A not so clinical (but evidenced) diagnosis: the FDA suffers from raw pet food phobia.
In the late afternoon on Friday February 14, 2020 the FDA issued another warning to pet owners about a raw pet food.
These FDA consumer warnings on raw pet food have become quite common. Since May 16, 2016 the FDA has issued 18 consumer alerts regarding pet products. Nine of those alerts – or 50% – were regarding raw pet food. Another vital statistic that needs to be considered is that raw pet food only consists of “about 1.3 percent of all sales” (all pet food sales).
So…why would 50% of all FDA pet product consumer warnings be specific to ONLY 1.3% of the pet food market?
The FDA’s attitude is that raw pet food is dangerous; the Agency’s main concern with raw pet food is pathogenic bacteria such as Salmonella. The FDA’s opinion is that these consumer warnings validate their concern of raw pet food (‘see, we told you it’s dangerous’). But, do the warnings and FDA scrutiny of raw pet food validate a legitimate concern or instead, does the action of FDA confirm the Agency’s deep, irrational fear (phobia) of raw pet food?
There is no evidence that confirms FDA’s belief raw pet food is more dangerous than other styles of pet food. In fact, the evidence indicates that overall – raw pet food is LESS of a risk than meat purchased in your grocery.
The USDA (regulatory authority over raw meat) allows 25% of all ground poultry products sold in your grocery to be contaminated with Salmonella. An FDA study of raw pet food found only 8% of samples were positive for Salmonella. In other words, millions of human food consumers that shop for meat are 3 times more likely to be exposed to Salmonella than 1.3% of pet owning consumers that purchase raw pet food.
The FDA attempts to validate their raw pet food fear by stating “animals can shed the bacteria in the feces when they have bowel movements“; this statement was included in several of the raw pet food warnings including the most recent. However, the study FDA bases this raw fed dog poop irrational fear on found that ONLY 2.5% of dogs and LESS THAN 1% of cats shed Salmonella in their poop. This means that every day – millions of human food consumers shopping for meat in your grocery are 10 times more likely to be exposed to Salmonella than dog owners picking up their pet’s poop, and 25 times more likely to be exposed to Salmonella than a cat owner cleaning the litter box.
To further validate the FDA suffers from raw pet food phobia, is the statistical evidence of pet food recalls since 2012. Taken from FDA Enforcement Report records:
Based on historical recall records, kibble is 75 times more likely to be contaminated with Salmonella than raw pet food, kibble is three times more likely to be contaminated with Salmonella than raw meat purchased in your grocery.
As further evidence that FDA suffers from an irrational fear of raw pet food: the Agency has repeatedly manipulated inspections and testing procedures to validate their phobia. Multiple raw pet food companies – which recalled their products or FDA issued a warning about – were denied access to required documents and split samples (including the most recent pet food FDA issued a warning about).
From the FDA document Food/Feed Testing Laboratories Best Practices Manual, under Chapter 4 Sampling, Best Practices it states:
“Sampling often begins with routine collections for surveillance purposes, food safety inspections, monitoring studies or as a response to a complaint. Samples collected may include investigative, documentary, emergency response, law enforcement, research or convenience samples. If there is any possibility of future regulatory action, official samples should be collected in a manner that will assure legal defensibility. The essential characteristics of a valid, official sample include ensuring that the sample contains a representative portion of the lot, sampled in a manner that assures it is not changed in its physical, chemical or biological nature from the whole. In addition, the sample should be collected, preserved and handled in a manner consistent with the intended testing. Also, any required sample reserve portions should be collected and the sample should be accompanied by accurate records that legally establish its identity, responsible individuals and chain of custody.”
In MANY cases – including the raw pet food FDA just issued a warning about – the above sampling procedures were not followed. Chain of custody documents – required by regulation to be provided to the pet food manufacturer – have been denied time and time again. Split samples (“sample reserve portions“) have been refused to be provided to the raw pet food manufacturer. And in at least one case (Rad Cat), we know that the sample was NOT preserved or handled to assure sample integrity (the raw pet food was transported to the lab on the seat of a car in July).
