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Pet Food Regulations

Live Salmonella or Dead Salmonella – both cause illness

Have all the FDA raw pet food recalls got you a little scared? Well, something the FDA isn’t telling consumers might scare you even more (sorry).

Have all the FDA raw pet food recalls got you a little scared? Well, something the FDA isn’t telling consumers might scare you even more (sorry).

The Centers for Disease Control (CDC) states that each year 1.2 million human Salmonella illnesses are acquired in the United States. CDC estimates that food is the source for about 1 million illnesses, 19,000 hospitalizations, and 380 deaths.

Just for the month of March 2018 (through 3/27/18) there have been six raw pet food recalls, and fourteen human food (everything from mini-eclairs to coconut flour) or supplement recalls for Salmonella.

In other words…Salmonella is prevalent in all types of food, not just raw pet food.

The FDA considers a pet food to be “adulterated” if it contains live Salmonella bacteria: “FDA considers a pet food to be adulterated under section 402(a)(1) of the FD&C Act (21 U.S.C. 342(a)(1)) when it is contaminated with Salmonella and will not subsequently undergo a commercial heat step or other commercial process that will kill the Salmonella.”

Notice the FDA states the pet food product is ONLY considered adulterated if the product does not go through a process that will kill the Salmonella. Salmonella itself is acceptable to the FDA, if the Salmonella bacteria is dead. But…the dead Salmonella poses another problem in pet food – a problem the FDA is ignoring.

Live Salmonella bacteria poses a significant risk to young or old pets and immune compromised pets.

Dead Salmonella bacteria poses a significant risk to all pets – young, old, sick, and healthy.

Salmonella is a gram-negative bacteria (E.coli is also gram-negative, Listeria is gram-positive). When gram-negative bacteria are killed – through FDA’s suggested “commercial heat step or other commercial process” – the dead bacteria produce a toxin known as endotoxins. And endotoxins can cause deadly results for pets that consume them.

A 2008 study published in Critical Care Medicine looked at the effects of endotoxins in dogs. They found (bold added): “There was positive correlation (r = .844; p < .001) between plasma leptin and ghrelin levels in endotoxin-treated dogs. Endotoxemia was associated with several-fold elevations in circulating levels of stress hormones, proinflammatory mediators, and hepatorenal (kidney) injury markers.

In other words – endotoxins cause inflammation; inflammation is the foundation of disease. Science has linked endotoxins to obesity, diabetes.

From Donald R. Strombeck, DVM, PhD, Professor Emeritus, University of California, Davis, School of Veterinary Medicine:

“Endotoxin entering the body is carried to the liver where it is inactivated. Increased endotoxin levels can damage the liver. Moreover, when the amount of endotoxin reaching the liver is normal, the presence of another potential toxin can interact with endotoxin to damage the liver. The other substances are not necessarily toxins. They include vitamin A, copper and iron, and many drugs. Thus, any level of endotoxin can damage the liver. Exposure to endotoxin should be minimized as much as possible.”

Mycotoxins are stated to “aggravate exposure to endotoxins”. In a pet food industry/animal feed industry publication, regarding poultry and endotoxin exposure risk, it states that mycotoxins “increase intestinal permeability” to absorb endotoxins. Recent science (2014) found that propylene glycol – commonly used in pet foods – “increased the mortality rate in sepsis induced by the bacterial endotoxin lipopolysaccharide in mice.”

 

So…pet food consumers have a problem. Either way – live Salmonella or dead Salmonella – the bacteria causes health problems. Live Salmonella bacteria in a pet food is a problem, a serious problem that could turn deadly for some people and some pets. Dead Salmonella bacteria in a pet food is no problem for the human handling the food, but it is a problem for the pets consuming the food. Depending on the level of endotoxins, synergy with other substances in the pet food – it could also turn deadly (sepsis).

The FDA’s firm stance that ONLY live Salmonella is a risk, their lack of acknowledgement to the dangers of endotoxins in pet food – is a concern. In March of 2016, we had a meeting with FDA specifically addressing the risk of endotoxins in pet food. The agency was provided with a slew of scientific data but they refused to even begin a monitoring/testing program for endotoxin levels in pet food. I recorded that meeting…below is a short excerpt of what the FDA told us.

