Veterinarians and Pet Food Safety

Do your clients know what’s in their pet’s food, or where it comes from?

November 21, 2013

by Barry Kellogg, VMD

The Humane Society Veterinary Medical Association is concerned that the recent jerky treat and dog food recalls due to reports of illness have not been solved or even totally understood. I am sure most veterinarians are at least aware of the issue, the details of which can be found in our recently published alert to pet owners.

Looking at it from the veterinary perspective, however, we need to explore the issue further to understand how it impacts the clients and animals we care for, and us. The complaints the Food and Drug Administration has received involve different sizes, ages, and breeds of dogs. According to the report, "about 60 percent of the reports are for gastrointestinal illness (with or without elevated liver enzymes) and about 30 percent relate to kidney or urinary signs. The remaining 10 percent of cases involve a variety of other signs, including convulsions, tremors, hives, and skin irritation."

Along with the report, the FDA released a Dear Veterinarian letter asking veterinarians to report any suspected jerky treat-related illnesses so they may properly investigate the issue. The agency is also requesting that veterinarians obtain a urine sample (10 ml if possible) from dogs or cats that may have illness associated with jerky treats and freeze it for Fanconi syndrome testing by the FDA’s Veterinary Laboratory Investigation and Response Network (Vet-LIRN). Fanconi syndrome is a specific kind of kidney disease associated with 135 of the kidney and urinary cases. This testing will allow the FDA to get a better idea of how many of the suspected cases involve Fanconi syndrome.

In order to provide some insight and understanding for the veterinary community about the current regulations and oversight or lack of them on the production of pet food and animal treats in this country, I recently had an in-depth discussion with Mr. John Gigliotti, the CEO and Founder of Whole Life Pet Food Company. I have asked him a variety of pertinent questions regarding the current situation. I have known and worked with John for many years and he has an extensive knowledge of the industry and animal health and nutrition and the pet food industry. He and his company exemplify the way it should be done! Here are some of the questions and key points that arose during our conversation:

DR. BARRY KELLOGG: John, can you summarize for us the current oversight that FDA has or doesn't have on the production and labeling of Pet Food?

Whole Life Pet Food Company CEO and Founder, John Gigliotti
Whole Life Pet Food Company

JOHN GIGLIOTTI: There are currently no systems in place where pet food and treat manufacturers have to apply for and meet any requirements prior to the start of manufacturing, packaging and selling products into the pet channel.

When I opened my facility, I went first to my local board of health for what I assumed would be a process to be certified and was told that no such thing existed because I was in the pet food industry.

There is however a “voluntary food facility application” with the FDA that our company did register for which then triggered a random walk-in inspection by the FDA. However, I do have to stress that this was a voluntary application.

During their visit, they examined our entire process from receipt of raw materials to finished goods. They also covered sanitation, complaint procedures, recall procedures and reviewed sampling/testing procedures and results. Samples of products were also taken and tested. Inventory from the lot sampled was held in quarantine until the FDA contacted us with negative test results, releasing that lot.

There were no requirements made of us for the future and ongoing testing of our products. Although we actually test every batch of product we make daily and hold inventory until lab results are verified to have negative results, no such requirement is made of us by the FDA.

BK: Is this different for the production of treats?

JG: No

BK: Does food have to be labeled as to where it is produced?

JG: During our voluntary FDA inspection, labeling was examined for statement of identity, net quantity of contents, ingredient listings, name and place of business and nutritional information, without attention to the source of the ingredients.

BK: Would this be the same for treats?

JG: Yes

BK: If ingredients are imported from another country and then used here to produce a final product, do they have to be labeled as such?

JG: I am unaware of any such requirement and do not believe one exists.

BK: Does the FDA or anyone do sampling or testing for bacteria or contaminants on a routine basis?

JG: The FDA currently performs two types of sampling that I am aware of. One is random sampling from products taken off retail shelves. Secondly, samples are taken from random facility inspections. Neither of these are routine tests.

BK: Do you feel that is necessary?

JG: Yes, these samples are absolutely necessary and should continue to be taken randomly.

BK: Are you aware of the new rules proposed for the Pet Food Industry and do you feel they will make a significant change in the safety of the products?

JG: Yes, I am aware of these proposed changes and very much in favor of them. If they are enforced, they will make a significant change in the overall safety of pet food and treats, however there still needs to be additional steps put in place. The real danger is in the ability of new companies to enter the market place, produce food or treats in an un-inspected facility and sell them anywhere in the country with no restrictions. There is nothing in place to prevent this. This is a key issue due to tremendous growth of the pet industry and how that attracts thousands of new companies to enter the market each year. New manufacturers of pet food and treats must be forced to begin operations at a certain safety standard with a minimum of what a restaurant or food service provider would be required to in the human food industry.

BK: How can a veterinarian advise his or her clients as to what to look for and how to avoid issues?

JG: I would recommend several ways to advise their clients.

First is to direct them to the FDA website to review the list of recalls currently on file. Second, transparency and trust is extremely important: instruct pet owners and veterinarians to contact the companies that make the food or treats they are using and ask the following questions:

  1. Where are ingredients sourced?
  2. Where is the product manufactured and packaged?
  3. Who does the manufacturing (very few pet food and treat companies make their own products)?
  4. Does the company perform batch testing for each batch made, or random sample testing? If random, how often are tests performed.
  5. Does the company hold inventory until lab tests are confirmed negative?

If these very simple questions cannot be answered, the client should not use this product.

Lastly, pet owners should be suspect of new companies with no history. This is due to the lack of barriers to entering the market.

In conclusion, one has to keep in mind that previous Chinese imported goods have had issues with safety:

  1. The cadmium-in-paint issue
  2. The melamine issue: Melamine has been an adulterant for feedstock and milk in mainland China for several years now because it can make diluted or poor quality material appear to be higher in protein content by elevating the total nitrogen content detected by some simple protein tests.

Therefore, a simple conclusion can be reached that pet food or treats that are manufactured in or imported from China should never be fed to pets. This also includes products produced here in the USA, but using ingredients from China.

While the final responsibility to avoid these products lies at present with the consumer or pet owner, HSVMA believes that veterinarians also have a responsibility to make sure clients are aware of the potential health risks associated with these products.