There may not be unanimity on how to change the current state of pet food manufacturing, testing and inspection in the United States, but there seems to be general agreement that some changes need to be made, if only to reduce the number of recent pet food recalls and associated illnesses that have killed or sickened thousands of our companion animals. This past October, the U.S. Food and Drug Administration (FDA), the federal agency responsible for overseeing the safety of pet food, proposed a comprehensive and lengthy rule, including preventive controls for pet food and animal feed, as required under the Food Safety Modernization Act (FSMA). FDA’s proposed rule would require equal processing standards at all facilities manufacturing, processing, packing or holding animal feed and pet food, including Good Manufacturing Processes (GMPs) and risk-based preventive controls, among other changes. Sources told Food Safety News that FDA’s proposed rule is a positive development, although they also believe — along with others involved in the pet food industry — that the devil is in the details. More than a year before the rule was introduced, FDA Deputy Commissioner for Foods Michael R. Taylor telegraphed the wide interest his agency knew would ensue in a speech he delivered in April 2012 at the Pet Food Forum in Schaumburg, IL: “The pet food industry has customers with high expectations. We all know that by the calls we get when something goes wrong. The melamine contamination of pet food in 2007 is a good example; we received more than 14,000 reports in the first four weeks after the contamination was discovered. The changes we are making through FSMA will improve public health, animal health, and also improve consumer confidence in the global food and feed supply. These are benefits for all of us.” Manufacturers prefer longer comment period Pet food manufacturers are leery of new federal regulations, particularly ones with the breadth and scope posed by FDA’s proposed new rule, and they have conveyed concern about the 120-day comment period. Richard Sellers, senior vice president of legislative and regulatory affairs for the American Feed Industry Association, delivered that message to FDA officials at a FSMA public meeting on the proposed rule held Nov. 21, 2013, in College Park, MD: “This industry has never seen the magnitude of such rule-making with such a major impact on all of the feed industry,” Sellers said. “We are expected to review, answer questions and provide comments in just over four months. In fact, except for medicated feed, this industry has never seen good manufacturing practices regulations, and FDA is proposing to implement those, as well as hazard analysis and risk-based preventive controls, in a very short timeframe. We think FDA and the industry will have their hands quite full in the next decade implementing these rules.” Ten changes to improve pet food safety Here, in no particular order, are 10 changes sources indicated would help enhance pet food safety in the U.S.:
- Adopt a greater overall focus on product safety, even if this means using human food manufacturing standards for pet food.
Chip Sammons, who owns the Holistic Pet Center in Clackamas, OR, decides which labels of pet food to carry after touring manufacturing facilities. He looks for cleanliness, human-grade ingredients, and a culture where safety concerns can stop production. Sammons says he’s seen this approach in action with firms whose products he stocks. “One thing that made those plants stand out in a nice sort of way is that employees can stop the production run at any time,” he notes. “Anytime an employee sees a thing that they believe might not be right, they have the ability, the authority, to stop the run. You contrast that with the big boys, who are just into volume and production, and it’s incredible.” Barbara Royal, D.V.M., of The Royal Treatment Veterinary Center in Chicago, believes pet food standards are a good idea but should be realistic. “It makes sense to have standards for pet foods, but perhaps the same standards (a GMP/USDA-licensed facility) are not necessary for pet foods,” she says. “There are many conditions set for human foods that are not necessary or feasible for pet food manufacturers. Making human standards required could be so costly it could raise pet food prices to an untenable level.”
- Make sure a Hazard Analysis and Critical Control Points (HACCP)-certified staffer is present at pet food manufacturing facilities to help avoid safety problems.
Brenda Stahl, Ph.D., national food safety manager for EMSL Analytical, Inc., in Morrisville, NC, says this issue is her top concern. “They’re manufacturing food, just like everyone else,” she points out. “The issues you see are cold extrusion, an ambient or cooler method of preparing or pelleting or extruding the food for dogs to eat. The problem is there’s no kill step. The process itself kind of spreads things around, and there’s no protection against contamination.” Dr. Royal is also concerned about how dry kibble is processed. “The extrusion process (a high heat processing), creates two potent carcinogens, a heterocyclic amine and an acrylamide, which will be in every extruded kibble food, but certainly not be on the label. It is a byproduct of the extrusion process, and because it is not an ingredient that is added, it need not be put on the label,” she explains. “So owners are unaware that, with every bite, they are feeding a potent carcinogen. I believe that this is one reason we are seeing such an increase in cancers in our pets.”
- Ramp up safety education training to increase general awareness of potential problems.
Dr. Stahl, who performs safety audits for small to large pet food manufacturers, notes that the highest number of product withdrawals and recalls ever have occurred during the past 10 years. “Ninety percent of the time, they’re occurring at the production level,” she says. “They’re not happening because of raw ingredients or at the transportation level. They’re happening because of manufacturing, and that’s one of the things we can help people with.”
