Investigation documents provides concerning information about No-Hide Dog Treats.
A Freedom of Information Act (FOIA) request was submitted to Pennsylvania Department of Agriculture (PDA) on January 10, 2019. We asked for all records relating to the PDA investigation of Earth Animal No-Hide dog treats. The request was recently received – 100% paper documents (no digital) in an envelope that was 3 1/2 inches thick. In other words, a lot of documents were provided.
Before details of the FOIA are shared, I want to thank Pennsylvania Department of Agriculture (PDA) for the detail of documents provided, the detail of their investigation, and the fair cost of this FOIA. Many states send very little information and charge exorbitant fees for FOIA documents (Missouri Department of Agriculture charged $323.18 for 10 fake pages of records and 14 emails in 2017). I appreciate your fairness in fees and the detail of information provided. Other states could learn a lot from Pennsylvania.
Pennsylvania Department of Agriculture Investigation
No-Hide dog treats and rawhide should be very different products. The potential similarities and differences between the products was the foundation of the PDA investigation. Is the No-Hide dog treat a basted piece of Chinese rawhide or is the No-Hide dog treat made from gelatin and rice flour (and a few other ingredients) as the label indicates?
Quote from Pennsylvania Department of Agriculture email to FDA (obtained in the FOIA):
…from the beginning we’ve treated this investigation as a misbranding investigation so our purpose was to determine if the no hide chews were being misbranded and instead the company was substituting all of these rawhides and just calling them no hide chews.
Click Here to read email exchanges between PDA and FDA received in the FOIA.
Pennsylvania Department of Agriculture (PDA) did not find misbranding of the No-Hide dog treat. There was no enforcement action taken.
Thanks to this Freedom of Information Act (FOIA), pet owners can decide for themselves – whether the No-Hide dog treat is rawhide or not – when they look at the evidence provided.
Manufacturing of No-Hide Dog Treat
Earth Animal is the company No-Hide dog treats are sold under. The treats are manufactured by Pony Express Foods which has two locations in Pennsylvania; 1016 E Main St., Blue Ball, PA 17557 and 121 Jalyn Dr. New Holland, PA 17557. The company manufacturers a human food jerky and the No-Hide dog treat for Earth Animal. Under the Pony Express Foods umbrella, multiple pet products are sold including bulk sales of rawhide imported from China (stated by Pony Express Foods).
The documents provided in the FOIA explain that No-Hide treats are made in two steps. One is mixing a dough of base ingredients, dough is rolled into treat shape, and baked. Step two following baking, the treats are “hand coated” with a meat slurry and baked again. (To read a full description of the baking process by a consultant to Earth Animal, Click Here. This same document was provided in the FOIA – provided to PDA by Pony Express Foods.)
The concerning issue is: Pony Express Foods also imports large loads of rolled rawhide from China. Emphasis – rolled rawhide from China. Received in 11 inch pieces that appear to be remarkably similar in appearance to un-coated No-Hide.
As evidenced by photographs provided in the FOIA, Pony Express Foods imports rolled rawhide from China. The Chinese imported rolled rawhide pieces are received in the exact same size – 11 inches – as the manufactured No-Hide treat.
To view the FOIA pages of the above pictures, Click Here.
Pony Express Foods explained to investigators that the similar shaped and size rawhide imports are sold in bulk at the Green Dragon Farmers Market, 955 N State St, Ephrata, PA (open 1 day a week – Friday). Pony Express provided multiple bulk sale cash receipts to investigators, however each cash receipt neglected to provide the purchaser’s name (for verification purposes). More than 50 pages of cash receipts were provided in the FOIA, some of those are provided here.
Some import documents were provided in the FOIA, including an invoice for $51,168.00 from Shanghai, China for 96,000 rawhide dog chews. Click Here to view.
From external import records (not provided in the FOIA), Pony Express Foods imported more than 900,000 pounds of rawhide from China during 2018.
PDA took samples of the No-Hide raw un-baked dough, finished No-Hide dog treat samples, and Chinese rawhide samples from the Pony Express manufacturing facility. PDA also purchased No-Hide dog treats from retail and from Amazon. And PDA purchased rawhide dog treats from retail and from Amazon for comparison testing.
Protein and Starch Testing
The Pennsylvania Department of Agriculture (PDA) protein and starch testing results of a raw dough No-Hide dog treat found the product contained 19.23% protein and 24.7% starch. In a pie chart those results look like this:
Comparing ‘apples to apples’, PDA tested a No-Hide treat that was baked – but with no meat coating applied. This test product would be the same type as the above dough No-Hide, only testing the product after it was baked (two different samples – one dough, one baked). The sample – ID: D201800406 – was “collected out of the bin at the batter adding station.”
After baking, a dramatic change in analysis occurred. Protein content increased in the No-Hide treat by almost 373%. Starch content decreased by 99%.
