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FDA Warning Letter alerts us to MORE Pentobarbital in Pet Food

Valley Proteins – one of the largest rendering companies – told FDA that pentobarbital is an “unavoidable contaminant.”

Valley Proteins – one of the largest rendering companies – told FDA that pentobarbital is an “unavoidable contaminant.”

The FDA issued a Warning Letter to Valley Proteins on November 18, 2019. Though the Warning is cryptic, it is evidence of several concerning problems in pet food AND apparently a new (bad) attitude from FDA.

FDA stated “On February 5 and 6, and April 3 and April 22, 2019 the U.S. Food and Drug Administration (FDA or “we”) conducted an inspection of your rendering plant located at 1635 Indian Hollow Road, Winchester, Virginia 22603. Your rendering plant produces animal food ingredients distributed to animal food manufacturers.”

The Warning Letter states that pentobarbital was found in fat ingredients produced by Valley Proteins. FDA warned Valley Proteins (bold added for emphasis) “the presence of pentobarbital in your animal fat products causes these products to be adulterated because the animal food contains an unsafe new animal drug. The drug is unsafe because it was not used in conformance with the drug approval, which does not have a tolerance established for the presence of pentobarbital in the edible tissues of animals.”

Note the FDA warned Valley Proteins – a rendering company that turns dead animals into ‘food’ (but actually feed) ingredients – about pentobarbital because the drug was not “used in conformance with the drug approval“. This is a distinct change in FDA language regarding pentobarbital in pet fooda very concerning distinct change in language.

As example of FDA’s change in pentobarbital language, in February of 2018 FDA warned the public about the potential of pentobarbital in numerous Smuckers manufactured pet foods. Within this warning FDA stated “any detection of pentobarbital in pet food is a violation of the Federal Food, Drug, and Cosmetic Act.” This warning is the accurate warning that should be declared by FDA on ANY pentobarbital warning. The Federal Food, Drug and Cosmetic Act clearly states ANY food (the legal definition of food includes animal/pet food) is adulterated (illegal) “if it is, in whole or in part, the product of a diseased animal or of an animal which has died otherwise than by slaughter.” A pentobarbital euthanized animal is ‘an animal which has died otherwise than by slaughter’. This 2018 warning accurately cites law as the foundation for the adulterated pet food.

BUT…this new Warning Letter to Valley Proteins completely revises the previous FDA warning about pentobarbital. Now the FDA is publicly ignoring federal law in the Valley Proteins Warning stating ONLY that pentobarbital was not used properly (“in conformance with the drug approval“). This is extremely concerning language from FDA as it indicates that FDA is positioning themselves to further defend their allowed use in pet food of diseased animals and animals that have died other than by slaughter.

Another serious concern of the Warning Letter is a statement from Valley Proteins to FDA. Valley Proteins told FDA “that pentobarbital is anunavoidable contaminant not known to present a health hazard‘.” Valley Proteins as well completely ignores federal law that clearly states any food is adulterated if it is sourced from “an animal which has died otherwise than by slaughter.”

The Valley Proteins website states “Valley Proteins, Inc. has grown to become one of the largest rendering companies in the United States with several hundred million dollars in annual sales. On average, the company currently processes three million tons of raw materials, and manufactures over one million tons of value-added animal feed ingredients annually, which are marketed throughout the world.” For a company of this size, processing millions of tons of animal material all over the world to have an attitude that “pentobarbital is an unavoidable contaminant not known to present a health hazard” is EXTREMELY concerning.

And then this Warning Letter discusses one more concerning issue. FDA stated to Valley Proteins “Our investigation revealed that once you became aware of the pentobarbital contamination on December 18, 2018, you did not take immediate action to notify customers or recall the product, which are actions specified in your “9.12 Recall Plan” written procedure. On February 11, 2019; April 3, 2019; April 16, 2019; and April 22, 2019, FDA inquired whether you planned to recall the animal food product contaminated with pentobarbital. You stated you did not plan to do so and did not provide FDA with requested information regarding the amount of potentially affected product that was distributed by your firm before you learned of the positive FDA test result.”

The FDA knew products sold by Valley Proteins were adulterated, but FDA did not force the company to recall. Valley Proteins told the FDA ‘No’ – we won’t recall, and we’re not going to tell you more. And FDA just accepted their response. This issue has been going on for almost 1 full year – beginning December 18, 2018 – and only now did FDA take some action by issuing this Warning Letter (a very weak response from FDA).

To read the full Warning Letter, Click Here.

This is very concerning and completely unacceptable behavior from FDA and Valley Proteins. Pet owners don’t know where these adulterated ingredients ended up – don’t know if their pet is consuming an illegal adulterated pet food right now. Beyond absurd.