What can consumers do?

Send FDA and your State Department of Agriculture an email asking them to promptly establish a ‘No Significant Risk’ level for endotoxins in pet food. Endotoxins are a certain risk to pets, ignoring the problem is not of benefit to pets or consumers. You can email FDA at this address: AskCVM@fda.hhs.gov. Consumers can find their State Department of Agriculture representatives here: https://www.aafco.org/Regulatory

Consumers can also ask FDA to provide all pet food manufacturers with advice on how to prevent bacterial contamination. Currently the agency is doing little more than putting a band-aid on a large wound (with recalls). Preventing bacterial growth is the ONLY way to minimize the risk of Salmonella and endotoxins. FDA needs to become the proactive agency manufacturers turn to for advice on prevention, not the agency that ONLY contacts them to recall a product.

Ask your pet food manufacturer about preventative controls. Based on manufacturing requirements for human grade and feed grade pet food, human grade pet foods (using 100% human edible ingredients and manufactured per human food requirements) would be of lesser risk to endotoxin contamination. Human food ingredients and the manufacturing process are required to abide by preventative controls established to prevent the growth of bacteria.

On the other hand, feed grade pet food’s ingredient and manufacturing requirements are focused more on killing live bacteria – not so much prevention. But…this is not to say that some feed grade pet foods go above and beyond sourcing clean as possible ingredients and enlisting their own non-required preventative controls. Consumers can ask their pet food manufacturer what preventative controls they have in place to source bacteria free ingredients and methods established to prevent contamination before, during and after production of the pet food.

To learn more about endotoxins and how to prevent the damages of endotoxins, Click Here.

One more thing…

Opinion. It is my opinion that we are seeing so many raw pet food recalls of late because that is the ONLY style of pet food that is being tested. I believe if kibble pet foods were tested, we would not only find live Salmonella bacteria – I believe we would also find dramatic varying levels of endotoxins.

My personal opinion is that regulatory authorities believe they have the best interest of pet food consumers at heart – they honestly believe that consumers are at risk from live Salmonella bacteria and I believe THEY believe raw pet food is most likely to be contaminated.

But…my opinion is also that regulatory authorities are intentionally ignoring the significant risk of endotoxins. I personally believe that endotoxins kill far more pets each year than live Salmonella bacteria. I hope that thousands of consumers send their regulatory authorities an email asking for the risk of endotoxins in pet food to be acknowledged and a ‘No Significant Risk’ level be established.

 

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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27 Comments

27 Comments

  1. Laurie Raymond

    March 29, 2018 at 11:56 am

    Looking at kill steps is short sighted. We and our pets are part of the food chain. We as humans are obligated to discern the whole, the big picture. This means looking at agricultural practices, slaughter and handling practices, storage, shipment and processing of all ingredients going into food, especially processed food, because it is there that we are lulled into a false sense of security. Just because something is sterile does not mean it isn’t dangerous. We have permitted soil, water and air contamination to be accepted as normal. The crops and livestock we raise are contaminated. Then we selectively “enforce” safety regulations in favor of the segments of the industries with the deepest pockets (the best-paid lobbyists.) If we’re concerned about pet food safety, we have an obligation to face the implications of our whole economy’s dependence on growing industrial profits as the highest value goal. It means becoming political. But if we don’t we are just indulging in venting without assuming our proper responsibility.

  2. T Allen

    March 29, 2018 at 12:09 pm

    Thanks Susan! Can you be more specific on regulatory officials for people who may not know? maybe a tab on your page of references? Titles, departments and form letters? Would make it easier to get more people to get involved. 🙂 We have to address this issue! Maybe with the help of Truth about Pet Cancer enough money can be raised for an independent study on this? We know this is a contributing factor!

  3. Pet Owner

    March 29, 2018 at 1:37 pm

    But it’s an even deeper question now. Raw food is more bio-available, but the Salmonella risk is high. We know companies aren’t batch testing everything. And if they’re high pressure processing, then what’s the point of raw? Canned wet food has endotoxins, which sounds like a build-up isn’t too good either.

    So were back to feeding our dogs, human grade quality protein, cooked to a safe temperature … right? But then my pet supply person said, feeding cooked meat that way to a dog, can be detrimental to their digestive process over time.

