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Pet Food Safety Study is Not Junk Science

Opinion

It is sad to report that the credibility of our results has been attacked. And by someone who knows nothing of the two scientists who oversaw the testing for us. There were no questions asked prior – just bashing. Makes one wonder.

Phyllis Entis is probably known to many readers here — she was known as “The Food Bug Lady” when she had a blog about food safety. She just came out of her retirement from blogging to call our pet food test results “junk science.” You can read her unflattering response to our testing here.

So — for starters, in response to the “junk science” claim — the scientists who oversaw our testing project were Dr. Gary Pusillo and Dr. Tsengeg Purejav of INTI Service Corp. For any doubters to the credibility of our testing, below is a bio of INTI Service:

INTI Service Corp. provides animal and agricultural forensic science services to companies all over the world. Dr. Gary Pusillo, a board-certified veterinary nutritionist, has more than 300 professional forensic investigations to his credit, in addition to personally reviewing and evaluating hundreds of cases that never made it into the judicial system. Dr. Gary’s investigative and expert reports are peer-reviewed, scrutinized and analyzed by the some of the best minds in science and the legal system. Dr. Gary has been an associate member of the American Academy of Forensic Scientists (AAFS) since 2012 and has presented two papers at national meetings. In Washington, D.C., in 2013, Dr. Gary received the AAFS General Section Achievement Award. This was the first an animal professional ever received the award since 1948.

Those who know me and my consumer advocacy work know very well that I would not have trusted our very serious pet food testing project to anyone other than the absolute best. We had the best with Dr. Gary Pusillo and Dr. Tsengeg Purejav.

Ms. Entis calls our testing “a wild goose chase after low-level pathogens of minimal risk to either humans or their pets.” Interesting perspective — but incorrect.

The information provided in the full report was quoted from FDA, the Centers for Disease Control, and the Food and Agriculture Organization of the United Nations. I am by no means a scientist, so I relied on information from these well-known organizations to provide risk information to consumers.

As an example, Ms. Entis states that Acinetobacter (found in 8 pet foods) is a “low-grade pathogen that is mainly associated with hospital-acquired infections … .” FDA, on the other hand, has classified Acinetobacter as a “Qualifying Pathogen” – it is listed in the Federal Register as a qualifying pathogen. As for this bacteria mainly being associated with hospital-acquired infections, yes, I’ve read that, too. But why was a bacteria mainly associated with hospital-acquired infections found in pet food?

Ms. Entis states about Pseudomonas bacteria, “These bacteria are present in the environment, in our water, and in food. It is a cause of ‘swimmer’s ear’… .” However, specific to meat (such as meat in pet food), the Food and Agriculture Organization of the United Nations lists Pseudomonas as “microorganisms causing microbiological spoilage of meat,” and states specifically that Pseudomonas is a bacteria that causes “putrefaction” of meat. Again, why was this bacteria — linked to swimmer’s ear AND putrefaction of meat — found in pet food?

Ms. Entis discounts the risk of Streptococcus, Staphylococcus, and Bacillus. On the other hand, FDA discusses these bacteria and their risks to humans — at length — in its “Handbook of Foodborne Pathogenic Microorganisms and Natural Toxins.” Note the word “foodborne.” Not even to mention the risk to pets consuming the bacteria.

Ms. Entis states, “the study organizers decided to troll through the foods for a long list of other irrelevant microbes.” The bacteria testing on the pet foods was performed at Baylor University. The results they provided were for full bacteria content of pet foods tested. There was no “trolling” for microbes. What was found, was found. What wasn’t, wasn’t. We did not “select” what bacteria to look for — our testing searched for all bacteria in each pet food. Salmonella and Campylobacter were not found in our testing — we didn’t avoid them as Ms. Entis suggested. Had she bothered to ask me prior to her post, she would have learned this. As for species identification, my apologies. Consumers didn’t have the funding to perform this for you.

Ms. Entis also took offense at how our mycotoxin results were provided. She suggests that we (me) intentionally changed the results from parts per million to parts per billion to make “the data appear more shocking.” Wrong again.

The results were provided to me as parts per billion, and, in turn, I provided them to consumers as parts per billion. Ms. Entis suggests that FDA states mycotoxin levels in parts per million. But, as you can see in this FDA Guidance document, FDA states aflatoxin levels in parts per billion — just as we did.

