An ‘FDA Warning Letter’ is not just a ‘Warning’

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If you’re just catching up, Midwestern Pet Foods (manufacturer of Earthborn, ProPac, SportMix, CanineX…

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When a Simple Switch for Hades Meant Big Changes

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When our loyal customer, Brandon shared his “raw story” with us, it was too heartwarming not to share! The below is Brandon’s first hand experience with switching his picky German Shepherd to a minimally processed diet…

“I was surprised with my best friend “Hades” 5 years ago by my girlfriend Chelsea and how can anyone forget that moment? A box was checked off the bucket list as we prepared ourselves for a great future with the little guy (a thirteen week old German Shepherd).

Although, things changed drastically. When we had picked up Hades, he was actually within the progressive stage of Kennel Cough into Pneumonia. Tough, I know but luckily after immediate veterinarian assistance and a few weeks to recoup, Hades tackled Pneumonia and made it out okay. We were warned though that he most likely not grow to the normal size of a GSD and certain attributes (lungs, heart…etc) would not develop fully. Then we met Nicci and her staff at NorthPoint.

Hades was a VERY picky eater when he came home from the hospital and we struggled big time when it came to getting him to eat. Numerous bags of dry food went to waste because he seemed to have become bored with it, as well as wet food. We found it tough to gain back the weight he had lost when he got sick, too.

Luckily enough I had discovered NorthPoint Pets & Company in the middle of this dilemma and a simple 10 minute conversation with the staff re-directed my mind state from kibble to raw. We gave raw a shot and I’ll tell you what, we’ll never switch back. Instantly, Hades was hooked. Not only was it a simple switch but the benefits showed immediately.

 

Not only was it a simple switch but the benefits showed immediately.

 

After starting raw, his plate was licked clean every time and he started to finally show some weight gain! His hair started to shine and we started seeing all of the typical signs of a 4-6 month old puppy we were warned about! Hades’ energy was up and boy did he start filling out (he even did so well on hiking trails I had to quit smoking to keep up!). My favorite thing when we started to feed raw and even to this day was that as he developed, the adjustments on how much to feed and when to feed, became natural. He was kept lean throughout his puppy stage (by vet recommendations due to certain hereditary possibilities like hip displaysia) and then bulked up with ease as he grew older and older. Well, 100 lbs later, I believe the initial diagnosis from the vet was proven wrong. I credit all of that to raw. No joke.

 

In my opinion, raw has set Hades up for the best physical and mental condition that he can possibly be in.

 

In my opinion, raw has set Hades up for the best physical and mental condition that he can possibly be in. He is currently 5 years old and has not eaten kibble since he was 13 weeks. Good luck getting him to eat anything else… he won’t even go for one of those whipped cream doggy drinks from that fancy coffee place!  Thank you, NorthPoint for everything you have done for Hades and all of the raw education you have shared! Hades says thanks too!”

 

This is why we do what we do. This is what drives our team to continue our research, to provide the most up-to-date information, and further our education in everything we do. Thank you Brandon for sharing your raw story with us! 

 

We want to hear from you! If you have a success story to share with us, send an email to info@northpointpets.com.

How to Pick the Best Food for Your Pet

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Ever wonder how to help determine what food is best for your pets? Packaging and marketing can make it difficult to make choices. Did you ever wish for a guide to help you evaluate the quality and nutrition of products available? Good news! We did just that. Read on….

What if I told you that it’s highly likely that the pet food you are feeding your cat or dog has never been tested to ensure it is nutritionally adequate? Or, maybe it’s been tested, but your pet food company claims the results are ‘proprietary’. What if I told you that some of the most recent pet food recalls and scandals likely could have been prevented if companies were testing to prove nutritional adequacy? The fact is that pet foods are allowed to come to market and be sold without ever being tested to prove nutritional adequacy– leaving your pets exposed to significant risks. Most companies will only perform a palatability study – just to ensure pets like the food. Surprised? …read on.

Lack of accountability

It’s no secret that the pet industry has more than its fair share of problems, and to be honest most of these are self-inflicted wounds. Recalls, contamination issues, formulation errors, and deceptive marketing tactics are numerous. As a ‘retailer’ or ‘shopkeeper’, it’s exhausting to keep on top of issues and communicate them to customers – but it’s way more exhausting to even get pet food companies to answer simple questions – never mind hold them accountable. The more I learn, the more questions I ask – and unfortunately, I keep uncovering holes that many retailers and consumers are woefully unaware of.

We’re starting to change the industry

There are a small number of retailers across the country that have been asking many small and large pet food companies some very pointed questions centering around transparency, formulation, nutrition adequacy testing, safety, and ingredient sourcing. I can count on one hand the number of pet food companies that are truly transparent and provide adequate nutritional and scientific data to back their product. There are several more who are making positive changes. However – most companies are not and to be honest, they really don’t have any incentive to change. They have been getting by doing the bare minimum for years, if not decades. Advertising budgets continue to boom – to keep the consumer largely in the dark, exactly where they want you. But this is where you can help create significant change.

Who’s asking the tough questions?

The problem is that consumers aren’t asking tough questions because many companies have trained consumers to read ingredient labels. This is because the label is something that is easily controlled and manipulated. The consumer’s perception of that label is further distorted through various product claims and marketing ‘puffery’ that alludes even seasoned retailers. Most pet food companies know this and target their marketing efforts, product claims, and packaging design to appeal to the customers (and retailers) desire for certain ingredients. And that is exactly what pet food companies want you to continue to focus on – questions that they can control. They don’t want you to ask the tough questions.

