On March 31, 2013, I announced that I was “moving on,” and I ended my daily posts on eFoodAlert. Since then, I have been concentrating on my creative writing projects. Nevertheless, I’ve continued to monitor food safety stories, muttering under my breath from time to time about the quality of some of the coverage. But I have not been motivated to comment publicly on any of these stories until today’s release of a pet food safety study carried out under the auspices of the Association for Truth in Pet Food (ATPF). I decided that I could not let this report stand unchallenged and unanswered. The Association for Truth in Pet Food, headed by Susan Thixton, has just released a report that details the results of mycotoxin, nutrient and bacteria tests carried out on a number of brands of canned and dry cat foods and dog foods. According to James Andrews, writing for Food Safety News, the testing program was sponsored by consumers through crowdfunding and coordinated by ATPF. Susan Thixton, writing in her TruthAboutPetFood.com blog, describes the results of the study as “shocking and sad.” In my opinion, her adjectives are correct but misapplied. What I find “shocking and sad” is the waste of consumers’ money in a wild goose chase after low-level pathogens of minimal risk to either humans or their pets. Consider the “qualifying pathogens” reported in the detailed study:

  • Acinetobacter. This is a low-grade pathogen that is mainly associated with hospital-acquired infections (especially in intensive care units), or with community-spread outbreaks in war zones and natural disaster areas.
  • Pseudomonas. These bacteria are present in the environment, in our water, and in food. It is a cause of “swimmer’s ear.” Otherwise, Pseudomonas is an opportunistic pathogen, typically either hospital-acquired or affecting individuals with compromised immune systems or respiratory systems, such as cystic fibrosis patients.
  • Streptococcus. While some species of Streptococcus are pathogenic (e.g., Streptococcus pyogenes), others are benign. Some species of Streptococcus are used in the production of fermented dairy products and are considered to be probiotic.
  • Staphylococcus. While Staphylococcus aureus is associated with food poisoning (via its production of enterotoxins) and with infections, other species of Staphylococcus are either benign or are low-grade pathogens associated with hospital-acquired infections. Staphylococcus epidermidis is a common inhabitant of the skin of humans and animals. Even Staphylococcus aureus is carried on the skin and in the nasal passages of many individuals.
  • Bacillus. Most species of Bacillus are benign and are widely dispersed in the environment. Bacillus is a spore-former and very heat-resistant. It can be found with great frequency in dried foods, including spices, flour, and powdered dairy products. Bacillus cereus is a source of foodborne illness, but it must attain high concentrations before it can cause illness.

In addition to these “qualifying pathogens,” the study organizers decided to troll through the foods for a long list of other irrelevant microbes, including Anaerococcus, Comamonadaceae, Corynebacteriaceae, Halomonas (another low-risk pathogen associated with contamination of intravenous lines), Cloacibacterium, Bifidobacterium (a probiotic), Pantoea, Gemella, Peptoniphilus, Actinomyces, Sphingobium, Bradyrhizobium, Tumebacillus, Paracoccus, Paenibacillus, Lactococcus, AcetobacterChloroplast and Lactobacillus (a probiotic). The author of the study provided absolutely no rationale for this selection. Nor was any explanation offered for excluding known human and animal pathogens, such as Salmonella and Campylobacter, from the list. Where was the logic in this? What was the point in throwing money at a laundry list of irrelevant microbes? The funding did not allow species-level identification of any of the bacteria, according to the study report. Yet, without species-level identification, the results of the bacterial testing of the pet foods are worthless. I also take issue with the presentation of the mycotoxin test results. The results are reported at levels of parts per billion (PPB), whereas these results are usually reported as parts per million (ppm). By changing the manner of reporting the results, the study makes the data appear more shocking. For example, FDA recommends a limit of 10 ppm for fumonisins in grain destined for pet food. This is the same as saying 10,000 parts per billion. Even the worst-performing pet food sample was well within this guidance level. Furthermore, the comparison table presents an arbitrary set of risk values generated using a proprietary formula developed by Alltech, an animal nutrition company. There is no way to substantiate the validity or the significance of these so-called risk levels. I have refrained from commenting on the portion of the report dealing with nutritional analysis, as this is outside of my expertise. I sincerely hope that someone else will put this portion of the report under a microscope. I acknowledge the good intentions of Susan Thixton and the Association for Truth in Pet Food, but 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. The pet-loving consumers who funded this study — and their dogs and cats — deserved far better.