Ms. Entis states, “I am appalled at the way in which this study was designed and carried out. The portions of the study relating to bacterial analysis and presentation of the mycotoxin results are the epitome of junk science.”

Junk science? You call a board-certified veterinary nutritionist and a member of the American Academy of Forensic Scientists junk science? You call science performed by a leading university junk science? I beg to differ.

It does NOT matter if bacteria found in our test results are known to be found in hospital-acquired infections — they were found IN PET FOOD. They are linked to serious human illness. They are linked to spoilage of meat.

If doubters wish to question Baylor University and the results they provided us, go right ahead. No one — to our knowledge — has ever tested pet food at this level before. So perhaps the shock and disbelief from doubters should be expected. But I must say I was disappointed that Ms. Entis never bothered to reach out to learn more from me prior to her publicly discounting our testing. She not only insulted pet food consumers, she insulted numerous professionals. That is a shame.

© Food Safety News
  • Mike_Mychajlonka_PhD

    The study defended here by Ms. Thixton does seem to be a useful undertaking. I see nothing wrong with consumers taking matters into their own hands. In fact, I encourage consumer involvement. However, this article should have (I think) provided a link to the original report. As I did not find it in the article, I provide it here: (http://associationfortruthinpetfood.com/the-pet-food-test-results/). A little more than halfway down this page, one may find a link to download a PDF of the entire report. As far as I could see, this report did not sufficiently describe the methodologies used to generate the results. Nor have I been able to find any discussion of the controls run during the analysis that would provide evidence of the validity of the methods used to the generation of the actual results. If Ms. Entis takes exception to what she perceives to be over-interpretations based upon inadequately described methodology, then I can understand her point. However, just because the Materials and Methods section is largely absent in the report does not necessarily mean it is lacking in the study. It may be that a publication is being prepared for submission to a peer-reviewed journal (or other publication) wherein Materials and Methods will be addressed at some length. Alternatively, it may be that the report itself just needs to be better written. Also, these days there are many ways to speciate bacteria. I currently have the capability to rapidly identify bacteria by means of mass spectroscopic methods. Of course there is a cost associated with doing so but that cost compares favorably with older methods. If isolates from this study are still available and Ms. Thixton is interested, please contact me. It is my hope that the issues raised here may be discussed by consideration of the actual data produced, not the personalities involved.

  • Paul_LK

    I think both authors are being unreasonable. Ms. Thixton, whether by design or lack of knowledge on the subject, has overstated the importance of the study’s findings – resulting in hype and fear mongering. The results of these findings should be viewed in the context of veterinary epidemiological studies (if they exist) and not tangentially linked to statements by various organizations.

    As for Ms. Entis’ commentary, I think it used inflammatory rhetoric and does not foster critique with reason and constructive debate.

    I tried to trackdown the study authors’ findings to see if they overstated their research findings, but was unsuccessful. The problem with many of these Crowdfunding research projects is that the proposals are not adequately reviewed (and not competitively) to fix methodological flaws beforehand.

    As with human studies, I believe that we should begin with applied veterinary epidemiology, and develop theories about causation of pet diseases. For example, from my limited knowledge on the subject, there is an epidemic of cat hypothyroidism possibly linked to environmental exposures – including possible contaminants in processed pet foods. Start with the disease and associations, followed by integration with laboratory studies and other knowledge.

  • Nicole

    To Mike Mychajlonka: I am not a scientist but I am pretty smart. If I am way off here by all means let me know.

    This was a test for bacteria in pet food. Why on earth would you expect a control group or that the methodology be submitted to a publication for a peer review before validation. Is that ever done when testing for bacteria? If I were sick and they did a culture to identify the bacteria, would that testing involve control groups or peer review publications for validation? That could take years. Really? Can you cite to one single instance when a pet food manufacturer, human food manufacturer, CDC or FDA, when testing for pathogens, uses control groups and peer review publications for vetting before a recall. This isn’t a scientific thesis waiting for validation
    from the scientific community. It is a test for pathogens in food for pets.

    To Ms. Thixton: I was not aware of your advocacy until this test. I have visited your blog this weekend and I would like to say thank you very much.