    What do we do?? Actually, is dehydrated (THK) the safest alternative at this point?

    • T Allen

      March 29, 2018 at 3:22 pm

      Couple of thoughts. The endotoxins in pet food are at very high levels because of the use of 4D meat. Human grade/ grocery store meat won’t have those high levels but will have more live “bugs”. Cooking meat to a high enough temp to kill those bugs may not be “perfect” but is better than getting sick. Think about this… we’ve been eating cooked meat and living to 80-100yo for a long time. Between vaccine over use, pesticides and toxins in the food and environment, I think cooking meat for our pets is the least of our worries. Especially if a healthy blend of other vegetables, fruits and herbs are fed as well. There is a lot of research in using herbs to protect the liver and kidneys in people and animals. You can’t use them safely in cats without a vet’s help but for the most part if it’s safe your your child it’s safe for your dog. And no, THK isn’t necessarily better because it’s too high in carbs fed as is. Mixing at a level to decrease carbs decreases the amount of vit/min etc. No great answer right now but we are working on it! Follow Rodney Habib and Karen Becker on FB, ( just don’t click on ads!) 🙂 Planet Paws Or the website https://www.planetpaws.ca/.

    • Laurie Raymond

      March 29, 2018 at 9:48 pm

      Healthy dogs and cats can handle a bacteria load that would kill us! And for all the raw recalls, you don’t hear about dogs or cats actually getting sick. And meat for human consumption, commodity meat from the grocery store, is likely contaminated with the same bacteria, but passes because it is assumed it will be cooked. I have used Vital Essentials for many years and never had a problem, but because of FDA zero tolerance, they are going to HPP, and I have been working to line up local farmers from whom I can buy direct. I am absolutely convinced that raw is the way to feed dogs and cats. For those who are severely immuno-compromised, you can feed raw that has been treated to a kill step: HPP or bacteriophages or fermentation. But what we need to do is to reform agriculture so that pathogenic bacteria are not ubiquitous in soil, water and livestock. The farmers who are already growing clean, humanely raised animals deserve (and truly need) our support! And by the way, I haven’t seen any studies, but the fat in cooked meat creates a serious risk of pancreatitis in susceptible animals. The Ketopet Sanctuary, which has had amazing success with ketogenic diets for dogs with cancer, insists on feeding everything raw. And many of these dogs are immune compromised, but they respond beautifully to the raw diet.

      • Pet Owner

        March 30, 2018 at 2:28 am

        If Vital Essentials goes to HPP, how much less valuable will it be as a raw food? It was the last frozen raw brand left that didn’t do the kill step.

        • T Allen

          March 30, 2018 at 9:23 am

          If you want to feed raw and take the chance with disease at least feed human grade, store bought, meat. It’s still contaminated but less so than the rejected garbage that goes into pet foods! I buy directly from a USDA slaughterhouse that I am comfortable with. He feeds his own dogs the same ground product he sells to us. This is the only way I feed raw with no kill step. The new superbugs that have developed in the last 50 years from overuse of antibiotics and keeping animals on the same land without rotation will kill and seriously injure people and pets. Search http://www.foodsafetynews.com/ for your “bug” of choice.

          • Pet Owner

            March 30, 2018 at 11:16 am

            Okay. What you’re saying here, makes sense too. I understand (all too much) quality must exist first. So when you buy locally how do you balance the raw meat, is it already ground up (organ, bone, nutrients). Do you know of any sustainable ranchers in the Northern California area? SFRAW in the Bay Area is a great option, but I’m 2.5 hours away.

          • T Allen

            March 30, 2018 at 3:59 pm

            I’m in Maine so I can’t help locally. 🙂 But I also buy meat products, including a premixed ground raw chicken that has not been through a kill process from a company called Hare Today Gone Tomorrow. https://hare-today.com/ They ship frozen, country wide. They are a small company that kills/processes themselves and buys from local farms. I have never had any concerns about their products and they have been around for years. You do need to order at least 50# so it stays frozen and keeps the price down but if you have room for a small chest freezer (<$150) it's much cheaper to buy in bulk and you can pick up several turkeys cheap at the holidays (.69/#! ) and feed them too. Hope this helps. It's not easy keeping your family safe anymore.