A dough – when cooked – will certainly change in analysis. A dough is heavy in moisture. Thus when the moisture is removed through baking, the ‘numbers’ change. But should the ‘numbers’ have changed so dramatically in the No-Hide treat from dough to baked?
Notice that the starch percentage changes from dough to baked on both products were similar. The puzzling difference is the protein percentage change. With moisture removed (through baking), the protein content of bread only increased 33%. The No-Hide baked (and un-coated) increased by more than 372%.
Was the un-coated No-Hide – ID: D201800406 that was “collected out of the bin at the batter adding station” actually a piece of rolled rawhide imported from China? Does this possibly explain the dramatic increase in protein?
Unfortunately, the Pennsylvania Dept of Agriculture (PDA) FOIA documents gave no explanation for this dramatic change in protein content. But, PDA did analyze one of those rolled pieces of rawhide imported from China found at the Pony Express No-Hide manufacturing facility. Side by side comparison pie charts below: a baked No-Hide taken from the “bin” at the manufacturing facility and a rolled rawhide taken from one of the boxes in the trailers in the parking lot.
The lab analysis of a Baked No-Hide treat is almost identical to the analysis of the Chinese rolled rawhide treat removed from the trailers in the parking lot of the same manufacturing facility.
Click Here to read all of the protein and starch testing results provided in the FOIA.
Histologic Evaluation Penn State Animal Diagnostics Laboratory
PDA also sent two samples of No-Hide treats and two samples of Rawhide treats to Penn State Animal Diagnostics Laboratory for Histologic Evaluation. The lab analysis failed to find a difference between No-Hide and Rawhide. The “Conclusions and Summary” of this analysis stated:
The analysis performed was not able to determine whether or not animal hide (skin and related structures) is present in the samples examined. It appears that the commercial processing of the animal products has so badly damaged the integrity of the original tissues that they are no longer identifiable by this method.
To read the full report from Penn State Animal Diagnostics Laboratory provided in the FOIA documents, Click Here.
Histologic Evaluation Illinois Veterinary Diagnostics Laboratory
Also provided in the FOIA documents was a Forensic Pathology report from Illinois Veterinary Diagnostics Laboratory. One report was provided on No-Hide Salmon Chews and another was provided on “Dentley’s Rawhide Rolls”.
Dr. Adam Stern of Illinois Veterinary Diagnostics Laboratory report stated “Based on my evaluation of both products, I suspect that the product from #17-217 (No-Hide Salmon Chews) is composed to material similar to that of #17-279 (Dentley’s Rawhide Rolls).” The Illinois report provided these slide images comparing the two dog treats:
To read the Illinois Veterinary Diagnostics Laboratory report on No-Hide, Click Here. To read the Illinois Veterinary Diagnostics Laboratory report on Dentley’s Rawhide Rolls with comparison to No-Hide, Click Here.
Various Inspection Reports and other FOIA Documents
To read the 8/29/18 “Inspector Narrative” report, Click Here.
To read the 9/18/2018 “Inspector Narrative” with images of No-Hide ingredients, Click Here.
To read the 9/21/18 PDA inspection report, Click Here.
To read the 10/9/18 PDA inspection report, Click Here.
To read the 10/24/18 “Inspector Narrative”, Click Here.
To read the 12/4/18 PDA inspection report, Click Here.
To read emails between PDA and Pony Express Foods regarding the trailers that stored the imported rolled rawhide, Click Here.
To read email questions from Pony Express Foods (regarding inspection) to PDA and the PDA response, Click Here.
To view various images provided in the FOIA including more pictures of the shipments of rolled rawhides from China and pictures from the Green Dragon Farmers Market where (reportedly) bulk rawhide orders are sold, Click Here.
And after reading all of the details of investigation from Pennsylvania Department of Agriculture (all of the above), Click Here to read the minimal FDA inspection report.
Many of the documents provided in the FOIA are significant information for pet owners to be alerted to. One of the most significant statements made by Pennsylvania Department of Agriculture was the following (made to FDA):
“Our hypothesis is that the no hide chews are starch-based and will show a significantly higher level of starch when compared to the Rawhide samples and the histological analysis will hopefully show the difference between a no hide starch-based treat and a pure hide treat.”
Pennsylvania found the complete opposite of their hypothesis. Starch was almost non-existent, and protein content and histological analysis was almost identical to rawhide. Repeating two images from above:
While I appreciate the depth of the Pennsylvania Department of Agriculture investigation (especially when compared to FDA), I remain baffled that the agency closed the investigation taking no action.
Regardless of PDA’s lack of enforcement action, the investigation of No-Hide dog treats performed by Pennsylvania Department of Agriculture benefits pet owners. From a wealth of Freedom of Information Act request documents, each pet owner can decide for themselves what this product is.
Wishing you and your pet(s) the best,
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