Why so many excess Vitamin D Recalls?

The FDA isn’t talking, so we speculate as to why there have been so many excess Vitamin D recalls in the past couple of months.

The excess Vitamin D recalls began on November 2, 2018 with a recall from Natural Life Pet Products and Nutrisca dry dog foods. The Natural Life recall notice gave us a clue to the problem behind the recalls (bold added): “An investigation revealed a formulation error led to the elevated vitamin D in the product.”

The FDA has not provided pet owners with an explanation about the “formulation error” – specifically who’s error was it? We are left to speculate if the ongoing problem was a formulation error at the pet food manufacturing facility or if it was a formulation error by the supplier of the Vitamin D supplement.

After the first two initial dog food recalls, seven more dry dog food recalls occurred up to December 5, 2018. For 8 weeks we saw no new excess Vitamin D recalls, and then on January 31, 2019 we learned of a Hill’s Pet Nutrition recall for 25 different varieties of canned dog foods.

So…after the Hill’s recall – we know that at least two separate manufacturing facilities are experiencing “a formulation error” with Vitamin D. At least one kibble manufacturing facility and at least one canned pet food manufacturing facility.

Was the Vitamin D ‘formulation error’ at the pet food manufacturing plant?

It could be possible that two separate manufacturing facilities experienced ‘a formulation error’ at the manufacturing facility (human error adding the supplements into the pet food mix). As example – the vitamins and minerals ingredients listed on a pet food label are added ingredients. The pet food company – most often – purchases what is known as a “premix” of vitamins and a premix of minerals. The following photo is actual bags of premix at a pet food manufacturing facility (all photos provided by a friend):

The above bagged premix supplement are hand added (by employees) into bins (the large bags are cut open and the powder is poured into the bins)…

The premix supplements in the bins are pulled from the bins by an auger (underneath this level), delivered to a conveyor system to the pet food mixer.

Considering human error can happen anywhere, anytime – the bins where vitamin premixes and mineral premixes are added could be a source of a formulation error. An employee could add the wrong product in the wrong bin. As well, equipment failure could cause an error – pulling too much of a vitamin premix from the bin to lot after lot of pet food.

If the issue is not a error at the pet food manufacturing facility, the other possibility is much more concerning.

Or was the ‘formulation error’ in the Vitamin Premix?

The other potential ‘formulation error’ could be the vitamin premix itself. Most pet food manufacturers purchase vitamin and mineral premix products to ‘balance’ the pet food meeting AAFCO requirements for a Complete and Balanced pet food.

A “premix” is a blend of all required vitamins (or minerals) that is added to the pet food formula in order to meet the required nutrient profile for Complete and Balanced pet food. In other words, the premix is formulated to add X amount of the premix per XX pounds of the batch of pet food. The top picture above is pallets of large bags of premixes.

It could be that the vitamin premix provider made the ‘formulation error’ for the premix – as example: if the requirements of a 50 pound bag of Vitamin premix (using arbitrary numbers) is 10.50 grams of Vitamin D per 50 pound bag – an error could have been made adding 105.0 grams of vitamin D were added instead (human error moving the decimal point).

Because the FDA has not informed pet owners, we don’t know if this concerning problem was/is a vitamin premix formulation error or if this is a pet food manufacturing error. If it is the premix, the concern is how many other pet food manufacturers received that same ‘formulation error’ premix? Is Hill’s the only one or are there many more? Are pet owners – right now – unknowingly giving their pet a toxic dose of vitamin D?

TruthaboutPetFood.com spoke with a devastated pet owner today (2/1/19) who fed the Hill’s Vitamin D toxic dog food – her dog became ill on January 15 and sadly died on January 20, 2019.

It has been 8 weeks after the last Vitamin D recall to the recent Vitamin D recall from Hill’s (on 1/31/2019). Had FDA traced the problem to Hill’s sooner, would this dog still be the active happy dog he once was?

A frightening question…

Was the 8 week delay between Vitamin D recalls due to the government shutdown?

The government shutdown began December 22, 2018. Did the FDA stop their trace forward investigation during the shutdown (did not investigate other pet food manufacturers that received a potentially mis-formulated vitamin premix)? The FDA has been performing on-site investigations (at manufacturing plants) of several raw pet food manufacturing facilities during the government shutdown. So, did the agency determine that toxic levels of vitamin D pet food wasn’t worth their effort to investigate during the shutdown but raw pet food was?

A Freedom of Information Act request will be filed to try to determine the answers to those questions. When this information is received, it will be shared with everyone.

No doubt about it – the FDA should tell pet owners what is going on with the many excess Vitamin D recalls. One pet has died…a death that perhaps could have been prevented. There is no excuse.

Wishing you and your pet(s) the best,

Susan Thixton
Pet Food Safety Advocate
Author Buyer Beware, Co-Author Dinner PAWsible
TruthaboutPetFood.com
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