      • T Allen

        March 30, 2018 at 7:09 am

        “Healthy dogs and cats can handle a bacteria load that would kill us!” Do you have research that shows that? No. That’s a myth. Superbugs kill pets and people. “And by the way, I haven’t seen any studies, but the fat in cooked meat creates a serious risk of pancreatitis in susceptible animals.” You haven’t seen any studies because there aren’t any. Another myth. RANCID fat, like that in 4D dog food can cause diseases. KetoPet does NOT feed raw to all dogs. They use HPP in severely health compromised dogs because of the potential for disease from raw meat. I totally agree with your overall premise but touting myths does not help the raw cause. Truth heals, myths can kill.

        • Pet Owner

          March 30, 2018 at 11:09 am

          Wow. Thank you so much for clearing up those myths! I was about to go down the dark rabbit hole with Laurie. But now, I don’t feel so bad about continuing to use Vital Essentials. Because they will be (at least) controlling pathogens if they employ HPP. And I do get worried (always) about too much / unbalanced fat triggering a problem in a dog.

          • T Allen

            March 30, 2018 at 4:06 pm

            Do you follow Rodney Habib/Planet Paws/Truth about Pet cancer? They are studying ketosis in dogs to cure cancer. It uses more fat, less protein, and minimal carbs. But you do have to be careful about too much fat in the presence of too many carbs. It’s complicated. Check out their FB pages and websites for more details. (FB is safe if you don’t click ads! In 4 four years I have had 5 companies get any info on me.) 😉

    • Chelsea Joyner

      March 30, 2018 at 12:12 am

      Dehydrated is becoming a popular alternative. Most of the benefits of raw, but the dry form everyone thinks they have to have now. There Is a heating process tho kill bacteria and such. You still have to make sure of the QUALITY and FRESHNESS of ingredients. That is how you are going to avoid endotoxin. Of course the pet supply person told you it would cause problems. His/ her mod is to sell you food. Most of them don’t even know what is in it.

    • Christine

      April 4, 2018 at 7:33 pm

      Trouble is, meats meant to be consumed by humans can have high bacterial counts as it’s assumed we’ll be cooking them, which is a kill step – this leads you right back to endotoxins. Some comercial raw food manufacturers test ingredients as they come in, and certainly before they go out. That’s a much bigger reassurance than anything, as they’re insuring there’s not a big bacterial load when it hits the market. So many of these raw food salmonella recalls have even tested negative by the manufacturer, and if FDA finds any, often follow-up testing by the food manufacturer finds nothing in other samples if the same batch. This says to me that there’s not enough bacteria to create an endotoxin problem even if there is a kill step, and unlikely to make any animal sick, which is why I still favor commercially made raw foods for safety. They’re generally testing and know they’re under scrutiny, unlike grocery stores selling meats for people, or kibble manufacturers.
      We should be asking all of our manufacturers if they test for bacteria *before* processing, which I’m sure most don’t. I would like to assume that THK is doing this, but I’ll have to ask.

  4. Laurie

    March 29, 2018 at 4:24 pm

    Hi Susan. Laurie here with White Rock Pet Food Delivery in Dallas. I’d like to ask your opinion. Many of the raw manufacturers have instituted HPP with their poultry products. I personally do not like HPP but that’s a side note.
    I know that a year or so ago, Rad Cat began HPP with their poultry products and last week they had a recall on one lot of turkey and one lot of chicken. If HPP is such a “great” thing and is suppose to eliminate pathogens that might be present in raw poultry, why did the HPP treated Rad Cat have Listeria Monocytogenes? Thank you for your opinion and thank you for what you do. Kind regards … Laurie

    • T Allen

      March 29, 2018 at 7:39 pm

      Hi Susan- I can only speculate as to the cause of the problem but I can tell you from experience that contamination can happen in a processing facility after the “kill” step (assuming the kill step was performed correctly) . The fact that that happened is extremely concerning and indicates either a serious break down in the processing or sanitation procedures as well as their quality control and testing program. OR HPP if done correctly kills all “live” “bugs” but if the product is not handled properly afterwards (frozen below zero or kept cold and used quickly) any spores left over can regrow. That could be caused by leaving it in hot trucks, etc. “Hold and test” before shipping is critical for these raw pet food producers. I hope they figure this out soon!

