A suggestion…just as restaurants receive ‘grades’ of their Health Department inspections, and the grades are public information, pet food manufacturing inspections need to be graded and made public. Grading could be the only way to motivate pet food manufacturers to clean up their plants and follow proper Good Manufacturing Practices.
Below are excerpts from a 2005 FDA Inspection of the South Carolina Diamond Pet Food manufacturing plant (the same plant that was the source of dozens of recalled pet foods earlier this year)…
“Firm’s written procedures require each shipment of incoming corn shipment be checked for aflatoxin. Records for the Aflatoxin testing of incoming whole corn did not always document that the tests were done or that the [ REDACTION ] test was performing properly.”
“As per the firm’s written procedures, retention samples of all bulk materials (including whole corn) are to be collected. Over 50% of the retention samples of incoming whole corn shipments from Sept. 1, 2005 to Nov. 30, 2005 are missing. Quality Control personnel who are responsible to ensure the collection and storage of retention samples failed to notice the retention samples were not being collected or were missing.”
“Accepted incoming bulk feed ingredients do not always meet the firm’s ingredient specifications. Some of these ingredient specifications include ranges for protein, moisture, fat, ash, and fiber. The five listed specifications are checked by Near InfraRed Spectroscopy (NIR).
A. 17 of 21 accepted shipments of wheat flour failed three or more of the five specifications tested by NIR.
B. All five accepted shipments of rice bran failed four out of five specifications tested by NIR.
C. Six of seven accepted shipments of Chicken By-Product Meal (Low Ash) failed all four specifications tested by NIR.
D. There was no documentation of NIR test results for whole corn for 2005.”
If this pet food manufacturing plant inspection was graded as a restaurant would be, we can safely assume this FDA inspection would have provided the Diamond Pet Food manufacturing plant a failing grade. What if, back in 2005, that failing grade of inspection, similar to the inspection grades of restaurants, was required to be posted on the websites of all the pet foods manufactured there? Even further, what if that failing grade was required to be posted on the labels of pet foods manufactured at this pet food plant? Do you think this would have caused the Diamond South Carolina manufacturing facility to clean up its act?
Of course this didn’t happen, the inspection report of 2005 which showed this South Carolina Diamond pet food plant did not follow written procedures for testing pet food ingredients, never became public information (other than for those willing to dig around on the FDA website in search of FDA Form 483 information). No passing or failing grade was posted anywhere, alerting pet food consumers to the concerns of manufacturing at this pet food plant.
Instead, seven years later the same pet food plant had another inspection (the result of a positive Salmonella testing) which show the plant doesn’t appear to be following proper Good Manufacturing Practices. The following are excerpts from the 2012 FDA Inspection Report of the very same pet food plant…
“All reasonable precautions are not taken to ensure that production procedures do not contribute contamination from any source.”
“Failure to maintain equipment, containers and utensils used to convey, hold, and store food in a manner that protects against contamination.”
“Failure to maintain equipment so as to facilitate cleaning of the equipment.”
Maintaining equipment and ‘reasonable precautions’ to prevent contamination are basic Good Manufacturing Practices. Seven years later, the Diamond Pet Food South Carolina plant basically repeated the very same issues they did in 2005, they did not follow written Good Manufacturing Practices.
FDA has for years stated they cannot inspect everything/everywhere. They continue to encourage industry to self-regulate. At the January 2012 AAFCO (Association of American Feed Control Officials) there was discussion of ‘third-party facility certification programs’ for pet food manufacturers and pet food ingredient suppliers. This ‘discussion’ was publically announced by the American Feed Industry Association (AFIA – trade organization representing the “U.S. animal feed industry and its suppliers”) a few days later. From a January 24, 2012 press release “AFIA announced a new third-party facility certification program designed specifically for manufacturing pet food and pet food ingredients. The Pet Food Manufacturing Facility Certification Program (PFMFCP) and the Pet Food Ingredient Facility Certification Program (PFIFCP) were developed by AFIA’s pet food and quality committees with input from third-party food safety experts. “AFIA sees this as a model program for the entire pet food industry,” according to Joel G. Newman, AFIA’s president and CEO. “I commend the pet food committee for developing this program to help ‘raise the bar’ for their own industry.”