  • mainecoonmom

    “On March 31, 2013, I announced that I was “moving on,” and I ended my daily posts on eFoodAlert. Since then, I have been concentrating on my creative writing projects. Nevertheless, I’ve continued to monitor food safety stories, muttering under my breath from time to time about the quality of some of the coverage.”

    Ms. Entis can you please share your credentials? I too monitor food safety issues published thankfully here on Food Safety News. I do not profess to be any sort of expert, just someone who is trying to protect my family, my cats and myself.

    Thank you.

    • Phyllis (former FoodBugLady)

      I am happy to share my credentials. I have a BSc. from McGill University in Montreal (Honours Microbiology & Immunology), and a MSc. from the University of Toronto (Mycology). I was employed as a microbiologist by Canada’s Health Protection Branch (Canadian equivalent of FDA) from 1972 to 1979, and spent the last four years as head of the microbiology lab group for the Quebec Region. From 1979 to 2001, I was Research Director of QA Laboratories Limited (in Canada) and QA Life Sciences, Inc. (in the USA), during which time I was responsible for developing a series of rapid tests for food borne pathogens, validating those tests through AOAC International, and providing technical support to the Company’s clients, which included some of the largest national and multinational food companies. After 2001, I was a consultant to several clients, including a number of attorneys who represented victims of food poisoning. I have written two text books: FOOD MICROBIOLOGY – THE LABORATORY (Published by Food Processors Institute) and FOOD SAFETY: OLD HABITS, NEW PERSPECTIVES (Published in 2007 by the American Society for Microbiology Press). I developed, researched and wrote the eFoodAlert food safety blog for five years, retiring in 2013 to turn my attention to writing fiction.

      Please note that I am not, and never have been, a veterinarian or a veterinary nutritionist. I deliberately refrained from making any comments or observations on the nutritional aspects of the Pet Food Report, as I do not feel competent to evaluate that portion of the study. I have posted a follow-up to my initial eFoodAlert posting on the Pet Food Report, which can be found at https://efoodalert.wordpress.com/2015/01/08/still-shocked-and-saddened.

      Also, please note, in response to one other commenter. My husband and I live with a twelve-year old Australian Labradoodle, Quintzy.

  • tallen2007

    No one seems to know what prompted Ms Entis to come out of retirement to unfairly attack a report that she has obviously not checked her facts on. The rebuttal to this by Ms Thixton will addressthose concerns. I have only checked one tiny part of the study And wanted to share as an an example of Ms Entis misinformation. Per a quick search of FSN I found 8 references to Acinetobacter (https://www.foodsafetynews.com/search/?q=Acinetobacter#.VK_ffKZ8Ic0) as being a FOOD SAFETY RISK, including this quote: “In February (2011) I blogged about chicken testing being done in
    London, where 20 grocery store chickens tested positive for E. coli,
    Staphylococcus aureus, Acinetobacter baumannii, Mirabilis, or
    Micrococcus luteus.” From Publisher’s Platform: Is Your Chicken Safe? It doesn’t matter that the species wasn’t tested because knowing the Acinetobacter species is not of concern. Per FSN 2014:

    White House Releases Spring 2014 Regulatory Plan


    “And a list of pathogens
    with the potential to pose a serious threat to public health (including
    Acinetobacter species, Staphylococcus aureus, Campylobacter species,
    Clostridium difficile and Vibrio cholera) has inched past its expected
    date in June but is still required to be published by July 9.)

    This is one tiny piece of this study. Instead of tearing the study apart maybe we should focus on the big picture of why all of this stuff is in supposedly (per Pet Food Industry) thoroughly cooked and safe pet food.

  • JTAK Food Safety

    Well said and welcome back Phyllis, even for this brief moment.

  • Food Microbiologist

    Good for you for taking the time to read and comment. I stopped about two thirds the way down from disgust at the poor science.

  • Sarah R

    Thank you! I was confused as I read it yesterday on those organisms choices. I didn’t have any hand in funding this junk report, but feel bad for those who did.