      • Christine

        April 4, 2018 at 7:39 pm

        Yes, but Rad Cat does a full plate count after they test and hold. They test all of their surfaces for listeria as well – I’ve been in their kitchen and I’ll tell you it’s spectacular and their safety protocols are multilayered. If only my human meats were handled so safely! I own a pet supply store and we even test the surface temperature as raw food enters our doors to make sure the food hasn’t been compromised during delivery from our distributor, and we turn food away that feels like it’s been thawed a bit and refrozen (nuggets sticking together at all, etc). It honestly makes me question FDA testing protocols – are they testing with sterile equipment and handling the samples well after testing? How are their surfaces?

        • T Allen

          April 4, 2018 at 9:13 pm

          Wow! That’s impressive! It’s good to know someone is trying to do it right. It must be really hard with the meat coming in being contaminated from the start. Kudos to you for testing product temps on delivery. That is the only way to keep the middlemen on their toes when making deliveries of perishable items! Thanks for letting us know about RAD cat!

  5. marlene salter

    March 29, 2018 at 5:02 pm

    I am so very heartsick over what the animal food manufacturers get away with & I wish they could be dealt with commensurate with what they do to animals.

  6. chimonger

    March 29, 2018 at 8:38 pm

    Be careful what you ask for. Has pet food been irradiated yet? Human foods are, more often than we’d like to know.
    Irradiation is NOT what you want the industry to do to pet foods, any more than we’d want it for human foods!
    Unfortunately, irradiation of human foods has been aided and abetted to remain covert; that is, loopholes like “any food that has been processed, does not have to label that it’s been irradiated for longer shelf-life”.
    That means, that wording allows user-definition of “any food that’s been processed”…into “simple water washing at the edge of the field, to knock off the dirt, has now been termed “processed”.
    Therefore, it can now be irradiated to lengthen shelf-life, and Not be labeled that it’s been done…even on organic produce in some instances. Irradiation ruins nutritional content. It certainly destroys almost all antioxidants, which humans require to live decently.
    So, you want that for pet food, too? With human nutritional deficiencies at such all-time highs for a few generations, that now nutritionally caused bone deformities are called “normal”?
    I don’t think so.
    Pet food industries need some good suggestions from consumers, on how to fix the problem of toxins and germs in foods, since they have not figured it out themselves.

  7. Lorraine Birish

    March 30, 2018 at 3:01 pm

    thank you Susan, your video says a lot about the state of all matters concerning humans and pets. bottom line is the dollar. it rules.

    • T Allen

      March 30, 2018 at 3:59 pm

      Amen to that!

  8. Jeanne Anne Hensley

    April 1, 2018 at 1:39 pm

    While all of this is extremely important and the need for a total overhaul of our agriculture system in general, and specifically, in these cases, animal production and processing, keep in mind that a good quality colloidal silver will protect your pets (and yourself) from these pathogens. This includes, E Coli, Salmonella, Listeria, and the like and can save your pet from Parvo and other health concerns. I know, I’ve used it for many years with family, my dogs, cats, goats and chickens as well as wild animals that were injured in some way. Keep some on hand, always. As well, Vitamin C will help. Yes, most animals do make their own C but in cases where they are overcome with pathogens and in the state that most animals (and people) are in these days, they often simply produce enough to protect them from serious illness and resulting death.

  9. Jeanne Anne Hensley

    April 1, 2018 at 1:41 pm

    EDIT: typo alert…..”…they often simply cannot produce enough to protect them from serious illness and resulting death.”

  10. Marsha

    April 2, 2018 at 3:18 pm

    So many things that the FDA overlooks for our pets. Wish they wouldn’t, but then they do not know that our pets are family. Some of us only have pets, no children. Thank you for all you do Susan.

  11. Seth

    April 3, 2018 at 10:06 pm

    Wow that is disappointed that the FDA. Doesn’t care pet/animal health. They would rather beat around the bush. Why are they so incapable of doing what’s right. Can’t they follow the law and not pick and choose what they will do

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