Voluntary Versus Mandatory Food Recalls

Lately it seems there are weekly recalls in the pet food industry; contamination with euthanasia solution, bacteria, or endotoxins, over or under-supplementation of vitamins and minerals, and inclusion of foreign material in food may all result in a recall. If it feels like there have been more raw pet food recalls than kibble recalls for bacterial contamination, you are absolutely correct. FDA and state authorities have been selecting more raw foods for testing than any other type of food for at least the past year. The reason for the targeting is that FDA has set a zero tolerance level for bacteria in raw pet food. Some believe the raw food manufacturers are being targeted because the big three kibble-based manufacturers have a large lobbying group that talks to government officials. There certainly is no large lobbying power (although a new group has been formed to represent them) for the small raw food manufacturers.

But who decides whether a product should be recalled? Do animals or people have to get sick or die in order for a recall to occur? Is it up to the government or the pet food company to issue the recall? Recalls may be conducted by a company's own initiative, by FDA request, or by FDA order under statutory authority. In a nutshell, a voluntary recall can be put into effect by either the company which made the product or U.S. regulatory authorities. A mandatory recall is issued by the U.S. government. The most recent recalls listed on the FDA website include:

Date Brand Name Product Description Reason/ Problem Company
01/31/2019 Hill's Science Diet Canned Dog Food Elevated Vitamin D levels Hill's Pet Nutrition
12/28/2018 Purina Lamb chow Elevated copper level Purina Animal Nutrition
12/21/2018 Columbia River Natural Pet Foods Dog and Cat fresh frozen meats Potential to be contaminated with Salmonella and Listeria monocytogenes Columbia River Natural Pet Foods
12/07/2018 9Lives Cat food Low levels of Thiamine J.M Smuckers Company
12/05/2018 Columbia River Natural Pet Foods Frozen meat product for dogs and cats Listeria monocytogenes Columbia River Natural Pet Foods
12/05/2018 Abound Chicken & Brown Rice Recipe dog food Elevated level of Vitamin D King Soopers
12/05/2018 Abound Chicken & Brown Rice Recipe dog food Elevated level of Vitamin D The Kroger Company
11/29/2018 Elm Pet Foods Pet Food Elevated levels of Vitamin D ELM Pet Foods
11/28/2018 ANF Lamb and Rice Dry Dog Food Elevated Levels of Vitamin D ANF, Inc
11/27/2018 Evolve, Sportsman's Pride, and Triumph Dry Dog Food Potentially elevated levels of Vitamin D Sunshine Mills Inc.

The list posted above is from the FDA website. It does NOT indicate whether the recalls were voluntary or mandatory, unless you click on the highlighted individual companies. (All I could find were voluntary recalls, which means the FDA applied some pressure and the companies opted to recall without FDA issuing a mandatory recall.)One glance shows many companies affected by elevated levels of Vitamin D. Large recalls involving many brands occur commonly when a common source of vitamin/mineral pre-mix or meat meal ingredient is shared by multiple companies. In this case, somewhere along the way the vitamin premix had too much Vitamin D added, causing many brands to be recalled. Sadly, the elevated levels were known as far back as November 2nd, yet Hill's was not recalled until the end of January. That means, for three extra months, pets were exposed to life threatening levels of excess Vitamin D, which can cause high levels of calcium, kidney stones, kidney failure, seizures, and death. Clearly, if the same premix was used by Hill's, they should have been aware of the issue months earlier. (As of this writing, no one has publicly said where the initial premix was made.)

The big question: when FDA applies pressure, does the company have to issue a recall? The answer is NO. Right now, Answers Pet Food and Hare Today Gone Tomorrow are fighting back. They were both targeted as raw food companies for bacterial testing. Thankfully, these two companies were strong enough to question testing methods, request samples for testing, and tested their own batches of the same food regulatory officials confiscated. They were able to show inconsistencies in handling and testing. If more companies can follow through in this manner, perhaps the playing field will get leveled. We have a long way to go.

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