Believe it or not, most companies are not nearly as transparent, or thorough in their manufacturing and formulation processes as they advertise – or would like you to believe. In fact – in asking many of the following questions some companies have actually had the audacity to call me ‘suspicious’ or ‘uneducated’ when I have asked certain questions. You see, when companies start to figure out that you know more than they want you to, they get really uncomfortable. Some will go as far as trying to discredit your experience, education, and reputation to try and scare you from seeking answers. This would not be the case if consumers and even veterinarians started to ask these questions and put pressure on them to change.

How you can help make your pet’s food safer and healthier?

All things considered, I strongly suggest that you reach out to your pet food company and ask the below questions. If consumers begin to put enough pressure on the industry there will inevitably be a positive change. So how can you help hold pet food companies accountable? How can you improve the pet industry and the quality of products on the market?

1. Who formulates your food, and what are their qualifications?

An answer of ‘a team of veterinarians’ or ‘a formulator with 20 years’ of experience’ is not a good enough answer. One thing I’ve learned is that the list of board-certified veterinary nutritionists and board-certified Ph.D. nutritionists who are actually qualified to formulate, evaluate pet food is very short. This is because the science of nutrition is very complex and takes years of schooling and experience – not something many people have done. In short, the company should be willing to provide you the name(s) and qualifications of those formulating – whether they work for the pet food company themselves or on a contract.

2. Do your products meet an AAFCO nutrition profile as verified by a 3rd party nutrition analysis on all of your finished products?

If yes, are they willing to provide a copy of that analysis? A nutrient profile is different from the Guaranteed Analysis on the pet food package and puts the focus on nutrients and not ingredients. Essentially, you’re asking the company to show you the proof that their ingredients are superior. The nutrient profile will display a range of amino acids, essential fatty acids, minerals, vitamins, and fiber. Pay close attention, because most companies are deceptive and will instead provide a ‘Target’ analysis, which is a prediction and NOT representative of the final product. If a company tells you that this information is proprietary, or that they do not perform a nutrient analysis I would highly recommend finding another company that is more transparent and does their due diligence.

3. Do you conduct 3rd party digestibility studies for each of your formulas?

If yes, are they willing to make those publicly available? A digestibility study is important because it tells you what amount of each of the nutrients listed in the nutrition analysis the animal is able to absorb. Some companies will say they do not conduct these studies and claim it is because they don’t test on animals or believe in invasive testing. However – this answer is simply ‘crap’ since digestibility testing is a very simple, non-invasive process that involves feeding the food to a group of dogs or cats over several days, collecting feces, and analyzing the feces. In fact, one could argue that a company that does not perform these tests is using your animal for the experiment – not good! If anyone or any company attempts to tell you otherwise they are simply ignorant to reality.

Ideally, companies should be willing to provide a total percentage of digestibility for fat, protein, energy, and total digestibility. A ‘high quality’ pet food should be in the high-80% range and above. Foods less than this may put your pet at risk for nutritional deficiencies.

4. Do you test your final product to ensure the formulation is correct and ensure there are not any contamination issues?

If so, do they hold those products from the market until all testing comes back clear? You may be surprised to learn how many companies (yes, even raw pet foods) that do not conduct pathogen testing on their final product. We also know that some kibble companies do not conduct nutritional adequacy or even contamination testing prior to products leaving their facilities. This is a significant issue.

5. Does the manufacturing facility where your food is made have 3rd party safety certifications in place?

For reference, these include a Global Food Safety Initiative recognized 3rd party food safety certification (i.e. SQF, BRC) to verify your facility follows adequate manufacturing, food handling, and safety procedures. For many pet food manufacturers, the answer should be yes, mostly because many use the same co-manufacturing facilities (i.e. one manufacturer makes several brands of food). However, there is still a fair share of companies that do not have safety certifications in place, which again put your pet and you at risk for health and nutrition issues. If you ask this question and the answer is no, or they seem confused by the question then the pet food companies ‘transparency’ is likely smoke and mirrors.

References:

Publications: Cammack, N.R., Yamka, R.M., and Adams, V.J. (2021). Low Number of Owner-Reported Suspected Transmission of Foodborne Pathogens From Raw Meat-Based Diets Fed to Dogs and/or Cats. Frontiers in Veterinary Science 8. doi: 10.3389/fvets.2021.741575.

https://www.frontiersin.org/articles/10.3389/fvets.2021.741575/full

Contact Nicci:

www.northpointpets.com

https://www.linkedin.com/in/nicole-cammack-8400084b/?trk=author_mini-profile_title

Pet Food Storage: Could Dry Pet Food Be Making Your Pet Sick?

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Feeding your pet dry food is convenient. You don’t have to worry about any special handling requirements or finding extra space in your refrigerator or freezer. However, that convenience can come with a price that can harm your pet.

Our Top Four Tips for Safely Storing Your Pet’s Dry Food.   


1) Keep your pet food in the original package.

Pet food bags are designed to keep the food as fresh as possible. After opening, fold over the top of the bag to press as much air out as possible. If you’d like to use a storage container, put the whole bag inside the container, but do not dump the kibble out of the bag. 

Why?

Dry pet food formulations include necessary animal fats, which start to go rancid once exposed to oxygen (right after manufacturing, even inside the sealed bag). These fats coat the inside of storage containers and continue to oxidize over time and interact with compounds of the storage container itself (metal, plastic, etc.), which then contaminates the fresh kibble you just poured in.  In fact, improper storage of kibble is a large reason for food-related illness in pets.

2) Keep your pet food in a cool, dry place.

To prolong freshness and maximize nutritional value, keep your pet food in the same places that you store your own food: away from sunlight, heat, and moisture.

Why?

Moisture and food can be a fatal combination. Humid and warm areas create a perfect environment for mold and harmful bacteria to thrive. The worst of these bacteria, called aflatoxins, can cause severe liver damage and even lead to life-threatening emergencies.  Learn more about how to properly store your pet’s dry food here. 

