FDA told Industry a different DCM story than what they told Pet Owners

Information provided in a FDA FOIA request raises some questions about the Agency’s investigation of DCM in dogs.

More than 1,000 pages of documents were provided in a Freedom of Information Act (FOIA) request regarding FDA’s investigation of grain-free pet food potentially linked to dilated cardiomyopathy (DCM) in dogs. Documents provided ranged from a slide presentation FDA provided industry, to test results of pet foods, to email communications between the trade association that represents Big Pet Food (Pet Food Institute) and FDA.

The FDA released to the public their first alert about their investigation into grain-free pet foods on July 12, 2018. FDA alerted the Pet Food Institute (PFI) to this announcement on the same day as evidence by this response from PFI to FDA (PFI thanking FDA for the “heads-up”):

What is concerning about the above email from Pet Food Institute to FDA are these sentences: “I was under the impression that our webinar next week would inform…pet food makers’ understanding of the issue, perhaps before any public messaging was issued. So this is a little concerning. I imagine the public reaction might be quite severe and impact products that aren’t implicated by FDA.”

The PFI wanted to know FDA’s information FIRST – before pet owners (we can assume to be prepared to handle consumer concerns). FDA was giving a private webinar update to PFI members the following week (evidenced below). And it appears that PFI wanted to steer the FDA in a direction that called attention to ONLY certain brands of pet foods and away from other pet foods; “public reaction might be quite severe and impact products that aren’t implicated by FDA.”

At the same time of FDA’s first public announcement regarding their investigation of DCM cases in dogs – the same time PFI wanted to make sure certain brands were NOT “implicated by FDA” – the Agency provided a special webinar for members of the Pet Food Institute. The email below is from Pet Food Institute to FDA regarding the webinar (to be held later that day):

Note in the following email that 14 FDA representatives participated in the Pet Food Institute webinar:

But…the puzzling part…at the time of the FDA public notice (July 2018) and the time of this webinar, the FDA had received ONLY 24 DCM reports over 4 years (cat and dog cases, received between 4/3/2014 through 6/12/2018). From a slide presentation FDA gave to industry on July 18, 2018:

And what brands were “implicated by FDA” at the time – the products Pet Food Institute worried about? Per another slide from the FDA webinar to industry on July 18, 2018 a Mars Petcare brand – California Naturals – was top of the FDA list:

Also notice, of this FDA 2018 list of implicated pet foods…almost half of the pet foods were a kangaroo based variety.

At the time of the first FDA public notice regarding the DCM investigation:

• The FDA ONLY had 21 reports of dogs diagnosed with DCM (over the previous 4 years) reportedly linked to pet food.
• Almost half of the foods consumed by these 21 dogs were a kangaroo based pet food.

But…the FDA never told the public in July 2018 the Agency had only received reports of 21 sick dogs over 4 years. The FDA July 2018 public announcement never mentioned kangaroo.

The FDA presentation to industry in 2018 also stated that grain-based pet foods and grain-free pet foods both tested similarly for taurine and the amino acids dogs require to produce taurine:

But again…in the public update issued at the same time (July 12, 2018), FDA never mentioned that both grain-based pet foods and grain-free pet foods tested similarly for these amino acids.

(Side note: the above slide from FDA’s industry presentation includes some false information. The 3rd bullet point states that non-grain free cat foods test higher for amino acid levels “because they have greater minimum AAFCO requirements”. This is absolutely false. Pet food nutritional requirements are ONLY in two categories – adult maintenance and puppy/kitten/reproduction. Grain free pet foods have no different nutritional requirements than grain based pet foods. It is VERY puzzling why or how FDA could have made such an error in their presentation.)

And one more concern…FDA Failure to recall or alert the public to out of compliance pet foods.

Within the documents were FDA testing results of multiple samples of California Naturals Kangaroo & Lentil dog food and testing results of Fromm Heartland Gold Grain Free Large Breed Adult dog food. Both of these dog foods tested well below the minimum requirements for iron. With the California Naturals Kangaroo & Lentil dog food (manufactured by Mars Petcare – the entire line of California Naturals pet foods have since been discontinued), testing of 3 different samples revealed this dog food contained 30 and 31 mg per kg of iron. This dog food was out of compliance as the AAFCO minimum requirement for an adult dog food is 40 mg per kg of iron.

With the Fromm Heartland Gold Grain Free Large Breed Adult dog food, the testing results again showed the same low iron results. The Fromm dog food testing found the pet food out of compliance at 30 mg/kg iron (again, when the required minimum amount is 40 mg/kg iron). Note: the testing results chart below – provided in the FOIA request — mistakenly lists the AAFCO minimum iron at minimum 88 mg/kg – which is the minimum iron required of a puppy food, not an adult food as this product is listed. It is unknown why FDA made this error as the product name clearly states “Adult” (an adult dog food requirements is 40 mg/kg of iron).

Both of these pet foods were not complete and balanced (per AAFCO requirements) and could have been recalled for being out of compliance. Why didn’t FDA publicly release these testing results and/or require the manufacturers to recall the products?

It is unknown why the FDA did not fully disclose what they knew about the DCM investigation to pet owners (at the same time and in the same manner they disclosed to industry). Giving the public a different perspective of the Agency’s DCM investigation than what is given to industry seems problematic. Lack of recalls and/or public warnings to out of compliance pet foods is certainly problematic.

My thanks to Daniel Schulof of Keto Natural Pet Food for providing me these FOIA documents.

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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