By far, the most interesting session at the AAFCO Mid Year Meeting was the presentation given by Dr. Xin Li of the FDA concerning the summary of FDA sampling in raw food for dogs and cats. Dr. Li is a microbiologist at the CVM, which is the veterinary branch of the FDA. This office deals with recalls and disease outbreaks, and includes the Office of Surveillance and Compliance.
In May 2015, the assignment was issued to test and culture raw pet foods. Raw foods are becoming more popular, so the raw pet food companies have a target on their backs. The first slides Dr. Li put up showed results of Salmonella prevalence in DRY pet food and treats for the years 2002-2014. Before 2010, dry pet food had a contamination rate of about 10%. The manufacturers must have gotten better at controlling contamination after that, because the rates have fallen to about 1.5% since then. Treats had a 12% contamination rate prior to 2007, then fell to just under 5%. Since 2010, treats are still coming in with about 3% of those tested containing salmonella. One of the biggest offenders in this category is pig ears.
In a published study in 2014, 196 samples of raw dog and cat food were tested and 15 (7.7%) were found to be positive for Salmonella bacteria. An additional 32 (16.3%) were found to be positive for Listeria.The reason for the testing and concern about Salmonella contamination in pet food is the association between human outbreaks of salmonellosis and contaminated pet food. The CDC reported 79 cases of human salmonellosis from DRY dog food between January 2006 and October 2008. In 2012, 49 human cases were linked to DRY dog food. 42% of those people were hospitalized for treatment. So the FDA believes regulatory action is warranted in cases involving pet foods contaminated with any Salmonella bacteria, due to the heightened human health risk, given the high likelihood of direct human contact with such food and pets eating the food.
In a study performed in 2002, 80% of samples of raw chicken dog food diets tested positive for Salmonella. 30% of the stool samples from dogs fed the diet tested positive.
In 2007 a study showed that 50% of dogs fed Salmonella-contaminated raw food diets shed Salmonella in their feces. Because the bacteria is shed in the stool, there is concern that people living with those dogs may be exposed and suffer illness.
Because of these studies, the FDA decided raw pet foods needed to be tested. This is interesting because no studies were shown that linked shedding of Salmonella in feces of dogs fed contaminated DRY food. It’s also interesting because NO HUMAN ILLNESSES have been linked to contaminated raw food, only dry food and treats.
After all the testing was done in the past six months, there were recalls of raw pet food associated with Salmonella contamination. These included Oma’s Pride raw cat food, J.J. Fuds Raw Pet food, OC Raw cat and dog food, Nature’s Variety, Northwest Farm Food Cooperative, K-9 Kraving Dog food, and Bravo Raw Pet Food. Listeria was found and resulted in recalls by J.J. Fuds, Carnivore Meat Company, K-9 Kraving, and Stella & Chewy’s. All products were purchased from retail stores for testing. The FDA was also looking for E. coli in samples, but was unable to find any.
Of the batches tested by the FDA, 4 frozen raw products had positive tests (11.4%) and one freeze dried raw product tested positive (3.1% of samples). Susan Thixton (Association for Truth in Pet Food) boldly asked how many tons of dry pet food have been recalled versus how many tons of raw pet food have been recalled. There was no response other than, “we do not have that data.” You can bet there has been a LOT more dry food contaminated than raw food.
The FDA has a ZERO tolerance to E. coli, Salmonella, and Listeria found in pet food. What is interesting is that the USDA has a HIGH tolerance for bacterial growth in USDA approved poultry meats sold for human consumption. On average, 20% of chicken purchased in grocery stores will have a positive culture for salmonella, which sickens more than one million people per year according to some estimates (others go up to 48 million!). Why the discrepancy? Because they ASSUME all individuals will cook the grocery store meat to a high enough internal temperature to kill the bacteria before consumption. They also ASSUME all individuals will use safe handling practices for raw meat in the kitchen. Yet the chance your pet MIGHT shed bacteria in the feces (yes, in one study 30% had positive feces and in the other study 50% had positive feces) results in ZERO tolerance for salmonella in pet food. And while contaminated dry pet food and treats have caused many human illnesses, the FDA feels it is imperative to go after raw food companies.
Roxanne Strong, of Answers Pet Food, brought up a valid point to the committee. By targeting the raw food companies and publishing statements against raw food companies, pet owners are being driven to a DIY (do it yourself) form of raw feeding. They purchase contaminated food approved by the USDA in the supermarkets and feed it raw to their pets, assuming they are feeding a good product. The chances of contamination of a high quality raw pet food are much less than the chances of contamination when feeding USDA grocery store meats. Dr. Jean Hofve was met with laughter when she suggested that perhaps the solution would be to clean up the meat industry…