But does an industry developed inspection program really ‘raise the bar’ for pet food safety?
Beginning in the fall of 2011, a cantaloupe Listeria outbreak caused the deaths of 30 people. Their deaths were painful and preventable. Attorney and food safety advocate Bill Marler stated to CNN “Listeria gets into the bloodstream and it causes enormous problems. Most of these people who died, died very, very painful deaths. They had neurological symptoms, physiological symptoms, they suffered lots of pain, and in some cases it was like losing their minds. That just that shouldn’t happen from eating fresh cantaloupe. It shouldn’t happen.”
Cantaloupes producers, similar to pet food manufacturers – are rarely inspected by any government body. Instead “food retailers and the industry have created the third-party audit system, in which auditors are hired by farms or facilities to inspect their premises and provide scores.” (Though these scores are not made public.)
The Colorado farm (Jensen Farms) responsible for the 2011 cantaloupe Listeria outbreak was ‘inspected’ just days before the bacteria outbreak. A 26-year-old “with relatively little experience” was sent to inspect Jensen Farms. The audit resulted in a “superior” grade but included a note saying “no anti-microbial solution” was used to clean the melons. Experts stated in the CNN article that having no antimicrobial wash should have caused the auditor or inspector to shut down the entire operation. Some believe that because these inspections are paid/hired by the farms (or pet food manufacturers) themselves, the inspections are useless. “But the entire system is a voluntary patchwork of unregulated guidelines with no national standards or actual regulations.”
Back to Health Department inspection and grading of restaurants. Restaurants do not self inspect or hire their own ‘experts’ for inspection. It is understood in this industry (‘table ready’ human food) that self-inspection does not provide assurance of safe food. It should be clear to FDA that self-inspection will not provide safe food (packaged food) as well. The on-going complaints from FDA of no-funding for inspections is getting very old (and killing people and pets in the process). Here’s a suggestion…
Step 1. All food manufacturing facilities and food ingredient supplier manufacturing facilities are inspected once a year; the results of inspection become public information. The inspection process are similar to restaurant grading. Example: Health Department of New York City requires restaurants to post letter grades showing sanitary inspection results. Inspectors check for food handling, food temperature, personal hygiene, facility and equipment maintenance and vermin control. Each violation earns a certain number of points. At the end of the inspection, the inspector totals the points and this number is the restaurant’s inspection score; the lower the score, the better. Inspections are unannounced. Restaurants with a score between 1 and 13 points earn an A, those with 14 to 27 points receive a B and those with 28 or more a C. Inspection results are posted on the Health Department website. (In other words, the wheel doesn’t need to be re-invented…numerous similar systems are already in place and though not fail-proof, greatly improve the safety of restaurant food.)
Step 2. All food manufacturing facilities and food ingredient supplier manufacturing facilities that choose to have their facility re-inspected (to change their grade from initial inspection) can do so by a fee-based service of the Health Department, FDA, or State Department of Agriculture (same government body that did the original inspection). The re-inspection program can provide the entire inspection system with operating capital (no more FDA complaints we can’t afford it).
Step 3. Let the consumer decide which foods they purchase based on safety inspection grading.
Consumers deserve to know the manufacturing conditions of every piece of food they purchase (human or pet food). A system such as the Restaurant Inspection Grading system would quickly cause pet food and human food producers to clean up their plants – there is no motivation higher to a business than lack of sales. This type of system could be developed quickly and could easily pay for itself in re-inspection fees.
By the way, the State inspection report of the South Carolina Diamond Pet Food plant (inspection regarding the latest recalls) is not public information. I was told by the SC Department of Agriculture inspection reports such as this are never made public. Another pet owner was told a Freedom of Information Act Request would be required to obtain the report. How sad; they can’t (or won’t) see the forest for the trees.
Wishing you and your pet(s) the best,
What’s in Your Pet’s Food?
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