    I am a passionate supporter of pet food safety. When they kill my pet once, shame on them. If I allow them to kill two of my pets, shame on me.

    RIP Mabel 2002- March 11, 2007. We will never forget.

    • Mike_Mychajlonka_PhD

      Nicole – In the last sentence of the comment directed specifically to me you state: “It is a test for pathogens in food for pets.” That is precisely the point. If one is looking for pathogens, one must identify them specifically, not just the broader taxonomic grouping specific pathogens may be part of, which may contain a great many members that are not pathogenic. There are usually many different ways to identify a given pathogen. For a specific sample type, some may be better than others. The specific method used should be disclosed so that the reader can discern for her/him -self whether appropriate methodology was chosen. Both USDA and FDA have taken the trouble to publish methods they think appropriate for the identification of different pathogens. These methods are available for public perusal. All these methods include the running of at least one control to verify that the method is producing the results expected of it (i.e., validation). In fact, I would be hard put to identify even one analytical method that called for release of unvalidated results. By the way, you mentioned the term “control groups” several times. That is a term often used to validate the reliability of a clinical study. I am not calling for a “control group” but for disclosure of the specific control(s) used to validate the testing results described. These two concepts are vastly different. Lastly, I did say that if the results of this study were being prepared for a peer-reviewed publication, it might explain why the Materials and Methods were so lacking in the published report. I never suggested that there was requirement for: “. . . control groups and peer review publications for vetting before a recall.”

  • Food Microbiologist

    Dr. Mychajlonka’s comments are excellent. I found the original report faulty because of the lack of methodology but mostly for assuming two genera, Acinetobacter and Pseudomonas were pathogenic. Spoilage bacteria yes, they are psychrotrophic bacteria capable of growing at refrigerator temperatures but few strains are pathogenic. Ms. Thixton posted, “ I am by no means a scientist, ”. Yes, and I believe you picked the wrong people to interpret the results. I suspect they ran the samples through a VITEK® machine that popped out the genus without going further. Any competent microbiologist would not have reported those two genera as risks without further identification. Same goes for the other reported genera, Streptococcus, Staphylococcus, and Bacillus. Yes, there are pathogenic strains in those genera but the study apparently went no farther than reporting genus. Those are common environmental genera that are mostly benign. If you are in Iowa, do contact some microbiologists at Iowa State in Ames, Iowa. Jim Dickson would be a good start.

    • Think about it

      Not determining the species of bacteria is huge here, as it allowed her to use the shock factor that bacteria was even present, without determining if it was harmful or not.

      • Oginikwe

        Don’t forget to troll this article too:

        Lawsuit Claims Beneful Dog Food is Poisoning Pets: http://www.foodsafetynews.com/2015/02/lawsuit-claims-purinas-beneful-dog-food-is-poisoning-pets/

        • Think about it

          I doubt the sincerity of people who confront FACTS with “troll” and “schill”. I could sue you for whatever I wish…anyone can…let’s see where Beneful suit goes.

          Pets ARE dying, and why are the vets not more proactive? Where are the vets with the documents. Where are the vets reporting these dog food issues to their “Portal” IF they believe there are food issues? Has the number of pets who pass on any given day no matter what they ate risen dramatically?

  • dont dogs eat poop sometimes?

    Just stop talking Ms.Thixton, your making your self less credible by the sentence….We appreciate the time money and effort to put out your study, but dont get so defensive, criticism should be appreciated as well as praise.

    You didnt even state which Mycotoxins you were testing for so how do we know if they should be in ppb or ppm? There are more types mycotoxins then aflatoxins and some are reported in ppm…

    Yeah the bacteria you found could cause harm, but only if your dog has a serious immune deficiency… Yes that bacteria can be found in hospitals, it also can be found in your sink maybe your counter, and has nothing to do with it being resistant to antibiotics.

    dogs eat their own shit sometimes, Im pretty sure some of the most common bacteria you can find wont hurt them…

    If you dont want people to write articles criticizing your study’s legitimacy then conduct a better study and put out a report with less glaring holes in it, thanks.

    • JChurchtown

      Can confirm: I share a backyard with a terrible neighbor. The neighbor dog left a log in the middle of the walking path and my goldie thought it was a frozen poopsicle treat.