The unfortunate consequences of FDA’s irrational fear of raw pet food is an unknown number of other issues in pet food are being ignored. The FDA spent three quarters of a million dollars ($758,000.00) just to test raw pet food in 2015. Yet the Agency tells the public they don’t have the funding to properly enforce law in pet food; “Why doesn’t FDA enforce every violation of the law? Due to competing priorities and resource limitations, government agencies cannot act against every violation of the law.” While FDA spends three quarters of a million dollars to test 1.3% of the pet food market, they ignore the risks of illegal ingredients sourced from diseased animals and animals that died other than by slaughter used in perhaps 80% or more pet products.
Let’s hope the FDA seeks treatment for their raw pet food phobia.
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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Audree
February 18, 2020 at 12:54 pm
It’s time for the manufacturers of raw foods to work together as a cohesive force to educate the public and the FDA about actual benefits and risks associated with feeding a raw diet. Each time the FDA issues a “recall” or warning, the only response issued is from the affected company. How much more powerful would it be if their raw food colleagues spoke up in support of the affected company.
J. U.
July 14, 2020 at 11:55 am
I have to disagree with raw sales only making up 1.3% of pet food sales. “ In addition, the overall dry category declined by -4.9% YOY in 2019, mainly due to a -9.2% drop in traditional dry pet food sales, while what Lange called “preserved” foods (freeze-dried and dehydrated) soared 39.1%. On the other hand, wet pet food sales overall grew by 5%, fueled by a 55.4% boost from “fresh” categories such as frozen and refrigerated. At the same time, traditional, shelf-stable wet pet food decreased by -1.8%.” https://www.petfoodindustry.com/articles/8860-us-pet-food-market-grows-7-despite-grain-free-decline. I think raw (to include freeze dried, dehydrated, frozen, and fresh) is likely making up close to 10% of the market now (I know the data above also includes fresh/frozen cooked, but there is no way to break it out). I believe the inspections are making a concerted effort to keep this line of food in the proverbial Pandora’s box. It’s too late. Fresh raw/cooked is too big of a market share. This data doesn’t even include online direct to consumer sales (i.e. Darwin’s, My Pet Carnivore, Raw Paws, etc.). The FDA doesn’t have enough inspectors to handle the number of fresh pet food manufacturers that have sprung up over the last five to ten years. They are playing catch up. Just wait until the next “Vitamin D” incident, then the inspectors will have their hands full as well as an even bigger increase in fresh pet food sales as result. They won’t have time to mess with raw pet food manufacturers. Eventually, Mars, Smuckers, Nestle, Hills, General Mills (now they own Blue Buffalo) will start buying up fresh pet food companies like Freshpet then move on to raw once enough of their profits are eaten up by the fresh pet food industry. You’ll start seeing studies coming from them about the benefits of raw/lightly cooked pet food. It’s coming, slowly, but it’s coming. They are already making changes to some of their treats/food, removing dyes and colors and chemicals due to consumers. It’s not going to happen overnight, but it’s going to happen.
Cannoliamo
February 18, 2020 at 12:54 pm
I noticed that too. Unfortunately, FDA doesn’t know anything about raw pet food that AAFCO hasn’t told them. The following is the AAFCO warning about raw pet food ……. (They blame pet owners for improper handling and the increased contamination risks)
https://talkspetfood.aafco.org/rawfoods
“Retailers may sell raw pet foods; however, the majority of complete pet food products are not raw. They have been heat-treated during manufacturing to prevent microbial contamination. Pet food manufacturing plants often have limits regarding the receiving, storing and use of ingredients that make most raw ingredients impractical.
“However, consumers should be aware of raw-food handling practices. Most raw (or undercooked) pet food consists of meat, ground bone, organ meats, raw eggs, vegetables or fruits and some dairy products. Because of these raw ingredients, there has been an increased concern for cross-contamination of bacteria, such as salmonella, to humans. These bacteria may pose a danger to the people in the household, especially children, the elderly and those with poor immune systems. Although dogs and cats may be more resistant to these bacteria, they are not immune and can become very ill.
