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Pet Owners forgotten again with FDA’s DCM Investigation

The FDA recently participated in a DCM discussion webinar. Pet owners weren’t invited, again.

The FDA recently participated in a DCM discussion webinar. Pet owners weren’t invited, again.

Kansas State University held an online forum “Exploring Causes of Dilated Cardiomyopathy in Dogs” on September 29, 2020. The forum was private, invitation only. Pet owners weren’t invited.

The FDA was there, providing opening remarks and providing an update on cases (this was the 3rd update FDA has given directly to industry without an equal update to pet owners). The Pet Food Institute was there, Champion pet food was there, Hill’s pet food and Waltham PetCare was there. But no pet owners. Pet owners weren’t even made aware this was happening.

An insulting to pet owners statement came from Dr. Steven Solomon of FDA’s Center for Veterinary Medicine opening remarks; “I know that most of you, including me, would have preferred that we could come together in person. In my experience, the networking that takes place among colleagues during breaks and over lunch is an important opportunity to exchange knowledge.” FDA has repeatedly refused to meet with pet owners…but Dr. Solomon misses hanging out with his industry friends? For Dr. Solomon to reminisce about networking with industry is a slap in the face to the pet owners he continues to ignore.

Dr. Solomon stated “And I want to be clear: we at CVM currently do not view this as a regulatory issue. We have not requested any recalls. We have not taken any compliance or enforcement activity. This is a matter of science, and my hope and the hope of all the CVM staff working on this issue is that all the scientific expertise that is assembled here today will be able to put some more of the scientific puzzle pieces together.”

But will CVM ever put the ‘scientific puzzle pieces together’ with DCM? The agency never put the pieces together for Chinese jerky treats. After FDA received thousands of reports of illness and death – “more than 6,200 dogs, 26 cats, three people, and include more than 1,140 canine deaths” – the agency failed to find the cause and quietly dropped their investigation. (And by the way, 13 years later these jerky treats from China are still causing pet illness and death.)

Selective investigation. When you only look at part of a problem…

Dr. Solomon stated in his opening remarks: “We received the first report of DCM in a dog in 2014, then a handful of sporadic reports coming in through 2017. In those four years, we received reports involving 13 dogs. In early 2018 we received a notable increase in adverse event reports that got our attention, specifically the unique signal found by veterinary cardiologists who reported seeing DCM occurring in breeds not typically genetically prone to this disease. Then we looked for trends related to grains, or rather, the lack of grains. More than 90 percent of products, according to their labels or label ingredients, were “grain-free”.”

FDA only looked at information reported to them. The agency claimed they received “a notable increase in adverse event reports” regarding DCM in early 2018 and the agency clearly implicated grain free pet foods as the suspect cause. But another presenter at the event – BSM Partners – told a completely different story. Quoting from their presentation…

BSM surveyed veterinary cardiologists all across the US regarding DCM diagnoses over almost two decades; “survey included approximately 68000 dogs evaluated by veterinary cardiologists over 19 years.” “For all states over all years, the average annual DCM Incidence rate was 3.83%. This trend line does not support a change in DCM incidence over time among cardiology services that participated in this study.” In other words, over 19 years of data from veterinary cardiologists across the US (years 2000 through 2019), their data showed NO increase in DCM cases.

And then this group looked into the sales data of grain free pet foods; “if we consider the % market share data from the past 4 years, it is possible that as many as 40% of dogs are eating grain free diets today.” And based on a 19 year consistent annual DCM incidence rate (3.83% of all dogs per year) from veterinary cardiologists across the US, this group determined the FDA claim of a “notable increase” linked to grain free pet food did not match with their 68,000 dog survey; “This huge increase in popularity in these diets over the past decade does not correlate to the relatively stable overall incidence of canine DCM.”

Why didn’t FDA survey veterinary cardiologists all across the US to gain a true historical baseline of DCM cases in the US? Ideally this should have been done before FDA issued their first warning in 2018 implicating grain free pet foods and frightening pet owners. Is FDA investigating the DCM issue ‘selectively’ – in the same manner the agency enforces law?

What can pet owners trust?

With certainty, not inviting pet owners to participate (or at least listen live) to the DCM forum further divides this issue. We can’t help but wonder, what else are they hiding from pet owners?

Regardless whether the future determines grain free pet foods are no link to DCM or whether the future determines they are – the FDA holds ultimate responsibility in this issue. The FDA is a voting member of AAFCO’s Ingredient Definitions Committee that voted to approve pulse/pea/legume ingredients with no scientific data as foundation to their long term safety (no pet food ingredients are required to present safety data before they are approved by FDA at AAFCO). Dr. Solomon stated in his speech, “CVM does not review or declare any particular type of pet food as “safe” the way we do with animal drugs.” But CVM certainly DID declare all of the ingredients they have questioned as a possible link to DCM as safe, and the agency did NOT limit the percentage of these ingredients allowed in a pet food. While FDA doesn’t declare any particular pet food as safe – the agency absolutely declares the ingredients in pet food as safe through their participation in AAFCO.

Pet owners deserve far better than this from FDA. Are these ingredients safe or are they not? The questions go on and on. FDA started this mess with their 2018 warning to pet owners…2 years later we deserve some answers.

FDA should perform thorough and unbiased investigations. They’ve had years of experience at investigations, it’s a puzzler why they appeared to have failed so miserably in the DCM investigation (and the jerky treat investigation).

Pet owners are the largest stakeholder in pet food. Yet FDA continues to treat us like we don’t matter, our pets as collateral damage to their selective enforcement of law and selective investigations. Enough.

Should any pet owner wish to send FDA a message about the DCM investigation, you can email FDA CVM at: AskCVM@fda.hhs.gov.

Pet owners can read all of the presentations given at the DCM forum here: https://www.ksvdl.org/resources/dilated-cardiomyopathy-dogs-forum.html


Wishing you and your pet(s) the best,

Susan Thixton
Pet Food Safety Advocate
TruthaboutPetFood.com
Association for Truth in Pet Food

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