3) Purchase a bag of food that will last your pet for roughly one month.

For optimal nutrition, freshness and palatability, we recommend buying the smallest bag of food that is appropriate for your pet – about 30 days’ worth. A small bag (4 – 5 lbs) is appropriate for a small dog, and a large bag (20+ lbs) for a large dog.

Why?

When pet food is stored for a long period of time, opened or not, the risk of rancid fats, mycotoxin contamination, pathogenic bacteria, and storage mites are significant risk factors. We often hear pet parents state that their pet gets bored by the end of the bag, but if that bag is 2+ months old, it’s likely that your pet can smell that the food has spoiled. In fact, one of the largest reasons pets turn their nose up to food midway through the bag is because it has turned rancid. Here are more considerations for bulk buying pet food.

Our team is always happy to discuss these topics on an individual basis. If you have questions regarding the storage of your pet’s food, please see one of our pet nutrition experts in-store.

What Can My Pet Eat on Thanksgiving Day?

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As Thanksgiving quickly approaches, it is important to discuss and understand which foods are okay to feed our furry friends.

Many foods that we eat on Thanksgiving day are easily shareable with our pets but there are some foods that should be avoided. Let’s discuss the foods to give and when we should avoid sharing:

Foods that can be shared PLAIN:

These foods can be shared raw or gently cooked by baking, boiling, or steaming without added fats, sweeteners, or seasoning.

  • Baked or boiled mashed potatoes/sweet potatoes
  • Broccoli
  • Green beans
  • Carrots
  • Turkey (white or dark meat)
  • Cranberries
  • Pumpkin
  • Apples

Foods/Ingredients to Avoid:

  • Gravies contain a decent amount of sodium
  • Certain seasonings contain a decent amount of sodium
  • Certain broths contain high sodium content and vegetables that dogs should not eat (like onions)
  • Bones because cooked bones can splinter and cause damage to the gastrointestinal tract
  • Skin of the turkey is very fatty and can lead to pancreatitis (inflammation of the pancreas)
  • Stuffing(s) contains onions and is also made primarily of highly processed carbohydrates (containing high levels of sodium) and onions can cause damage to red blood cells leading to anemia in your pet
  • Cranberry sauce is typically high in sugar
  • Carrot and green bean intake should be limited as they contain decent amounts of sugar
  • Pumpkin pie and apple pie both contain loads of sugar

Why should we avoid foods high in sugar and sodium?

Foods that are high in sugar tend to cause upset stomach, weight gain, and impact multiple organ health. Foods that are high in sodium can lead to dehydration, vomiting/diarrhea, muscle tremors and even seizures. Sodium is necessary in a pet’s diet but only a very small amount and too much sodium can be harmful. Natural sugar (through our fruits and vegetables) is okay for our pets, but artificial and processed sugars (such as those found in our snack foods) or too much can cause these issues. 

Is Your Pet’s Healthy Food Being Served in a Toxic Bowl?

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Pet Parents are spending a great deal of time and money to ensure they are serving the healthiest foods to their pets.  However, when it comes time to select a bowl or feeder, most Pet Parents report that they choose the cheapest bowl or one that matches the décor of their home.  However, did you ever consider if your pet’s food bowl is actually safe?  Have you checked to see where your food bowl was manufactured or what materials it is made of?  Can you trust the labels on the package that sometimes provide this information?  Think about it…these food bowls are in constant contact with your dog’s mouth and tongue multiple times each day.

Let’s start out with the country where your pet’s food bowl is being manufactured.  Why should this matter?  Because you want to be sure that it is in a country that follows “GMP” or Good Manufacturing Processes.  The most important assurance of GMP is to provide quality control and safety.  Simply put, the manufacturing people are properly trained; working in a properly cared for facility; following a standardized process; producing consistent products, and guided by procedures that guarantee quality and safety.  Pet products made in the United States are most likely to be manufactured within these guidelines whereas those manufactured in China are least likely.  Pet Parents should especially be concerned about pet bowls, feeders, and lick mats made in China because there are no guarantees that the materials or manufacturing process are safe and free of harmful toxins. Of course, it is more expensive to manufacture under GMP because of the additional time and cost involved in the manufacturing process.

It is worth noting that just because a food bowl is manufactured in the U.S., it doesn’t mean that the materials were also sourced in the U.S.  The cost of quality materials can compel manufacturers to find cheaper materials sourced from other countries and have them imported.  So, you have to look at both where your pet’s food bowl is manufactured as well as where the material is sourced from.

Petfood Bowl Materials and Factors to Consider

The next factor to consider is the material of your pet’s food bowl.  Typically, pet food bowls and feeders are made of either stainless steel, plastic or silicone but not all of these materials are created equal.  Let’s consider each of them:

  1. Most Pet Parents automatically think that stainless steel food bowls are a ‘safe choice’ because they associate it with medical tools used in the health and dental fields.  However, these are not the sterilized tools used in the biomedical field which mandates a different manufacturing process.  Instead, all stainless steel requires the use of ‘cutting fluids’ which shape metal and are extremely difficult to get off of the surface.   Cutting fluids are highly toxic and continue to leach out over time.  There is a variety of cutting fluids and their safety is probably dependent on where the food bowl is made.  In order to reduce the chance of leaching, caustic cleaners and high temperatures (repeated dishwashing) must be used.
  2. Most Pet Parents are confused about how to think of plastics.  The single most important factor to consider is whether the plastic is recycled or not.  Recycled plastics are extremely problematic because of raw material contamination.  Recycled plastics can come from either used consumer products or used industrial products.  Post-consumer recyclates are improperly cleaned and can cause cross-contamination. (China was previously the biggest importer of plastic waste which created landfills and destroyed communities making them uninhabitable.)  Likewise, some post-industrial recyclates can contain industrial chemicals and cleaners which can be carcinogenic.  Unfortunately, except for some industrial recyclates, there is no way to trace their source to assess their toxic composition.  As such, many of these recycled plastics represent potentially serious health hazards to your pet.
  3. Silicone is a relatively new but popular material because it can easily be made into any shape and is fairly durable.  However, because it is a more expensive material, many silicone products contain chemical fillers to reduce material costs—especially those made it China.  These unknown chemical fillers could cause adverse side effects on your pet’s health.  Additionally, silicone products cannot be recycled and end up in landfills because they are in their final form—not particularly friendly to the wellbeing of our planet.  Finally, since silicone is a young material, there are few studies on the safety and long term health effects especially with daily use and contact with the material.  Use care and caution in assessing the quality of your silicone feeders.