“Whether preparing a family meal or pet food, bacteria is always an issue. Safe kitchen food-handling practices for raw animal products apply. For example, a dog bowl full of raw hamburger raises several concerns that need to be considered. Can children reach the dog food? Does the uneaten raw hamburger go back in the refrigerator? Is the bowl ever washed and cleaned? How often? What about what is spilled on the floor?
Additional precautions need to be taken to protect humans from accidental contamination or ingestion.”
T Allen
February 18, 2020 at 1:36 pm
Excellent! Just what the public needs to hear and the FDA is trying to hide. Another GREAT reference article! Thank you Susan!
Janet Wasserman
February 18, 2020 at 1:51 pm
This is one point on which I absolutely disagree with Susan Thixton. I reserve the right to investigate both scientific and non-scientific claims regarding the safety of raw pet food. To focus on the FDA’s sampling and testing misses the point for raw pet food just as it would for any regulatory agency’s investigation of human food.
Readers, like myself, may believe that the good work that Ms. Thixton does should not extend to her personal biases and preferences. Advocates for any cause should tread lightly on issues even where they rightly or wrongly disagree. There is much that is wrong with the current state of government regulation as it is nearly all being thrown out by the White House and Cabinet officers.
If this is Ms. Thixton’s personal blog, she can say whatever she wants. But her credibility is at stake regarding other issues when she attacks the FDA, an agency we should try to save from budget cuts and eventual weakening so as to be eliminated. AND we need a far better understanding of raw pet food in a nation as large as the USA with government oversight having the FDA and CVM in its gun sights.
These agencies need to be greatly improved with budget increases, hiring more scientific and field staff, and doing better outreach to the public. These may not happen under the current administration or in its reiteration in a following term. As a pet owner with a compromised immune system and a dog just diagnosed with Cushing’s Disease (or Syndrome), I rely on the veracity and honesty of human and veterinary medicine as well as on the best practices in the realms of pet nutrition, pet food production, pet food preservation, and pet food distribution. This is a tall order but why lose followers when one’s own biases take over the discussion?
I am ready to pick and choose the issues of interest to pet owners like myself without the drama. What does one say to a pet owner whose pet has consumed tainted food and become sickened and/or died? You’re just 1.3% of the market , so … sorry? Ms. Thixton rightly underscores “diseased animals and animals that died other than by slaughter used in perhaps 80% or more pet products.” Those regulations need to be changed and attending AAFCO meetings won’t do it … unfortunately. In my view there needs to be a concerted citizen political movement to effect legislation that would correct these damaging rules in place. Thank you.
Susan Thixton
February 18, 2020 at 1:56 pm
We’ll have to agree to disagree Janet. The FDA is solely to blame for FDA’s lack of enforcement of law – they alone choose to ignore food safety law. I believe FDA’s lack of enforcement of law needs to be well known by all pet owners. And, I personally won’t stop sharing that information until FDA enforces law. The only bias I have is against all those that ignore law putting millions of pets (and people) at risk.
Colleen
February 18, 2020 at 4:22 pm
My cat has been eating raw diet for 10 years, he’s never been sick from it, nor I.
When he ate kibble and wet, before switching to raw, he was made sick 3 times, with high fever.
I will never go back to feeding that commercial so called less harmless crap.
Kathrynne Holden
February 18, 2020 at 5:57 pm
Thanks once again Susan for providing us with important information to help our pets.
Beverly Moore
February 18, 2020 at 7:22 pm
My cat eats raw. She eats mice lol. She is a barn cat.
Bob
February 19, 2020 at 8:49 am
Does the FDA validate a legitimate concern, or do they have a phobia, of raw pet food? Neither. What they have are big pockets that are being filled by Big Pet Feed(oops, I meant Pet Food)companies that can bribe/influence the FDA to perpetuate the lousy pet food industry. Along with what seems to be no concern at all for the health and well being of animals, their only concern is perpetuating their current status quo in order to keep their cushy government jobs.