”
In other words, this particular pet food ingredient supplier was alerted to a serious problem in February and April of 2018, but they “continued to distribute” pentobarbital contaminated ingredients to other pet food/animal feed manufacturers; ignoring FDA notifications of adulterated products.
On August 8, 2018 – after FDA follow up testing confirmed this ingredient supplier was still processing pentobarbital euthanized animals into animal feed/pet food ingredients:
“FDA inquired whether you planned to recall, put a hold on distributing, or send notification to all customers regarding the animal food product contaminated with pentobarbital, regardless of the customer’s business. You stated you did not plan to do so, but had made an offer to animal food producing customers that received animal food product to remove any product deemed positive for pentobarbital and to have their tank cleaned.”
Just to be clear – FDA had months of testing evidence this pet food ingredient supplier was shipping adulterated pentobarbital contaminated fat ingredients to feed/pet food manufacturers. But…even with months of testing evidence – the FDA only ASKED the company if they were going to recall. Asked…not required them…asked if they would recall.
JBS Souderton/MOPAC told FDA “no“, they would not recall in August 2018. And because this company refused to recall, almost 9 months later the FDA finally does something by issuing a Warning Letter.
So many questions…
Pet owners have not been alerted to who else JBS Souderton/MOPAC sold pentobarbital contaminated fat to. Was it pet food? or was it sold to livestock feed?
FDA’s not talking.
And what about the rest of the material sourced from pentobarbital euthanized animals that were rendered? When euthanized animals are rendered, the fat is separated from the solid. The bone and animal tissues become meat and bone meal or meat meal. What about those pentobarbital contaminated ingredients? Is FDA even looking into this problem?
FDA has not even mentioned this issue.
Even if this one supplier does finally stop accepting euthanized animals as raw material, those euthanized animals just go somewhere else that also sells fat and meat meals to pet food. What is FDA doing to prevent that?
Little to nothing. As evidenced by this particular situation, regulatory authorities do NOT typically inspect or test pet food ingredients/ingredient suppliers. This entire situation was ONLY discovered because a television station tested pet food for pentobarbital. Had WJLA not tested pet food in early 2018, we wouldn’t be reading about the Warning Letter today.
Will the FDA ultimately force JBS Souderton/MOPAC to recall? Will pet foods/animal feed that purchased pentobarbital contaminated ingredients recall? We have to wait to see.
Why can’t FDA enforce law?
No one can “examine” a load of dead animals hauled to a rendering facility and determine by ‘examination’ which animal was euthanized with pentobarbital. This would require individually testing each dead animal received by the rendering facility for presence of pentobarbital, and wait for the results (while those already decomposing animal carcasses decompose even further).
It’s impossible to achieve. It’s concerning that FDA cannot (or will not) recognize this impossibility.
But there is a way. The FDA could enforce existing law. If FDA would just enforce law, this problem goes away. Why is enforcing law too much for FDA to do?
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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Amy
May 3, 2019 at 1:32 pm
Well. They can enforce law but it’s only as they choose. They act rapidly and aggressively on raw pet food companies when no one is sick but allow this disgusting behavior to continue to months and animals ARE sick!
Debi
May 3, 2019 at 1:33 pm
Reprehensible and SAD, Please people make your pet’s food, not that hard, U-Tube has a lot of videos.
Dr. Oscar Chavez
May 3, 2019 at 2:40 pm
Susan,
I’m confused. Aren’t the FDA just talking out of both sides of their mouths? As long as the compliance policies exist, are these suppliers really doing anything wrong? The first step would be to sunset the compliance policies that allow this. Only then can we discuss enforcement. Or maybe I’m missing something?
This is so strange.
Dr Chavez
Susan Thixton
May 3, 2019 at 4:28 pm
The Compliance Policies are gone, but FDA clearly stated in response to our Citizen Petition they will continue to allow pet foods to contain diseased animal material and material from animals that have died otherwise than by slaughter. Officially, pentobarbital euthanized animals are not allowed – but…as shown by FDA’s action here it isn’t much of a priority and they still allow those animals that have died otherwise than by slaughter. So yes, they are talking out of both sides of their mouth.
