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,
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