Salmonella contamination of pet food and pet treats is challenging the industry and leading to major operational changes, according to Robert Buchanan, Ph.D., director of the Center for Food Safety and Security Systems at the University of Maryland.
Buchanan, followed by a veterinary medical officer from the U.S. Food and Drug Administration (FDA) and a pet food regulatory attorney and consultant, spoke July 26, 2015, at the International Association for Food Protection (IAFP) annual meeting held this year in Portland, OR.
With decades of food safety experience at the U.S. Department of Agriculture and FDA (he was a senior science advisor at FDA’s Center for Food Safety and Nutrition for 10 years), Buchanan knows about pathogens in pet food. (He’s also a dog lover and has two West Highland White Terriers.)
“Our pets have actually been one of the predictors of what has happened to humans,” he said, mentioning the contamination of pet foods with mycotoxins and melamine. Buchanan also said that the “inherent connections” between public health, animal health and environmental health present advantageous synergies for scientific research.
About 25 percent of dogs can be asymptomatic carriers of salmonellosis, Buchanan said, adding that pets can transmit the infection to humans via physical contact (e.g., petting zoos), environmental contamination (such as rainwater runoff), fecal material (handling cat litter, etc.), scratches and bites, and vector-borne routes (such as fleas and ticks).
“In 2012, Salmonella Infantis caused a multistate outbreak involving 49 patients (people, not pets),” he said, adding that between all these outbreaks, about 53,000 tons of dry pet foods had to be recalled.
Salmonella bacteria can be brought into the home on a pet’s fur, via pet food or fecal material, or, in some cases, through direct consumption of pet food by the owner or by others in the household, Buchanan said.
“My brother’s favorite snack was a Milk-Bone when he was little. That’s actually done by more people than I would have thought,” he noted.
Under the Food Safety Modernization Act (FSMA), which FDA is in the process of implementing, there is going to be a “distinct difference in how pet foods are treated,” Buchanan predicted. “There’s been more testing of animal feeds and pet foods to assess the extent of contamination,” he said.
Salmonella data collection shows a substantial drop in prevalence after 2006, when it went from 13 percent to less than 9.8 percent now, he noted. Additional data on the long-term survival of Salmonella in pet food show that “it lasts for a very, very long time,” he said.
Pet treats have been identified as another Salmonella source, he said, adding that dog food and dog treats containing meat ingredients are much more likely to have Salmonella than those which are vegetarian.
He also said that switching from a dry pet food diet to one featuring raw foods was more likely to bring Salmonella into your house.
Buchanan said he had tallied up pet food-related recalls from August 2014 to July 2015 and found 11 separate recalls of pet foods and treats. “This is now a routine thing going on within the pet food industry,” he said.
The Peanut Corporation of America Salmonella outbreak in 2008-2009 prompted the recall of more than 3,000 products containing peanut butter, peanut paste and peanut meal, he said.
“About a third were actually pet foods or treats. So anybody in the pet food industry has to look at recalls and figure out whether they used any of those ingredients in pet foods,” Buchanan said.
Increasing consumer concern about pet food safety is finding its way into changing regulatory requirements for the industry, Buchanan noted, adding that companion animals aren’t viewed as just animals anymore, but as members of the family. He also said that FDA traditionally received more public comments regarding pet issues than anything except babies.
Since 2007, FDA has received more than 5,100 complaints about illnesses in dogs, along with 26 cats and three people, linked to jerky pet treats, said Lee Anne Palmer, VMD, MPH, supervisory veterinary medical officer at FDA’s Center for Veterinary Medicine (CVM). To date, there have been reports of more than 1,100 deaths, mostly of dogs, she added.
In her presentation, “The Deadly Jerky Pet Treats Mystery: Are We Close to Solving the Case?,” Palmer said the problem is linked to chicken, duck or sweet potato jerky treats from China, which she said are irradiated and shelf-stable for months at room temperature.