Why should we care?

The reason we should care about the food bowl we choose for our pets is the dramatic incident of cancer.  I want to be forthright in saying there is no mandatory reporting to a universal database that allows the scientific tracking of this disease.  However, the Animal Cancer Foundation has recently provided estimates that roughly 6 million new cancer diagnoses are made in both dogs and cats each year in the United States (out of a 65 million dog and 32 million cat population).

Always check labels and ask questions

What can Pet Parents do to check on the quality and safety of their pet’s feeding devices?  First, check the label to see the country where it is made, where the material was sourced and the type of material used.  Beware of products that do not state where it is manufactured as well as those that say ‘globally sourced materials’—there is no way to ascertain if it is a safe or reliable feeder.  Also, if it says, “Designed and tested in the U.S.”, dig deeper to find out where it was manufactured and where the materials were sourced—this statement has nothing to do with the quality or safety of the feeder.  Also, as a last resort, contact the manufacturer and ask them to provide this information!  You have the right as a Pet Parent to work around the ‘disinformation’ to ensure the health and wellbeing of your pet.

So, the next time you are purchasing a pet food bowl or feeder, invest the same time and money you would in choosing their food.  It is the one item in the household that your pet interacts with multiple times each day.  And now you can rest assured that you are truly serving them a safe and healthy meal.

About the Author: Carol Smeja, Ph.D

Carol Smeja’s career has focused in the area of psychology and sociology which led to her earning a Ph.D.  She applied these roots in understanding the psychological and social dynamics of eating while working in marketing/research with the U.S. and global food companies and improving health & diet with U.S. government agencies.  More recently, she has applied her extensive research and diagnostic training in understanding the eating behaviors of our dogs & cats by studying the natural and instinctive behaviors of their ancestral roots.  She has conducted comprehensive ancestral reviews and integrated information from wildlife specialists and professional research/observational programs.  She volunteers at zoos to continue to gain knowledge on our pet’s dietary needs and feeding habits in addition to improving conservation efforts.  Lecturing at both professional events and pet organizations, Carol seeks to educate Pet Parents on the importance of how you feed your pet to improve their health & wellbeing. She is also the co-creator of the Original Mine Pet Platter. Made with an innovative and sustainable material naturally sourced from plant life that is safe and non-toxic. 100% designed, sourced, and manufactured in the USA, the mine Pet Platter is food and dishwasher-safe, BPA-free, eco-friendly and recyclable. The Mine Pet Platter is safe for pets and the planet.

Is ‘Holistic’ Pet Food Safer?

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The word holistic started gaining traction in the late 1960’s and has been increasing in popularity ever since. The word has many different meanings to many different people. For most, the word brings about thoughts of wholesome, healthy, natural, fresh, etc. It’s evolved to invoke an emotional response to pet owners. As such, we’re conditioned to think holistic represents at least some level of quality, purity, or healthfulness of a pet food product bearing the term. It gives us a sense of confidence and trust in the product. But what is special about pet food packaging that proudly claims the product is holistic? Are there any guarantees? 

Let’s start by looking up the word in the Meriam Websters dictionary. It lists two definitions of the word holistic: 

PHILOSOPHY 

Characterized by comprehension of the parts of something as intimately interconnected and explicable only by reference to the whole.  

MEDICINE 

Characterized by the treatment of the whole person, taking into account mental and social factors, rather than just the symptoms of a disease. 

Given these definitions, it’s obvious that the pet food industry has warped consumers’ perception of what holistic means. Neither of these definitions really apply to pet food, or guarantee its quality. In fact, it seems that the consumers perception of what this means is entirely different.

Pet Food Definition of Holistic

A little secret in the pet food industry is that the Association of American Feed Control Officials (AAFCO) defines various terms for pet food. This can mean that the definition of a word in the dictionary can be very different than the AAFCO definition. Examples include terms like natural and organic – the AAFCO definition of these terms is very specific and not at all what the average person would expect.

Even more surprising is that in the pet food industry terms like ‘holistic’, ‘biologically appropriate’ and ‘super-premium’ have no definition and are there just to catch your eye. In other words, these terms plastered all over pet food, treat and supplement packaging tells a story to the consumer that might be purely fictional. This is known as “puffery” – or in other words subjective, rather than objective views. This practice is not exclusive to the pet industry, as it is common in many industries. Puffery serves to “puff up” an exaggerated image of what is being described.  

The term holistic doesn’t have a definition in regard to pet food, supplements, or treats. It’s just marketing. Because the term holistic is not regulated it offers no guarantees on the quality and sourcing of the ingredients or the nutritional value or digestibility of the product. Knowing this, it is frustrating to walk the aisles of a pet food store or visit pet food company websites only to see the term used to describe their brand and quality of products.  Further, a simple google search of “best holistic pet foods” will reveal various ‘Top Pet Food’ lists claiming benefits and ranking of holistic products, some even with holistic in the name. Sadly most, if not all, of these lists do not use meaningful or tangible nutritional benchmarks to rank pet foods. Instead, they are ranking foods based largely on marketing hype. 