- Be practical about the lowest level of bacterial or pathogen contamination that can be achieved.
For FDA to set a zero-tolerance policy for Salmonella on pet food doesn’t make a lot of sense since USDA has set an allowable level for the pathogen, Sammons says. “USDA knows that there’s Salmonella out there all the time on chicken, meats, etc. They have a wise oversight policy of around 7.5 percent,” he notes, adding, “FDA has a zero-tolerance policy, so consumers are confused, and it would be nice if government agencies could mirror each other on safely issues.” “There’s some history with regard to Salmonella and its potency and how it affects people,” says Dr. Stahl. “When people approach me and say, ‘We’re never going to get to zero level of Salmonella,’ I say, ‘Do you want to be the one incident that affects someone?'”
- Require environmental testing and finished product testing, even though FDA removed them from its proposed rule.
FDA may not feel like it can regulate everything, and finished product testing “may not be necessary” if a pet food manufacturer has measures in place to assure the safety of their product, Dr. Royal says. “Environmental testing, however, is an area that is sadly ignored in this industry,” she says. “The environmental impact of food manufacturing is clearly a critical issue for our planet, and, as this is a multi-billion-dollar industry, it is not a small concern. I know it may be difficult for the FDA to add this to their list of what they regulate. I just wonder, however, if not them, then who?”
- Enforce final safety standards on foreign suppliers as well as domestic ones. FDA is already proposing to require “good manufacturing practice in manufacturing, processing, packing, and holding of animal food” for both domestic and foreign suppliers.
It can be tough to enforce U.S. standards on exporters, but pet food safety requires it, sources say. Otherwise, increasingly educated consumers will vote with their wallets and avoid pet food products from other countries when they can. Sammons talks about one pet food plant he visited in Alberta, Canada, which clearly had high standards. “I liked them because there were clean,” he recalls. “I saw human-grade ingredients going into the products, and I saw quality-control labs where they spent a lot of money trying to do all the right things. At that plant, the people really cared about what they were doing.”
- Share information on cross-contamination issues between people and pets.
“We did a seminar a couple years ago and found some interesting data that people can get Salmonellosis from basically sleeping with their pet,” says Dr. Stahl. “If you share a pillow, they eat food that’s contaminated, and they transmit it that way. Basically you’re talking about cross-contamination.”
- Reduce or eliminate China-sourced ingredients from pet food.
Sammons recalls a time when he was touring a pet food manufacturing facility and didn’t care for what he saw there: “I walked out of a plant in California, and, in my head I said, ‘I can never carry any food that comes out of this plant,’ based on what I had seen in the plant and based on their way of doing high-volume foods without paying attention to what I thought they should be paying attention to. I saw way too many ingredients from China, and the quality-control person couldn’t answer my basic questions,” he says.
- Encourage proactive approaches to FDA compliance, including regular facility audits and product testing.
“There is poor reliability in testing of pet foods,” says Dr. Royal. “You can send the same product to three different labs and get three different nutrient analyses. The error rate is too high between labs.” She has another suggestion in this area: “I would recommend required testing for pathogenic bacteria and have all manufacturers have processes in place to test for and eliminate pathogenic contamination for all types of pet foods.” Sammons says he looks for quality-control labs at pet food companies and has seen some good ones. “There are other places I’ve visited who don’t even have labs,” he explains. “One place said everything is done in-house, which kind of bothers me, too. I think it’s good to have standards, but unless you get all your information double-checked by an independent lab, I’m not sure I’m going to have a lot of confidence in you.”
- Enhance labeling requirements to make sure stated ingredients are actually in the product at the level and quality advertised.
Dr. Royal says she would welcome better standards for nutrient requirements for dogs and cats: “Pet food labels, like human food labels, can be manipulated to appear more healthful than they are. Some of this is difficult to regulate, and the consumer must simply beware.” “I believe [labeling practices] have too long been swayed by the pet food industry, rather than the actual nutritional needs of the animals,” she adds. “We have allowed poor health and poor-quality food to become the norm. I would like that to change. We can do better.” Comment deadline is February 26 FDA’s deadline for comments on the proposed pet food rule is Feb. 26, 2014, and comments can be submitted up until that date by mail, hand delivery, courier (for paper or CD-ROM submissions) or online at www.regulations.gov, where information on alternative commenting methods is also available. Once FDA has time to sift through and respond to submitted comments, potentially adjust or revise the rule, and adopt a final version, we’ll know much more about what shape the agency’s new regulations regarding pet food will take. Meanwhile, FDA offers pet-related information on its website, and, since 2010, tracks and responds to consumer complaints about pet food-related illnesses and pet food product defects on PETNet. FDA also notes that, at the present time, no federal agency is responsible for monitoring, tracking, or responding to outbreaks of foodborne disease in companion animals. The pet food safety series on Food Safety News is sponsored by ABC Research, a company that conducts testing on pet food products. Read more about ABC Research pet food testing on the company blog.