    • tallen2007

      There were no “choices” as MS Entis and others proclaim. The foods were tested for ANY and ALL organisms, NOT specific ones. What is listed is what was found. If it’s not listed it’s because it wasn’t there. Ms Entis and others did not read or follow the purpose of the study and therefore her comments are misleading. The upcoming rebuttal to this “opinion” piece will make this all very clear.

  • Nicole

    It sounds like you are writing on behalf of the pet food
    manufacturers. I don’t think you have a pet or you wouldn’t have written the article in such a contemptible tone. You really missed the point of the testing results.

    Are you curious why so many hospital acquired pathogens are
    in pet food? Hospital acquired or nosocomial infections are caused by bacteria
    that are extremely drug resistant. Why is there a bacteria associated with intravenous lines in my pets food. Where do you suppose all of the diseased antibiotic riddled animals go? You aren’t eating them, you hope anyway. Your
    pet is.

    The point of the article is that the manufacturers say
    listen yes we are using diseased animals, the ones discarded for human
    consumption, a bunch of recalled human meat, perhaps even some road kill and
    well sometimes we throw in a euthanized animal or one with sutures …oops did we
    leave a suture in … the ones that have bacteria that are resistant to
    antibiotics, but don’t worry, kibble and canned food are cooked at such a high
    temperature that all of these bacteria are killed. So just because we use these
    downers and bad ingredients you don’t have to be concerned. Based upon the results, that is obviously not true.

    And to be clear not all manufacturers opt for the cheap way out. There is a reason the supermarket and many other brands of foods are so much cheaper than others.

    So if my dog is eating food with antibiotic resistant bacteria from diseased animals over the course of his life, can we say that my dog may develop resistance should he develop an infection or even get sick from the pathogen in the food? Do you know how many pets suffer from GI issues? Why do you suppose that is.

    Further, myotoxins cause severe illness and death in animals. Why you ask. Because they can’t be cooked out. So that moldy wheat or
    corn that you aren’t eating. Guess who is getting that? Yup, your dog. When a manufacturer says, this food is safe and won’t make your dog sick and then they use moldy crops, well most owners have an issue with this. There have been many recalls of pet food because of this.

    Regarding your complaint about the lack of salmonella
    testing, first off they may not have tested for this because the manufactures are testing for this. Not because of the animal mind you. Most dogs can handle salmonella. The stomach acid is so strong that it kills this bacteria. Salmonella laden food is tested for because your precious 3 year old may handle the food and then put his hand in his mouth. If that 3 year gets sick, the monetary exposure is high. Lose a pet, not so much. But the testing wasn’t about humans, it’s about the pets.

    And in terms of nutrients pets must have a specified near
    exact ratio of calcium to prosperous. For dogs, it is generally 1.1 calcium to
    1.0 phosphorous. If that is thrown off, there will be consequences. Manufacturers
    have convinced pet owners that feeding garbage processed food with added
    nutrients is healthy. Animals are carnivores. The pet food is supposed to mimic
    their natural nutritional needs. It does not.

    The pet food manufactures (not all) don’t actually care about the pets. Only that people buy the food, pay them money and fingers crossed, your pet won’t get sick or die.

    I am very thankful for the study, which you criticize. Who else is
    going to do this testing? Certainly not the manufacturers. Could you imagine?
    Hey we told you the high heat kills all the bacteria and we don’t use moldy discarded crops but we weren’t being honest with you. i don’t think that is going to happen.

    And in the interest of full disclosure, I feed my animals a raw diet of non-diseased, non-moldy food that I would eat myself.

    • FoodSci

      What is the clinical presentation of salmonellosis in dogs and cats?
      Dogs and cats can become ill due to a Salmonella infection and have diarrhea, fever, vomiting, decreased appetite, or abdominal pain; however, some dogs and cats may be asymptomatic. Like humans, some dogs and cats can become carriers and can infect other animals or humans. If your client has a pet that is known to have eaten any of the recalled products and they have concerns that the pet may have salmonellosis, they may want to bring the pet to you, their veterinarian, for assessment.
      You’d eat a raw diet? Have you submitted that for microbial testing?

  • johnmarkcarter

    The original report is so poorly documented that I can’t tell how the bacterial tests were performed. I saw no quantitative microbiology data, so I can’t tell whether there was enough bacteria to cause disease (ID50 per serving). Based on the data format, it looks like they did 16S rDNA analysis and then went database fishing for matches. That means the bacteria they detected may have been dead – killed by standard processing under HACCP. There is no information on experimental replicates, standards, or controls; so I can’t tell whether the science is “junk”. But the interpretation is certainly hyped to induce fear and outrage in pet owners.