These facts do not necessarily mean that foods claiming to be ‘holistic’ are bad. It just means that you may have to do some homework to determine the quality and nutritional adequacy of the product.  

So, What Gives? 

Any company can use the term holistic on their packaging and describe their product without having to meet any standards whatsoever. So, what should you know when choosing your pet’s food? When evaluating or choosing your pet’s food it’s important to review the ingredient panel and guaranteed analysis. Unfortunately, this simply isn’t good enough. One of the best ways to evaluate your pet food is to reach out to the company and ask some direct questions to determine how they validate their nutritional adequacy, product safety and how transparent they are. Learn more about what questions to ask here. 

An ‘FDA Warning Letter’ is not just a ‘Warning’

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….and other lessons courtesy of Midwestern Pet Foods

 

A little background:

If you’re just catching up, Midwestern Pet Foods (manufacturer of Earthborn, ProPac, SportMix, CanineX, Venture, Unrefined and Wholesomes) rounded out 2020 with an expansive ‘voluntary’ recall’ secondary to aflatoxin contamination among a variety of their products. As 2021 began, the ‘voluntary’ recall became larger, as retailers and consumers we were assured that this incident was isolated to one of their four US plants. If you are wondering why I put ‘voluntary’ in quotes, it’s because voluntary recalls are actually not voluntary – they are forced by the FDA (For more on that, see my other article ‘Voluntary Recalls Are Not Voluntary’ here). In short, when a company is subject to a voluntary recall it appears to imply that either the company did not have to recall the product, or that they may have found the issue themselves and thus recalled the product ‘out of an abundance of caution,’ when in fact that is usually pretty far from the truth. 

 

In the case of the aflatoxin recall with Midwestern Pet Foods, the recall was initiated by the Missouri Department of Agriculture as a result of pet illness reports and not Midwestern Pet Foods identifying the issue. Looking at the timeline of how things progressed, the initial recall was announced on December 30, 2020, expanded on January 11, 2021 (to include over 1,000 lots of pet food) and was followed up by an updated outbreak and advisory on January 26, 2021. The timeline and expansion of the number of lots and amount of pet food impacted shows just how important it is for pet owners and retailers to ask proper questions of their manufacturers to ensure the products they stock or feed their pets is safe – and to protect their businesses and livelihoods. In other words, the recall started out small and seemingly to be a self-caught issue, however the fairly quick expansion tells a different story. If Midwestern Pet Foods was properly testing inbound ingredients (i.e. aflatoxins in grains), testing foods after production and prior to leaving the facility (positive release) this would have never happened.

 

The outbreak and advisory notice outlines how the FDA was working with 10 different states to determine the impact of the aflatoxin contamination of Midwestern’s portfolio of brands. This advisory also provided an update that included at least 35 additional countries where the foods were likely distributed to and thus impacted by this recall in the United States. For example, The Food and Drugs Authority in Ghana issued a directive for all foods manufactured by Midwestern Pet Foods to be returned to the importer due to dangerously high levels of aflatoxin. For context, some of the products tested contained aflatoxin at levels as high as 558 ppb. FDA considers that aflatoxin levels in dog and cat food above 20 ppb will support a charge of adulteration because it is fatal or injurious to the health of pets.

 

Not an isolated incident

Soon, the general public, retailers and veterinarians alike realized that this was not an isolated incident and in fact was a result of widespread food-safety issues and problems across all four plants owned and operated by Midwestern Pet Foods. The worldwide aflatoxin recall was almost immediately followed by a second recall due to Salmonella contamination of several other lots of products in March of 2021 made in a second Midwestern Pet Foods facility. If you read the recall notice on the FDA website, you’ll note that this recall is also quite expansive involving several recipes and brands. When recalls are this large, several questions should be raised which include but are not limited to:

 

  • Was the company properly inbound testing raw ingredients to ensure they were free of contamination?
  • Did the company have proper documentation, kill steps and cleaning procedures of storage areas, equipment etc. to prevent cross contamination between lots?
  • Was the company properly outbound testing their final products?

 

Although the company claims that Salmonella-contaminated product never made it into the marketplace, and they caught the recall prior to it leaving their facility, the FDA letter states that it did indeed get distributed into interstate commerce. If none of the contaminated product left their facility and they were able to provide documentation to prove that no other product was impacted, then a recall would not have been triggered. This fact tells us again that food safety was an issue, and that again we see a large transparency problem with another manufacturer in the pet food industry. 

 

The “Warning Letter”

The FDA Warning Letter issued to Midwestern Pet Foods on August 9, 2021, included five FDA Form 483’s. An FDA Form 483 is issued to firm management at the conclusion of an inspection when an investigator(s) has observed any conditions that in their judgment may constitute violations of the Food Drug and Cosmetic (FD&C) Act and related Acts. I’ve heard a variety of comments after this warning letter was issued from pet owners and retailers – the largest, and most concerning is that many believe that because no new recall was issued that the Warning Letter is not really a cause for concern. Nothing is further from the truth and in fact, I would argue that the Warning Letter – impacting all 4 locations – is worse than a recall. Why do I say that?

 

This Warning Letter was issued as a Corporate Warning Letter because at the conclusion of inspections at all four facilities the FDA issued these FDA Form 483’s due to documented issues at each of their facilities: 

 

“At the close of each inspection, you or your plant manager was issued a Form FDA 483, Inspectional Observations. We acknowledge you1 have provided written Form FDA 483 responses dated February 25, 2021 (OK), March 12, 2021 (NY), March 19, 2021 (IN), March 30, 2021 (IL), and May 6, 2021 (IL) describing corrective actions you have taken or plan to take to address the observations at each of your facilities.”

