“Expanded Recall” = a Twofold Failure

On February 8, 2023 Purina issued a recall for their Purina Pro Plan Veterinary Diets El Elemental Dry Dog Food due to excess vitamin D. More than a month later – on March 10, 2023 – Purina expanded the recall.

On March 3, 2021 Bravo Packing issued a recall for All Performance Dog and Ground Beef Raw Pet Food due to Salmonella contamination. Two weeks later – on March 16, 2021 – Bravo Packing expands the recall.

On December 30, 2020 Midwestern Pet Food issued a recall for multiple brands due to aflatoxin contamination. Almost 2 weeks later – January 11, 2021 – Midwestern expanded the recall.

Why are recalls “expanded”?

Pet food manufacturers are required to keep detailed records. Typically, incoming ingredients are documented (ingredient supplier, date received, pounds received) and assigned unique manufacturing numbers. When a batch of pet food is made, each ingredient added into the batch is documented by these numbers.

In most manufacturing facilities, all of the documentation of incoming ingredients and manufacturing is performed by computers/computer programs. Due to this detailed record keeping, a manufacturer is able to know exactly which suppliers provided each ingredient in the batch of pet food, know when each ingredient was received, and even provide inventory information (how much of each ingredient remains available for future batches).

So…when a problem occurs, these records SHOULD provide the manufacturer with immediate knowledge of exactly which suppliers provided every single ingredient within that batch of pet food. Once the adulterated ingredient is determined (such as vitamin premix), records SHOULD provide the manufacturer with immediate data to every batch of pet food the adulterated ingredient was used in.

When the FDA or State authority comes knocking on a pet food manufacturer’s door to investigate a problem, the manufacturer SHOULD provide the investigator with all of these records. With proper record keeping and transparency with the regulatory authority, a complete recall can be quickly announced. But…if any part of the process falters, an incomplete recall could be announced only later to be expanded.

Pet owners are not informed if/when a manufacturer fails to properly document ingredients/batches of pet food. And we are not informed if/when a manufacturer refuses to provide regulatory authorities with necessary documents.

Pet owners are not informed if/when a regulatory authority fails to properly investigate a pet food issue.

But…our pets pay the price if any of these issues arise. The delay between the initial recall and the expended recall is deadly in many circumstances.

On January 31, 2019 Hill’s Pet Food announced a excess vitamin D recall. The FDA Warning Letter to Hill’s stated: “On January 31, 2019 your firm initiated a recall (RES# 82018) of twenty-five (25) different canned dog food products manufactured by your firm. On March 20, 2019 your firm determined that additional products were affected. As a result, approximately twenty (20) additional lots of product previously listed in the original recall were added, and the recall was expanded to include eight (8) new products of canned dog food. On May 20, 2019 your recall was expanded yet again to include an additional lot.”

Many pets lost their lives because it took Hill’s and the FDA almost four months to fully trace the adulterated ingredient. There is NO excuse.

After the 2007 pet food recall, the Office of Inspector General audited FDA’s handling of this deadly recall and found: “FDA’s inspection procedures did not ensure that FDA verified the accuracy and completeness of Menu Foods’ recall list. Specifically, FDA’s procedures did not require that FDA promptly reconcile the firm’s production records to its raw material lists to ensure that the recall list covered all contaminated lots.” It is unacceptable that sixteen years later the same mistakes occur.

Personal opinion: Manufacturers should be be issued fines for every expanded recall. A significant dollar amount fine for every minute from the initial recall to the expanded recall. Every recall investigation should be audited, and if regulatory failed in the investigation – that individual(s) should lose their job. Until there are substantial penalties for failed investigations, they will continue to happen and more pets will die.

Wishing you and your pet(s) the best,

Susan Thixton
Pet Food Safety Advocate
Author Buyer Beware, Co-Author Dinner PAWsible
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