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Unusual (But Typical) FDA Warning Letter To A Raw Pet Food

FDA continues to show their bias against raw pet food.

The FDA issued a Warning Letter to OC Raw Pet Food on February 23, 2022. Some very strange things were included and not included in the FDA warning. And…the warning itself appears to be minor issues that don’t seem to warrant an official Warning Letter.

Transparency notice: OC Raw pet food is a brand that is included on the 2022 List. This FDA Warning Letter does not change my personal opinion on the brand, it remains a brand I would trust to give my own pets. I have spoken with OC Raw, and learned a few other things not mentioned in the FDA letter.

The first strange issue of the Warning Letter was FDA stating they inspected this very small pet food plant “from April 16, 2021 through May 26, 2021“. If the FDA was not working on weekends, this means the FDA was inspecting this raw pet food manufacturer for 29 days. But…OC Raw told me the FDA was at their plant from “March 31, 2021 through May 26, 2021” – a total of 41 business days.

OC Raw is a very small manufacturer. By comparison – below are Google Earth images of the OC Raw plant next to the Hill’s plant that was responsible for manufacturing the excess vitamin D pet foods recalled in early 2019.

And as comparison, the FDA performed an inspection at the above Hill’s manufacturing facility after their deadly excess vitamin D recall from “February 1 through February 19, 2019 and March 25 through 27, 2019” – only 16 days in total.

Why did FDA spend so much time – almost triple the days at a raw pet food plant than it did at a feed grade pet food plant responsible for serious illnesses and deaths of pets?

The next very strange thing in this Warning Letter is this quote:

This inspection was conducted in response to a Class I recall initiated on (b)(4) of (b)(4), lot number (b)(4), due to the presence of Salmonella and Listeria monocytogenes (L. mono) detected by the (b)(4).”

FDA redacted the recall dates in this warning. Why? Recall notices are required to be public information. Typically only private company information is redacted by FDA.

To compare to typical FDA Warning Letters, the agency included the recall date in the Hill’s Warning Letter linked above and FDA included the recall date in the Midwestern Pet Food Warning Letter.

So why did the FDA redact the recall date in the OC Raw Warning Letter? The reason could be the recall from OC Raw FDA referenced in the Warning Letter occurred almost four years ago – April 2018.

The next issue is: this warning letter also points out that FDA performed “one hundred (100)” swabs in the manufacturing area for “environmental pathogens“. OC Raw told me the FDA took “180 swabs“.

The FDA warning stated they found “Listeria innocua” in multiple samples and “Listeria grayii” in multiple samples. Even though the FDA made a big deal of these two “environmental pathogens” – they are actually non-pathogenic bacteria. Research found on ScienceDirect.com states “Listeria innocua, the most commonly isolated specie is non-pathogenic as is also generally true for L. welshimeri, L. grayi, L. marthii, and L. rocourtiae.”

Why did the FDA take issue with a non-pathogenic bacteria? Was it necessary for FDA to even mention non-pathogenic bacteria or was FDA trying to make another raw pet food look bad knowing that most pet owners wouldn’t know these were non-pathogenic bacteria? Was their intent to scare pet owners?

Personal opinion: Perhaps it is my bad attitude towards FDA’s selective enforcement of law talking, but this warning letter appeared to be FDA grasping at straws – trying to find something…anything they could to draw negative attention to this pet food manufacturer. To perform a 41 day inspection at a tiny manufacturing plant that is responsible for no pet deaths, while only spending 16 days at a large Hill’s plant that was responsible for hundreds of pet deaths is blatantly biased. To classify non-pathogenic bacteria as “environmental pathogens“, to redact recall dates confirms FDA bias against raw pet food.

I encourage all pet owners – regardless to what style of pet food you provide your pet – to demand FDA stop their selective enforcement of law. Pet food should be regulated uniformly across all styles. FDA’s bias against raw pet food and FDA’s free pass to many feed grade pet products must stop. Please email the agency at: AskCVM@fda.hhs.gov.

Wishing you and your pet the best –

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


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7 Comments

7 Comments

  1. Alexis

    March 24, 2022 at 2:37 pm

    There are a few things one needs to be cautious of if feeding raw. One of those is if feeding a raw blend that includes raw salmon, make sure that salmon is wild caught – not farmed. Actually raw salmon isn’t a very good idea either way due to parasites (including “liver flukes”). I initially started a new rescue dog on the raw diet sourced from the rescue director’s own supplier. But then I found out where he was acquiring the meats. I respectfully bowed out of THAT customer list! I just went with my own blend (direct organic farm purchases and with a really good vitamin supplement) but eventually stopped the raw and resumed home prepared but gently cooked as the dog developed some serious GI issues that were exacerbated by a raw diet.

    • Dennis and Connie Gomez

      March 26, 2022 at 6:22 pm

      we have fed and love Answers Raw…is fermented as well! Their goat milk also fermented is wonderful. Our Beagle has been eating Answers products since his Holistic vet started him on them three years ago!!

  2. Debbie D

    March 24, 2022 at 2:47 pm

    Honestly, I cant wait to see the FDA burn down. ALL these 3 letter agencies are corrupt. EVERY SINGLE ONE. And they want to take away all of our rights. It has been very clear for many many years that they are incompetent of doing a job. I cant say the really bad things I truly think of them and other organizations (organized criminals) here…..so much censoring you know..but lets just say, FDA will be totally dismantled sooner than you think. They have also shown the world their true colors. Hold on Susan..a little longer…things are going to change. God will make sure all this evil is dealt with this year. Thank you for fighting against this evil Susan. We are an Army and they will not beat us.

    • Sheila

      March 24, 2022 at 5:49 pm

      Amen! Change is coming…The truth will Prevail and
      God Always wins!

  3. T Allen

    March 24, 2022 at 3:37 pm

    That is bizarre. There is another possible explanation. The FDA is getting audited. When Gov Depts get audited they jump through all kinds of hoops to try and clean up their messes. Auditors don’t know exactly what they are looking at, they are paper pushers not scientists. Guarantee they don’t know one Listeria from another either. So if the paper work is completed making it “look like” a plant was out of compliance, including the number of days they spent “investigating”, the ridiculous number of samples taken (your tax dollars at work! lots of money to some lab there!), etc. then the FDA appears to be doing their job. Whatever Congress person requested to see this data (because of all the emails they’ve been getting from consumers about pet food?) isn’t going to be able to analyze the data correctly either, unless we make info from this post public! Thanks Susan!

    • Harry

      March 25, 2022 at 9:28 am

      This is actually pretty normal if you read FDA warning letters regularly or work in human food. The FDA swabs for listeria species as indicator organisms, which shows lack of sanitation controls. Any listeria species should be reacted to as pathogenic, since they all survive and die in the same way. This was just a typical FDA swabathon, and they always tend to focus on environmental monitoring for anything pathogen related.

      Sounds like this company just needed some help writing their food safety plan and a better training program. They should have probably asked their chemical sanitation supplier for support training and validating their sanitation practices. It’s normally provided as a service from most sanitation chemical suppliers. It sounds like they just misunderstood what supply chain controls were in their plan.

      Likely, whatever they are spraying on their meat (acetic acid or lactic acid maybe?) isn’t doing much and anything raw or semi-cooked needs strict sanitation controls with good verification steps after sanitation as a rule.

  4. Anon

    March 25, 2022 at 12:08 am

    I like that you separate your personal opinion from the facts here. That makes things really clear, and I agree with you, and it eliminates a criticism of your writing that people have when I share it. I like this form of writing and appreciate you sharing this bias with us. I bet they have a bias against smaller companies too (my opinion).

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