 

This shows that OK, IN and NY each received one, and IL received two FDA Form 483’s for a total of five. The problem is that most people have never read? past the initial FDA in Brief that was released on August 17th, 2021. This letter detailed numerous apparent violations of the Federal Food, Drug, and Cosmetic Act that were shared across the four sites. The FDA states that these violations are likely to have contributed to the illness or death of hundreds of dogs resulting from high levels of aflatoxin secondary to violations of Current Good Manufacturing Practice, Hazard Analysis, and Risk-Based Preventive Controls for Food for Animals regulation. 

 

Per the FDA/CVM: The last of the four inspections concluded on April 16, 2021, and FDA immediately began the process of examining and compiling evidence from the multiple inspections into a corporate-wide warning letter.

 

Because the firm had voluntarily recalled the pet foods that had the potential to be contaminated with Salmonella or aflatoxin, because investigators provided initial feedback to the firm about their inspectional observations (FDA Form 483s), and because the Agency did not have evidence that violative Midwestern-manufactured product was currently in the marketplace, the FDA did not initiate a product seizure or injunction case.

 

However, because the conditions observed during the inspections indicated significant problems, the Agency took the step of issuing a corporate-wide warning letter.

 

A Warning Letter is not simply a ‘Warning’

This Warning Letter is far more than the FDA saying ‘Hey, clean up your act’ – this is a warning to ‘do better next time’. Instead, a warning letter is typically issued after an inspection of a plant or manufacturing facility that finds quality control issues and/or after consumer-related complaints as a result of injury or death. In this case, the warning letter started with consumer complaints, which triggered inspections at all four sites which then found further issues. These issues are outlined in this letter in which the FDA requests corrective action by Midwestern Pet Foods:

  • Hazard Analysis & Risk-Based Preventive Controls Requirements – FDA investigators “found significant violations that did not identify or implement preventative controls” to provide assurances that prevented product manufactured, processed, pack or held by their OK, NY, IN and IL facilities would not be adulterated
  • In regard to aflatoxin, the OK, NY, IN and IL facilities all “failed to follow their own and accepted sample preparation procedures by both the test kit manufacturer”, USDA mycotoxin handbook and/or their own facility to detect and identify aflatoxin in corn and corn products at their facilities. “Failure to follow proper procedure resulted in product NOT being rejected when it should have been.” In short, the procedure they had in place was ineffective because it was never properly implemented or executed.
  • In regard to Salmonella, the OK, NY, IN and IL facilities also “failed to implement and execute adequate procedures to detect and prevent Salmonella contamination” of their products. In the FDA Warning Letter it states the following: 

 

“During the IL inspection, you recalled approximately 104 products of dry dog and cat diets made in your IL facility from October 26, 2020 – November 12, 2020, February 1, 2021 – February 12, 2021, and March 15, 2021 – March 19, 2021, because your routine monitoring yielded Salmonella-positive results for pet diets manufactured on common equipment during those periods.”

 

The explanation of such food safety issues within this letter is what, in my opinion, makes this worse than a recall letter. Recalls are supposed to catch unfortunate accidents and rare occurrences of pet food adulteration. The highlights of these violations go far beyond a mistake, oversight, or single incidence of human error because they expand across multiple products, multiple lots on multiple dates of manufacture simply because they were common mispractice across all four of their manufacturing facilities. Further, it’s important to point out that these recalls were indeed so large, likely because of two reasons: poor food safety AND documentation of manufacturing. Was it likely that all lots impacted were contaminated? No, instead a large amount of product was recalled in an attempt to reduce the potential for any to be in the marketplace. On the other hand, is it likely that all contaminated products were found or recalled? It is uncertain, and this is because nowhere within the FDA reports does it state that all retained samples were tested for all products in the marketplace. It is unknown if all contaminated products were caught since aflatoxins are never evenly dispersed in grains, and instead you have ‘hot spots’. The hot spots are the reason why a robust and thorough screening program is needed for incoming raw ingredients, during manufacture and prior to distribution into the marketplace. In other words, if these programs are implemented properly, things like aflatoxin and salmonella are preventable.  As a result, the FDA likely made a press release so consumers, retailers and veterinarians can be hyper-vigilant in seeing early warning signs of aflatoxin poisoning in case all affected lots were not recalled.

 

How does a Warning Letter get resolved?

Within this letter, the FDA also states that voluntarily recalling product does not prevent the recurrence of such hazards (aflatoxin and Salmonella) in their products. Hence the need for Midwestern Pet Foods to respond to this robust Warning Letter with their plans to mitigate these risks, upgrade their Food Safety procedures in the future, document proper training and implementation of the programs (i.e. aflatoxin analysis and environmental Salmonella detection). While Midwestern has responded to some of these violations, as outlined within the Warning Letter, there still remains more work to be done as well as additional inspections of all facilities to ensure compliance. 

 

Not until the FDA inspects the facilities to ensure that their corrective measures are implemented and being executed properly, will the Warning Letter be resolved. In the meantime, since the warning letter and investigation are still open, one would be prudent to be cautious of any product coming from any facility with an open or unresolved issue.

 

At this point, you may be wondering what happened to Hill’s Warning Letter that was issued as a result of excessive levels of Vitamin D. This massive recall was also global and resulted from Hill’s not following their own food safety procedures. This Warning Letter is also currently unresolved, likely due to COVID restrictions and the FDA not being able to adequately execute a robust inspection. One could also argue that regulatory authorities don’t have the capacity to police everyone all of the time, or that they may be letting such a large manufacturer get by for reasons we can maybe discuss at another time. Regardless, the lesson is that unless a warning letter is resolved you should probably find another pet food for your pet, or stock a different brand in your retail or clinic location.