“The outbreak came to our attention in the summer of 2007 after the melamine incident was coming to a close,” Palmer recounted.
She noted that cases of Fanconi’s syndrome were also showing up (a normally rare kidney problem in dogs which people can also get), or a Fanconi’s syndrome-like disease, and that the American Veterinary Medical Association issued a safety alert about jerky treats made in China in September 2007 as a result.
Exposures associated with this disease are heavy metals, Palmer said, including cadmium, mercury and lead, plus ethylene glycol, Lysol, nitrobenzene and maleic acid. Affected dogs will exhibit extreme thirst and urination, but, “This is not a diabetes thing,” she said.
Laboratory testing of the products hasn’t resulted in anything definite, although FDA has found that the problem seems to affect smaller dogs and doesn’t seem to have a genetic component.
She compared the cases of two Pugs: One, age 10, who ate the jerky pet treats, developed renal failure, and had to be euthanized. The other, a 5-month-old puppy, ate the jerky pet treats, was promptly treated by a vet, and survived.
CVM now has about 400 samples from 230 cases that are still being tested, Palmer said. “The results show residues from five different antibiotics, and they found antiviral drugs, ethylene glycol, and xylitol,” she said. Some of the products contain glycerol, she added, and one test picked up propylene glycol.
FDA has been tracking Chinese jerky pet treat-related complaints by quarter and Palmer said that the agency wants people to continue voluntarily reporting information about their potentially affected pets and for veterinarians who may have related cases to submit pet urine samples for testing through the agency’s safety reporting portal.
“Are we really close to solving the mystery? I’d say we’re really not quite where we’d like to be. We’ve learned a lot about the processing of the product and hopefully we will get there,” she said.
Karl Nobert of The Nobert Group LLC, a regulatory attorney, talked about the impact of FSMA on pet food manufacturing and said that the basic regulations for pet food are that it must be “safe to eat, produced under sanitary conditions, contain no harmful substances and be truthfully labeled.”
Pet food manufacturing and distribution in the U.S. is regulated by FDA, USDA, Federal Trade Commission, the states, plus the Association of American Feed Control Officials (AAFCO) and the National Advertising Division (subscription-based).
One pet peeve attorneys have with FDA is that the agency “is regulating from guidance documents,” Nobert said. As a result, “What you have is the agency’s interpretation of the regulation,” he said.
There is no pre-market approval required for pet food product development and formulation, so, “You are not putting your food in front of the agency,” Nobert noted.
Claims that can get pet food companies into trouble if there isn’t any science to support them include that a product maintains urinary tract health or offers low magnesium, tartar control, hairball control, and/or improved digestibility.
“Claims must be truthful and accurate; they may not be false or misleading,” he said.
Changes due to FSMA that he sees on the pet food industry horizon include government regulators being more proactive rather than reactive, inspecting foreign facilities, and requiring maintenance of certain records.
New enforcement tools under FSMA give FDA mandatory recall authority when there is a “reasonable probability” that food is adulterated or misbranded by failing to disclose major food allergens and/or a reasonable probability the food will cause serious adverse health consequences or deaths, and the responsible party pays for all FDA recall activity expenses, Nobert said.
He mentioned FDA’s “expanded reliance” on the Park Doctrine, established by U.S. Supreme Court case law, which states that a responsible corporate official can be held liable for a first-time misdemeanor (and a possible subsequent felony) under the Federal Food, Drug, and Cosmetic Act without proof that the corporate official acted with intent or even negligence, and even if such corporate official did not have any actual knowledge of, or participation in, the specific offense.
Nobert said this means that “those in a position to know [about a food safety problem] should have known,” signaling a likely increase in responsibilities and oversight by industry executives going forward.
He noted that FDA warning letters to pet food manufacturers typically involve missing ingredients, deviations from low-acid canned food regulations, misbranded product, and issues relating to allegations of illegal drug residues/adulterated/misbranded.
“You actually see very few letters going to pet food companies,” Nobert said.
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