~Pet Owner~
May 3, 2019 at 4:47 pm
To make the ilogic of comprehension even MORE confusing try to follow these statements:
(1) Diseased animal material in ANY food (human food or animal food) is a direct violation of federal law. Decomposing animal tissue in ANY food (human food or animal food) is a direct violation of federal law.
(2) Yet Compliance Policies were established to permit the use of the above referenced.
(3) Except the Policies have been withdrawn.
(4) And the practice which the Policies permitted are subject to “enforcement discretion.”
(5) Since they “do not believe that the use of diseased animals that died otherwise than by slaughter to make animal food poses a safety concern and they intend to continue to exercise enforcement discretion where appropriate.”
(6) Except they neglect to define appropriate circumstances.
https://truthaboutpetfood.com/the-fda-classifies-dogs-and-cats-as-obligate-scavengers/
So they’ve just negated the counter to a stated negative that pertained to an illegal practice which they always permitted and will continue to do unless they choose not to.
Dr. Oscar Chavez
May 3, 2019 at 2:45 pm
Interesting – I found this: https://www.fda.gov/animal-veterinary/animal-health-literacy/questions-answers-contaminants-pet-food
It seems they are now conclusively stating that pentobarbital is not allowed. Also, it seems they are reviewing and possibly reconsidering compliance policies. They even admit to a lack of enforcement due to resources.
Overall, this would seem to be a step in the right direction.
Dr. Chavez.
Iva Kimmelman
May 3, 2019 at 4:16 pm
I feel ILL!
Claudine Boissonneault
May 3, 2019 at 9:30 pm
Actually it’s sad, but yes after a couple of days you can tell if the animal was euthanize vs ‘natural death’.
Extremities turns blue/purple, almost the same color as the euthanyl.The paws, the mouth.. for our pets anyways, i don’t know if it does the same thing to cows and chickens.
This is crazy..
Peter
May 4, 2019 at 8:05 am
The FDA is essentially held in “regulatory capture”: created as a state regulatory agency to act in the public interest, but instead advancing commercial or special interests that dominated the industries it was charged with regulating.
You keep reminding us of this failure of government. It is abominable.
~Pet Owner~
May 4, 2019 at 12:48 pm
So Regulatory Capture https://en.wikipedia.org/wiki/Regulatory_capture has been mentioned three different times now. I for one, am prepared to take my mid-term exam on the subject. So it’s clear WHY pets are eating garbage. And explains pets being victimized because of a fancy term – right. ‘Cause I’m pretty sure pentobarbital contaminated animal fat is in “Dollar Store” brand PF. Ooops I wonder if that makes it illegal, or simply another example of “enforcement discretion.”
Just my opinion – but it’s doubtful everyone out there has gotten the word yet about making their own PF. But then again, the fact that pets are eating euthanized animals just can’t be avoided.
Well at least we know. ?
reader
May 5, 2019 at 1:57 pm
This should be reason enough to understand that pets are recycled into pet food from animal shelter killing centers from across the nation. Rendering companies pick up all the killed pets at all the killing centers and the pets are recycled into pet food for a free protein to help make pet food even more profitable.
How hard is it to figure out where the Pentobarbital is coming from?
All the dead dogs and dead cats ground up into the pet food.
The fd a and the pet food industry are NOT required to put dead dogs and dead cats on the ingredient list, or pics of killed dogs and killed cats all over the kibble bags and canned food as that would be a hard sell to pet consumers
This fact has been known for years, just read the books Pet Food Pets Die For from pet food researcher Ann Martin.
And this pets recycled into pet foods are mentioned in random articles and books for many years.
Recycled Pets into pet food is a known and truthful fact.
Yes it is an unpleasant Truth, an inconvenient Truth. but all the same, it is a Truth.
Now finally, more are learning what is really in pet food.
What to do.
Change what you feed your pet. Stop buying pet food from the Big Pet Food Industry.
K d Ladd
September 10, 2019 at 12:53 pm
What about sulfuric. Acid in all types animal feed from wet milling grains & their byproducts & can be in human food also