 

What if a Warning Letter is not resolved?

An unresolved Warning Letter has actually never happened in the pet food industry, although it has happened in veterinary product and livestock industries. This is because pet food companies have historically complied with any changes that the FDA suggested after issuance of the Warning Letter. So, what happens if a pet food, treat, or supplement company fails to make adequate changes or fails to comply altogether? It’s likely that the U.S. Department of Justice would have to bring on an injunction on the FDA’s behalf. For an example of this, we’d have to look to human industry examples to determine what would happen…

 

Current Good Manufacturing Practices (cGMP) are historically what trip up food and supplement manufacturers. Failure of a company to conduct their manufacturing under such practices after being issued a Warning Letter would result in the U.S. Department of Justice doing what?  on behalf of the FDA. Just one example, the FDA shut down Sunset Natural Products for manufacturing and distributing adulterated dietary supplements following a ruling by a U.S. District Court which issued a consent decree against the company. Under a consent decree the company is not allowed to manufacture or sell their products until the FDA determines the business is in compliance with the Federal Food, Drug, and Cosmetic Act. While this has not happened often, it is possible for companies to resurrect themselves post past? an event such as these, but it does take quite a bit of reinvention.

 

Per the FDA/CVM: injunctions have also been regularly filed against dairy farms that have introduced food containing illegal drug residues into the U.S. food supply. FDA initiates civil actions like seizures and injunctions for different reasons than criminal actions. Civil actions are brought to protect the public from harmful products under FDA’s jurisdiction. Criminal actions are brought to punish culpable parties for wrongful action and discourage the behavior. Given the different goals and legal requirements for each, there are different procedures that FDA follows to initiate each type of case. Please see Chapter 6 of FDA’s Regulatory Procedures Manual for FDA’s policies about pursuing seizures, injunctions, and prosecution of criminal matters.

 

Depending on the nature of the violation, it is the FDA’s general practice to give individuals and firms an opportunity to take voluntary and prompt corrective action before it initiates a judicial action. In some cases, however, judicial action is necessary to protect public health. As noted above, all judicial action must be pursued by FDA through the U.S. Department of Justice.

 

Based on this and other incidents we can hypothesize that if a company did not adequately respond to or respond at all to a Warning Letter, the FDA would take legal means to shut down operations of that pet food company. In this case, involving Midwestern there are a number of issues across all of their facilities indicating that substantial overhaul of their cGMP is needed. If this does not happen, or happen to the level of satisfying the FDA, we could potentially see an injunction against the company – although this would be a first for the pet food industry. 

 

What should pet parents, retailers and veterinarians do?

At the end of the day, this is not just about Midwestern Pet Food, because there are multiple recent examples of adulterated pet foods in the marketplace that include Evanger’s, Sunshine Mills, Hill’s Pet Nutrition, Blue Ridge, NomNom…I could keep going. The lesson is just another example of why it is so important to ask pointed and meaningful questions of your pet food manufacturers. These questions include but are not limited to:

  • Do you have current 3rd party food safety (cGMP, SQF) certifications?
  • Do you perform a Nutritional Analysis on ALL of your finished formulas?
  • Do you perform digestibility testing to ensure dogs/cats can absorb all required nutrients your products are formulated to meet?

 

Bottom line: If your pet food company cannot answer these questions or they say the information is proprietary, don’t feed their food!

ABOUT THE AUTHOR: 

Nicole Cammack

 

Nicole founded NorthPoint Pets & Company to fill a void for pet parents: information and transparency. Nicci understood that, while there are countless pet stores and unending opportunities for buying online, much of the information about pet food and health is incomplete, biased, or misleading. Since 2014, she is proudly leading an incredibly talented team that boasts several national awards as the leader in independent pet retail, innovation, education, health, nutrition and transparency.

Research & evolution are the foundation for everything NorthPoint stands upon. Currently, Nicole is working on her PhD at the University of Georgia (UGA), College of Veterinary Medicine in Canine Nutrition & Metabolomics. In short, she is studying how the way we feed our pets can influence disease. Although research is not a new field for her, as she has experience in clinical research for diseases such as obesity, diabetes, Alzheimer’s Disease and various cancers. Her undergraduate and graduate education includes biology, chemistry, business and nutrition. She has worked in the pharmaceutical industry on multiple R&D projects and has had the privilege to learn from leading international figures in both the human and pet health industries. When not at NorthPoint or UGA she can be found presenting at national conferences, including federal, state, and municipal organizations. Her most recent publication reports on the prevalence of reported pathogenic infections related to raw pet food diets.

What Causes Dog Tear Stains? Plus Symptoms, Treatment and Prevention

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If you’re reading this, you’re probably frustrated with your pet’s tear stains. Maybe you’ve tried every over-the-counter solution, changed your pet’s food and have been vigilant about cleaning, all to no avail. So, what can you do? Tear staining, more often than not, is noticed on white pets but can affect any color pet. It makes the color of the coat around the eyes a brown, red, or copper color. It has always been believed that tear staining comes from epiphora (or excessive tear production) – but that’s not always the case. 

There are two main factors to consider with tear staining:

  • A blocked or maldeveloped nasolacrimal duct (where your pet’s tears are formed), can cause overproduction of tears that can lead to tear stains.
  • Certain breeds have a greater deposition for tear staining.  The most commonly affected are small breeds with longer hair coats. Some examples would be Shih Tzu, Lhasa Apso, Bichon Frise, Maltese, Toy Poodle and others.