    • tallen2007

      Thank you for a voice of reason. Obviously this report was geared towards pet owners not scientists! From what I undertand MS Thixton will be releasing the actually scientific report to anyone who sends her an email, including the manufacturers of the pet food tested. After you and other scientists review those papers then we would welcome knowledgeable discussion of methodolgy and I’m sure anyone offering to help do further testing would be gratefully welcomed!

    • kateiacy

      Thank you.

  • 3catkidneyfailure

    I guess my question for you, Phyllis, would be, as it was in the 2007 pet food recalls, why didn’t some trained individual come forward to help pet food consumers? Veterinarians would not come forward to assist. FDA offiicials would not offer help. Even Mr. Marler’s own law firm did not respond to a request for assistance. Could it be that there is too much money and media advertising revenue and research funding for anyone to speak up about the garbage content of many commercial pet foods?
    At least this group is trying to call attention to problems with commercial pet products that cause illness in many pets. Why don’t you offer some non-junk science advice to this consumer group as to what to test for? I am sure the crowd source funding could be raised for more testing. Perhaps a better science adviser could be hired by this consumer group, too. But after having met this group back in 2007 trying to unravel the melamine that killed so many pets in this country, don’t question a sincere desire to have healthier pet food produced and pet owners who are trying to do that. Just offer some real assistance

  • Nancy

    Dear Phyllis, Now that the pet food companies most likely pulled you out of retirement to comment
    on this “JUNK SCIENCE” perhaps you could clarify a few things for me. Your comments about this
    paid for by consumers PET FOOD TEST leaves much to be desired. It’s lacking in specifics such as who did the study. Such as Who were the doctors? From what company? What kind of credentials do these men have behind them? Are they affiliated with perhaps let’s say the Forensic Sciences? Do they provide animal and agricultural forensic science services to companies world wide? Are they board certified? How many cases have they participated in? What
    do their peers think of them? Oh, I see one of them has won the AAFS General Section Achievement Award, the FIRST TIME an animal professional received the award since 1948. Why
    that’s pretty darn good don’t you think??
    What you find shocking “is the waste of consumer money on a wild goose chase over a low level pathogen of minimal risk to either humans or their pets” Well lets take a look at one of those because that’s enough for me.
    ACINETOBACTER- this is a low grade pathogen found in hospital acquired infections. Especially in
    intensive care units. I used to work in one by the way. What I would like to know is: What the hell is it doing in our pet food??
    Phyllis, I have a five year old It. greyhound I adopted in August. Started her out on Blue Buffalo
    Life Protection mid October. It is now Jan. 9th and she is still sick. $3400 in vet bills and I’m on disability. The consumers money was NOT WASTED. We know the results on those tests and
    they will be passed around. I think you need to go back into retirement if you’re just going to do
    a half-***ed job of spouting off what you think of something you didn’t even check out. You’ve done a disservice to some truly wonderful professionals, to the consumers that have been ripped off by pet food companies, the FDA and the likes of you. But that’s just my opinion.
    Why don’t you be the one that puts this report under the microscope since you’re the one who
    doesn’t seem to see things clearly.

  • Pacificsun

    A couple of things are clear:

    (1) Ms.Entis (assuming the mindset of a scientist) fails to reference the Pet Food Test documents accurately. Read the article “It is NOT Junk Science.” http://truthaboutpetfood.com/it-is-not-junk-science/

    (2) She criticizes the work of professionals and institutions without consulting with them first for clarity and context. This is hardly objective reporting and does suggest a need for haste!

    (3) The language of her article isn’t scientifically objective instead choosing inflammatory
    words (like “trolling” instead of searching).

    (4) She mis-read what pathogens were indeed searched for and already declared not found in the article (Salmonella and Campylobacter). Instead choosing to characterize intended negligence or manipulation.

    (5) She appears to be defending the presence of bacteria and mycotoxins in a product that is deemed safe through high heat processing, without explaining / justifying their origination / existence. Is she saying the product is absolutely safe no matter the results?