  • Nicole

    Why are all of these scientist coming out of the woodwork to critique the testing results? I don’t mean to sound flippant, but we are not stupid. Whose payroll are you all on. Why do you care so much?

    You all are missing the point. Whether the bacteria found was in miniscule or abundant amounts, whether they are pathogenic or not, whether they are alive or dead or risky or benign is not the issue. The issue is why they are in the food. And why when pet owners have been screaming at the top of their lungs for years doesn’t anyone listen or care that we don’t want these bacteria in any shape or form in our pets food.

    Would you like these bacteria to be in your food if I said don’t worry they are dead and won’t hurt you. How about I pour some extracted waste water sludge, I mean animal fat, over your cereal.

    When manufacturers show commercials of beautiful plump ripe perfect fruit and meat raining from the sky in a beautiful grassy wheat field and instead use spoiled diseased carcasses with maggots, moldy food and dirty nasty extracted wash water from dead diseased carcasses, it is disgusting. The test results are a mirror into the
    actual degraded ingredients used. Pet owners don’t want food with bacteria that
    isn’t allowed in human food in pet food. Period. The manufacturers have to stop
    profiting from the disgusting waste or get out of the pet food business.

    The incessant hang up about methodology is really an irrelevant and moot point.

    The excessive calcium is another mirror. Bone has calcium. Meat has phosphorous and calcium (more phosphorous than calcium.) When an animal in the wild eats a prey animal, they eat the meat, organs and some bone, not a lot. The result is a perfect ratio of calcium to phosphorous. When a food has excessive calcium it means that the ingredients are mostly bone (a stripped carcass) and not enough actual meat.

    And to the poster who mentioned poop eating. Perfect. Dogs eat their own poop when the processed food they are eating has insufficient nutrients. They are trying to compensate and get more nutrients. Change to a quality food, poop eating stops.

    And if anyone would like the testing to go further, I am sure Ms. Thixton would gladly allow you to fund that.

    • CJ

      Not to troll, but bacteria are everywhere. In order to remove them you would need a sterile product- which is completely unfeasible unless you’re willing to pay $$$$$ and it would be become “contaminated” the moment it was placed into a pet’s bowl or package was opened. Also, to further this point, ever take a swab of your hand/mouth/throat/gut/soap bar etc. and see what kinds of bacteria are present? I’m sure you would be very surprised what you would find. Pathogenic potential is extremely important whenever you’re looking at this because the level of contamination and potential directly relate to who, if any, will get sick. There are over 2000 species of salmonella and only a fraction are considered pathogenic. Without testing out for the Genus or checking for validated method, I can take a swab of my table top, do a basic test and SURPRISE! there’s salmonella on it. Should I be saying that this is justification that my table top is going to get everyone sick and I need to completely replace it? No, because I cant make that kind of assertion without more specific data.

      I also question the use of posting results from a “scientific” study prior to peer reviewing unless the purpose is to utilize as a hit piece and get information to promote a certain agenda out before it is thoroughly scrutinized and can be repeated. You argue that methodology doesn’t matter in terms of the point is completely without merit and false. Methodology is everything for scientific studies- if you don’t believe me, look up vaccines and autism. Because of one abyssal study (which by the way was revoked and the PI had his license revoked), outbreaks of diseases that were otherwise gone in the developed world have increased and hundreds of millions of dollars have been spend to show how wrong that study was.

      • Nicole

        So basically what I believe you are saying is that based on the testing report, you can’t tell with 100% certainty that the bacteria found
        in the pet foods are not the same bacteria one might find on a counter or a hand or in say a delicious chocolate candy bar, or box of rice, bag of potato chips, shortening, cereal, yogurt, coffee, bottled water, even in makeup etc., if these items were tested. Because … the bacteria are everywhere.

        I think everyone who has a pet needs to just buy a great quality pet food (they do exist – they are not allowed to say they use human grade ingredients if processed in a pet food plant due to lobbying by the manufacturers of low quality pet grade foods – but do your research, you will find them) or make it themselves. There will never be change when you have large corporations with billions of dollars at stake. It’s time for all those who are financially able to walk away from this food forever. (I think that has happened to a large extent, anyway) Unfortunately, pets of those who have little means to buy a better product will continue to suffer.