Note: We will be filing Freedom of Information Act requests for more information, when FDA provides the information it will be shared. Unfortunately, FDA takes their time providing such requests – often up to 2 years.

Wishing you and your pet(s) the best,

Susan Thixton
Pet Food Safety Advocate
Author Buyer Beware, Co-Author Dinner PAWsible
TruthaboutPetFood.com
Association for Truth in Pet Food


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19 Comments

19 Comments

  1. Dianne & Pets

    December 12, 2019 at 3:03 pm

    Wow, just wow!!! Instead of following the money, this needs, follow the trucks. I wonder if the pet food manufacturers will tell us if they use them or not.

  2. Laurie Raymond

    December 12, 2019 at 3:16 pm

    Pentobarbital is only an “unavoidable” contaminant if the rendering company is not processing carcasses by species. Livestock species from slaughterhouses are not going to have pentobarbital – the euthanasia drug with NO other uses – in their tissues. No one euthanizes cattle. Well, they might, if a cow is a pet, as a horse might be euthanized – but this would not happen in a slaughterhouse. A simple rule requiring the processing of slaughtered animals separately from random sourced carcasses, as veterinary, home and shelter euthanasias, field deaths and highway deaths ought to be fundamental in ruling what sources can and cannot be processed into animal feed. Is this not also a tacit admission that species specific labels of ingredient meals cannot be trusted as accurate? If pentobarbital is an unavoidable contaminant and the identified species of a meal ingredient is not trustworthy, what IS the point of labels at all?

  3. readerguest9

    December 12, 2019 at 3:23 pm

    The use of euthanized pets in pet food has been going on since the invention of pet food. Read more at Pet Food, Pets Die For by Ann Martin. Killed and Murdered Pets at every so called shelter killing center is free meat protein picked up for free by the rendering companies, this is a free service for every killing center, and delivered to rendering plants where all the pets, collars and all are cooked down and grinded up for meat protein by all Big Pet Food kibble, semi wet and canned food. Including Purina, Iams, Science Diet, Hills, Walmart brands, Grocery Store brands, etc. This is why pet food is so profitable with free meat protein that saves them a fortune. The wheat, corn, soy, etc is the rotten, moldy, buggy, cereal and any old expired foods, that cannot be sold for human consumption, it is free to the pet food industry. The fat to stick all this kibble, semi moist or canned food, is free from the restaurant industry that has many 50 gallon drums of used oil sitting outside in the heat with bacteria producing toxins in the fat. When the kibble, semi moist or canned is cooked, it will not remove all the bacterial toxins, another very bad ingredient for pets.

    This is not a problem. Stop buying pet food when you can. Supplement pet food with a raw organic pastured EGG, as a raw egg is the most complete protein available with all the amino acids and nutrients needed to grown an entire chicken. This is an affordable and easy way to add raw to your pets diet.
    Add a handful of frozen or fresh green BEANS or green PEAS, add a slice of a cooked SWEET POTATO, etc
    Add a teapoon to tablespoon of plain yogurt or plain KEFIR for probiotics. Add a teaspoon or sprinkle CHIA SEEDS on the pet food for high fiber and firm poop. Add your own supplements like KELP capsule for iodine, a SELENIUM to help absorption of iodine, NEEM capsule to help repel bugs, fleas, ticks. BLACK WALNUT capsule 5 days a week to kill and prevent heartworms in dogs. Sprinkle CUMIN SPICE on your dogs and cats food, helps make the blood taste bad to fleas, bugs.

    Call your local livestock feed store, many now have freezers with frozen raw ground meat, bone, organs and some carry a Raw Complete for pets with veggies, fruits and supplements added too. Look for NO HPP No high pressure pasteurization, as pasteurization kills all the nutrients and vitamins during the high heat or high pressure process.

    Learn more at VitalAnimal.com with Dr Will Falconer amazing most honest vet or DoctorDeva.com with Dr Deva Khalsa. and go to DogsNaturallyMagazine.com sign up for their free weekly newsletters to learn more about true health for your pets. These are tips your vets will never tell you because it will save your pets health which will save you on vet bills.

    • C. Woosley

      December 18, 2019 at 6:37 pm

      Thank you for the informed response.

  4. ~ Pet Owner ~

    December 12, 2019 at 4:12 pm

    The change in language (approach) may be concerning and unavoidable, but the FDA just shot itself in the foot, by admitting (by default) and in print, they have no control over rendering companies who’re supplying to pet feed companies.

    FDA’s statement that the drug pentobarbital was not used properly, is a lot more definite (by reverse logic) than referring to the potential use of it regarding the Smucker’s issue.