    (6) She fails to acknowledge the cumulative effect of consuming multiple pathogens and mycotoxins via a daily diet or by a pet with a compromised or existing health risk. She fails to acknowledge a product with known bacteria is being used inside a household. along side human food, and is handled by children and adults with compromised health risks. She fails to discuss advice for cautionary labeling and handling instructions.

    (7) She ignores or chooses not to consider pathogens potentially causing illnesses in pets when Vets can find no other explanation. She fails to acknowledge that with more understanding Vets could be working to test for particular causes of illness to better understand appropriate remedies.

    (8) She fails to acknowledge this Pet Food Testing as a necessary “Step I” requiring more investigation! Instead of just debunking it, while not push for further study?

    As a result of the above points, what ~ IS ~ clear is that the pet food industry (or those profiting by it like sellers and distributors) and / or any opposing opinions, rather than submitting their own rebuttal, explanations, and defense required an immediate discredit to the original post (on the internet) to sit right along side the “Pet Food Test Results” article, in order to CREATE immediate doubt! Ms. Entis (for whatever reasons) seemed ready at their disposal to comply. Or saw a moment of self-serving publicity by being the “first” to critique it without obtaining complete context first. Her choice of language (like Junk Science) was useful for making an instant headline. (Note: there are few actions in this world that are without motivation. The question is which kind?).

  • Erica

    are You calling a board certified veterinary nutritionist and a member of the
    American Academy of Forensic Scientists junk science? Are
    You calling science performed by a leading university junk science?

    FYI: Susan makes a good point that It does not matter if bacteria found in the test results are known to be found in hospital acquired infections , Why were they found In pet food? They are linked to serious human illness and linked to
    spoilage of meat.

    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. This was not just Susan’s or
    any of the food tester’s opinions. If you would have done your research before
    reading only a portion of the results, then making assumptions about the
    seriousness of the bacteria and mold found then attacking people who are trying
    to protect our pets from toxins, you would see that these things found are of a
    REAL HEALTH CONCERN to all of us pet consumers,and FDA as they should be to you.

    You state that Acinetobacter (found in 8 pet foods) is a “low-grade
    pathogen that is mainly associated with hospital-acquired infections.
    The FDA has classified Acinetobacter as a “Qualifying Pathogen” and it is listed in the Federal Registry.

    You also state that Pseudomonas bacteria “These bacteria are present in
    the environment, in our water, and in food. It is a cause of ‘swimmer ear.
    FYI: the Food and Agriculture Organization of the United Nations lists
    Pseudomonas as “microorganisms causing microbiological spoilage of meat”
    stating specifically that Pseudomonas is a bacteria that causes “putrefaction”
    of meat.

    you discount the risk of Streptococcus, Staphylococcus, and Bacillus.
    the FDA discusses these bacteria and their risks to humans – at length – in
    their “Handbook of Food borne Pathogenic Microorganisms and
    Natural Toxins”

    Every one’s question is, Why where these things in pet food?? Don’t you want to know
    as well?

    You suggests that Susan intentionally changed the results from parts per
    million to parts per billion to make “the data appear more
    shocking”. This is false information. The results were provided to
    Susan as parts per billion and she provided them to consumers as parts per
    billion. Ms. Entis you suggest that FDA states mycotoxin levels in parts per
    million. As you can see in the FDA Guidance document, the FDA states aflatoxin levels in parts
    per billion – just as Susan Stated.

    This is only the tip of the ice burg for what will be discovered in future pet food
    testing. The testing will result in national pet food awareness with consumers
    and hopefully encourage laws to be enforced. I hope you will do your research
    next time and list resources for your information when you state it, just as I
    have provided resources for the information stated above.

    • do your research!

      Most of the bacteria found in this study posses no threat unless your dog has aids or some other type of immune deficiency.

      This type of mycotoxin, fumonisins is reported in ppm, not ppb. So she is correct there. Alfatoxins for example are reported in ppb. So some mycotoxins are legislated in ppb and some other types in ppm

  • Coral Beach

    Thank you, Phyllis, for sharing your insight. As a pet owner, I was pretty horrified when I saw the mainstream media coverage of this research. I, too, wondered why salmonella was left off the list. I appreciate you taking time to provide additional info on this study.

    • Mollie Morrissette

      It wasn’t intentionally “left off the list” – it just wasn’t not found.