      • tallen2007

        So you are saying that a package of properly cooked product was opened in a certified lab by professionals and they contaminated all the products with all these “potential” pathogens? Another instance of criticizing without doing the research to find out the back story to the project.

      • thinkingaboutnutrition

        Thank you to everybody that’s cooperating to improve our knowlegment about making the logic to help our real lives.

        IMHO a control group is important to test hypothesis that really unswer the doubts of the consumers. But I think there are a problem before the methodology.

        The first part of a good scientific work – after reading all about the subject that there are published in the scientific literature – is to develop really good questions that are intended to be clarify. Hypothesising. A second step would be to choose appropriate methodologies to test these hypotheses.

        For example, the hypothesis: “processed foods for dogs and cats contains bacteria.” This hypothesis is true or false?

        To start this would not be a good hypothesis to be tested for its result do not say if it is safer to feed our animals with homemade food or industrialized food.
        This is because there are bacteria and fungi, pathogenic and non-pathogenic, (almost) everywhere, including homemade food that, from what I understand, is intended to be a much safer alternative for the group of consumers that supported the test. Pasteur has done these experiments long ago and released the results.

        And even if it would found pathogenic bacteria in above acceptable levels, it would not unswer the doubt = should I give industrialized or homemade diet to my pet? It’s easy to realize that if you think that would be possible someone publish tomorrow a study that had used the same methodology and had just found the same results but in homemade foods! So it would be an indication that it is not the industrial process that would be responsible for the unwanted itens found (as the same itens in equal amount would exists in homemade diet, too), but nother factors.

        I think appropriate assumptions to test what worries consumers would be:

        1 – “Industrialized products for dogs and cats contain different types and / or quantities of substances, bacteria, fungi and mycotoxins potentially dangerous to health than those found in homemade diets. ”

        2 – “These kinds and/or amounts of these elements can result in greater health risk to animals.”
        Would anyone have suggestions for improving these?

        Hence, the development of the methodology: it is clear that it would be necessary to test as many industrialized samples then homemade recipes.
        So, the ‘control group’ represented by homemade foods is necessary.

        Then in my humble opinion it is a pity but this study did not help to clarify the doubt of consumers (industrialized ou homemade diet?), or rather, It may just become myself more confident about the GOOD QUALITY of industrialized products as all twelve tested foods were clear of melamine; pathogens of most dire human significance, Salmonella and Campylobacter and pentobarbital contamination. The most common concerns about pet food safety that people comment at Internet.

        I decided to join this discussion because I work with nutrition of dogs and cats (helping Clients in homemade food production and also working with pet food industries), because I’m interested in science and logical thinking and because I became veterinarian because I like animals and always had dogs and cats in my home.

        Sorry about my English, it’s not my first language.

  • Me

    Board certified veterinary nutritionist eh? The only board that legitimately certifies veterinary nutritionists is the American College of Veterinary Nutrition (http://www.acvn.org/directory/ ), and Dr. Pusillo is not listed as a diplomate. I suppose you’re referring to his American Council of Animal Naturopathy credential. ACAN is “accredited” by the American Association of Drugless Practitioners and is not recognized by the veterinary community as a bona fide specialty board. That alone spells junk science! The microbes mentioned are ubiquitous. I’m not surprised they were detected, especially given there was no mention of how samples were collected, stored, handled, and processed.

  • FoodSci

    https://microbewiki.kenyon.edu/index.php/Acinetobacter

    Acinetobacter is a genus of opportunistic pathogens in the proteobacteria group, species of which are distributed in widespread, diverse habitats
    … it is normal to have some amount of Acinetobacter on the skin surface; as many as 25% of healthy adults do in fact harbor these bacteria.
    They are found in soil, water, and in living organisms, where they may or may not be pathogenic.

    I’m not a microbiologist, but methinks “The Food Bug Lady” has a valid point and that “The Pet Food Lady” doth protest too much.

    • tallen2007

      What are they doing in pet food no matter where they came from? These aren’t raw foods, they are supposed to be cooked.

    • Think about it

      Ms. Thixton may use and defend the correct figures for aflatoxins, but not for the other mycotoxins. The link she provides conveniently addresses only the aflatoxin amounts.