    Check this box [ ] how dumb can they be!!

  5. Pat Scott

    December 12, 2019 at 4:41 pm

    Make your own food for your pet, that way you will know for sure!

  6. Eve

    December 13, 2019 at 12:25 am

    “well, the FDA isn’t testing for any health hazards – because it’s not for health is it, it’s a substance to cause DEATH” so that’s another play with words remark from the FDA. NO Pet Parent would EVER feed kibble after KNOWING this why play roulette.

  7. Bonnie

    December 13, 2019 at 12:45 am

    They are sickening and killing our pets slowly day by day, and it seems like an up hill battle fighting the good fight for pet food safety….. with FDA allowing these companies to get away with it. For one, why do they not make it mandatory for all rendering companies to list who they sell their rendered meat to? We the consumers have a right to this information and FDA is withholding that information from us, by allowing these companies to keep that information out of public eye. The food manufactures they sell the rendered meat to don’t even know where the meat actually comes from..Many manufactures state on their website we sell the highest quality food….B! S! Total B!S! They are making millions, producing food that is putting our pets at risk for sickness and death. FDA just can’t be trusted for their decision making and it looks like they are held accountable to NOBODY!!! Diamond was the worst. Just look at the whole court records of the law suit on the prosecutors web site when they were being sued. Diamond had several inspections one after the other in which they failed and were warned for the same things they were sited for just months earlier. Filthy old equipment, nasty warehouse, and the list goes on and on…are they still inspecting Diamond? That’s one pet company I would never buy from because the records show even after being inspected and fined, they tried to get away with not following the citations over and over again. That tells me they will try to get away with whatever they can and they should not be trusted with the heath of our pets. How many other companies are doing the same thing, while making mega profits?
    UGH! UGH!UGH!!! It is despicable! FDA is supposed to protect!!!!

  8. Deb

    December 13, 2019 at 4:57 am

    And, once again, the FDA has shown that it is as useful as feathers on a fish.

  9. Sherrie

    December 13, 2019 at 2:38 pm

    THE FDA is useless, why are they still working. CLOSE them up for good

  10. Karen

    December 13, 2019 at 2:55 pm

    Susan, first of all thank you so much for all you do to keep us informed. Secondly, I have a question. I looked on Valley Proteins website and found the following statement I copied directly from their website.

    “Wet Pet Food Ingredients
    Produced from fresh and frozen surplus beef, chicken, turkey, pork, lamb and fish prepared for human consumption, Valley Proteins blends and processes high-quality pet food grade ingredients for wet pet food manufacturers. Developed in our USDA-inspected Mifflintown, Pennsylvania, facility, our wet pet food ingredients are used in a variety of palatable loaf, chunk and gravy pet food products.”

    This paragraph reeks of lies. How are they legally able to make such false claims. If you notice, they don’t call it “feed”, several times on their page they call it “food”. Obviously they don’t measure up to the standard of pet “food”.

    • Susan Thixton

      December 13, 2019 at 4:59 pm

      They are allowed to make false claims because no one stops them. No regulatory authority – FDA and any State Department of Agriculture – scrutinizes websites for false or misleading claims. With the respect of it being feed and they call it food – that is strictly FDA’s fault. FDA allows this.

  11. Mary Victoria Blackwell

    December 13, 2019 at 9:34 pm

    What dog food product is made by valley protein? I use Purina product for my dog and cats. Is it safe

    • Susan Thixton

      December 13, 2019 at 10:14 pm

      Valley Proteins sells ingredients to pet food manufacturers, they don’t make a finished pet food. We don’t know who they sell to.

      • Margie

        February 2, 2020 at 4:34 pm

        Susan – I wrote both Royal Canin and Purina about Valley Proteins since my miniature schnauzer is on both their prescription diets. I have received a response from both of those companies that say that neither one uses ingredients from Valley Proteins. I would be glad to share those with you if you give me an email address. Also, I would like to thank you for your advocacy. Websites like your’s provide much needed information for all of us that care about our family members.

    • chuck linker

      December 14, 2019 at 1:02 am

      what is you source?.

      email me an answer please. thanks.

      ———boxeradvertising@aol.com

    • Steve

      January 7, 2020 at 6:12 pm

      Purina has never been safe. Just read the ingredient list. It is loaded with toxic preservatives (BHA, BHT), rendered domestic animals (“animal fat”), by-products, etc.

  12. Jarod

    January 7, 2020 at 6:30 pm

  13. Leslie Pfenninger

    January 10, 2020 at 8:16 am

    Instead of a Freedom of Information Act request, draft a letter for your Congress Rep or Senator and make your request a Congressional inquiry. Those have a 10-day time limit for the agency to respond.

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