  • Oginikwe

    You know what, I don’t frickin’ care. Something is making our pets ill, something is causing them to get all kinds of cancers that many of us have never seen before. All one has to do is spend any amount of time on this website to see the callous indifference on display in human food, and what in the world makes anyone think it would be any different for pet food?

    We are told to “trust the science,” and yet the FDA drags its feet on pet treats from China for how many years? Petco and Petsmart just moved to stop selling those jerky treats from China, not based on science but based on consumer demand because people’s pets were dying and getting sick. It has been consumer activists like Ms. Thixton that have resulted in change and those consumer activists are all we have right now. Why is that? Because “science” has repeatedly refused to police itself and because too often “science” is paid for by the corporations who are paying the bills instead of actually being objective. No where is the cravenness of some scientists better illustrated than in all the “science” of “tobacco is safe.” Or, all the “science” disavowing the dangers of exposure to asbestos which was a decades-long fight. Worse, where are the scientists to defend others who are unfairly targeted by industry and other scientists such as Tyrone Hayes?

    This round of testing was not meant to be a scientific study. It was a concerned citizen who took a variety of pet foods in to be tested and those are the results. If the industry is having a fit, good. Let’s see their testing done by an independent laboratory. I would be especially interested to see the levels of inorganic arsenic in pet food since we have a problem with inorganic arsenic in people-rice. And, because I’m real tired of my cats getting tumors from big box store cat food, I’m going to start making my own.

    So let’s see industry testing done by an independent laboratory.
    But, of course, it’s not like that’s ever gonna happen because they already know what’s in there.

    • Mike_Mychajlonka_PhD

      Oginikwe, You are right about “Big Tobacco” and their campaign to recruit various scientists to question and/or discredit any data suggesting that smoking might be unsafe. The delay period was considerable as were cigarette sales during that delay period. That campaign was run by a public relations firm that became quite wealthy as a result. As I understand it, that firm has undergone something of a reorganization and has, several years ago, hired a former undersecretary of USDA and head of FSIS. Go figure. You may be interested to know that I am currently putting together a crowd-funding proposal to analyze for various heavy metals in foods and food ingredients for both humans and pets. I can guarantee that any results I release will be hard as bedrock. Furthermore, despite all the controversy surrounding a similar effort put forward some years ago by the Dr. Oz show regarding arsenic in apple juice, recent publications have shown that human metabolism is capable of interconverting several forms of organically bound arsenic and inorganic arsenic. I am not aware that pet metabolism has been elucidated to that degree. Nevertheless, the argument that (at least for humans) certain organically-bound arsenicals may be viewed as “safe” is now open to question.

      • tallen2007

        How can we find your crowd-funding proposal? We need all the help we can get to figure out what foods are safe for us and our animals!

        • Mike_Mychajlonka_PhD

          tallen2007 – You may find it on KickStarter as soon as I can finish the application process and submit it. It then has to pass review. My holdup has been the requirement that this project be described in a video. I have had little experience in making and processing a video, so progress has been slow and the result looks like the amateur production it is. Nevertheless, I feel that the informational content is there. KickStarter’s time limit for video is ten minutes. I have yet to finish the somewhat longer, more detailed video I want to have available from my company’s website (foodsafetyanalysis.com). Anyone who sends me an email (mikem@foodsafetyanalysis.com) will receive notification when and if this funding project is eventually accepted for listing on KickStarter.

    • Think about it

      The number one cause of cancer in dogs is age. There was less cancer years ago, because most dogs did not live long enough for it to manifest.

    • Think about it

      The number one cause of cancer in pets is age. Years ago, without calculated nutrition and veterinary care, they did not live long enough for it to manifest.

      • Oginikwe

        Not when those cancers occur in pets who 2, 3, and 4 years old. Cancer is not a inevitable disease. It was rare for cancer to manifest in the early 1900s.

  • NutritionTech

    What nutrition board is Dr. Gary Pusillo certified by? His name is not present with either the American College of Veterinary Nutrition nor the European College of Veterinary and Comparative Nutrition, required to be named as a board-certified veterinary nutritionist. Please correct me if I am wrong, but ACAN is an indication of certification by the American Council of Animal Naturopathy, not board-certification in nutrition. Thank you in advance for the clarification.