It’s a common misnomer that the only cause of tear staining in our pets is the overproduction of their tears. Aside from a blocked tear duct and breed, there are plenty of other causes that complicate the main factors listed above:

  • Corneal injury or ulceration
  • Entropion (eyelashes are turned inwards and rub against the eyeball)
  • Infection of the eye 
  • Ear infections (bacteria, yeast)
  • Certain medications
  • pH imbalance
  • Red meat in the diet (iron and other minerals)
  • Poor diet (e.g., excess carbohydrates, vitamin or mineral insufficiency/excess)
  • Stress
  • Teething issues (especially in puppies)
  • The use of plastic food/water bowls 
  • Water Quality

Why are tear stains brown?

The brown color of tear stains comes from porphyrin – iron-containing molecules that come from break down of hemoglobin. These molecules can be excreted through the GI tract, saliva, urine, and tears! The majority of pets have these molecules in their tears, but some pets have more molecules than others, which results in staining. 

Prevention & Treatment:

  • Keep the hair around the eyes trimmed shorter than the rest of your pet’s coat, as this can lead to hair getting into your pet’s eyes, causing irritation and inflammation. 
  • Examine the appropriateness and quality of your pet food. Foods that contain high moisture, quality protein, and minimal carbohydrates are generally recommended.  Since carbohydrates enhance inflammation properties throughout the body, pay attention to how much of their diet (treats included) is carbohydrate-based. Lastly, avoid any preservatives, fillers, and additives. Avoiding these types of ingredients can help boost your pet’s resistance to inflammatory reactions. 
  • Focus on your pet’s pH levels. pH imbalances are an important aspect when addressing the quality of a pet’s diet. A high stomach pH can usually be attributed to certain medications (i.e., omeprazole and/or Pepcid) prescribed by a veterinarian. These medications have a tendency to lessen pepsin (digestive enzyme in the stomach that breaks down proteins and polypeptide) levels. Lower pepsin levels can eventually lead to malabsorption/maldigestion.
  • Consider protein source in your pet’s food. For example, red meats are rich in iron and can contribute to tear staining in some pets. If your pet is prone to tear stains, this may be something to eliminate to determine if it helps. The reason red meat contributes to tear staining is that their body works harder to break down the additional iron and magnesium. For dogs with liver concerns, this can put additional stress on the liver. As mentioned previously, excess iron intake can lead to the excess porphyrin – the compound responsible for the brown color in tear stains. 
  • Evaluate the quality of drinking water available to your pet. Tap water, especially well water, usually contains both iron and magnesium. As mentioned earlier, these contribute to the build of porphyrins. Therefore, providing your pet with filtered water is best to help prevent or treat tear stains.
  • Use a specially formulated dry shampoo or waterless shampoo to clean around eyes. Dry shampoos and waterless shampoos are recommended to help clean up existing tear stains because they allow the user more control than traditional shampoos.  This can come in handy when trying to cleanse the area around sensitive eyes to avoid irritation. 
  • Pay attention to the material your pet’s bowls are made of. Plastic bowls are not recommended because they tend to harbor bacteria more so than glass, ceramic, or stainless steel. Any bacteria in your pet’s bowl can be easily transferred to your pet’s coat, which can cause infection. Regardless of material, it is always best to clean your pet’s bowl regularly with soap and water to avoid the spread of bacteria.
  • Surgery (to treat entropion). In order to work closely to the eyes, this surgery requires your pet to undergo anesthetic gasses. The surgeon then will remove a section of skin on the eyelid to reverse the inward rolling. Sometimes, depending on the case this procedure may need to be repeated. 
  • Medications, minerals, and vitamins are also available to help with any type of infections/ulcerations.
  • Overuse of antibiotics can also contribute, as these can disrupt the normal healthy bacteria in the gut which help to reduce inflammation. If you find your pet is often on antibiotics it is best to work with your vet to determine the cause of recurring infections to avoid overuse.

NorthPoint Solutions:

 

Nootie offers an affordable and veterinary-quality pre-soaked wipe that helps to remove buildup and prevent staining around the eye. 

 

EarthBath also offers a waterless eye wipe, although it’s not formulated specifically for tear stains. This product is made with natural and organic ingredients that helps provide a preventative and maintenance solution for less severe staining.

 

Remember the ears! A high-quality ear cleaning solution can help remove buildup and keep ears and eyes clean. Some ear related issues can contribute to inflammation, including the eyes. Some of our favorites include EarthBath, Earth Animal & Kenic. For stubborn ear buildup, or dogs who spend a lot of time swimming we like Liquid Health’s ear cleaning solution. Our team would be happy to help you pick out the best option for your situation.

 

Omega 3 fatty acids are known to be lacking in most diets for pets and even humans. A high-quality fish oil that is made under high standards can help reduce inflammation. In addition, human studies do show some benefit to essential fatty acid supplementation and eye problems.[1] High quality fish oils are packed in glass (and never plastic), are stored in the fridge and are sourced ethically and responsibly. Some of our recommendations include Nordic Naturals, Thorne and Omega Alpha which can be found on our shelves.

 

Regular exercise is important!  Just like humans, canines and felines benefit from regular exercise to reduce stress, maintain a healthy weight and promote proper digestion. Exercise promotes blood flow, oxygenation and therefore helps to effectively cleanse all organ systems, including the skin and liver! In addition, regular exercise can help keep bodyweight in check. Excess bodyweight – even a pound or two in cats and dogs – can increase inflammation on many levels. It’s a simple and seemingly small detail that makes a world of difference!

 

Reduce or eliminate high carbohydrate snacks. Instead, opt for freeze-dried meat, jerky and chews instead of biscuits. Most pet biscuits contain very little meat (if any at all) and are instead filled with flour, tapioca, molasses, maple syrup, potatoes and other starches and sugars. These directly influence the amount of inflammation within the body. Some of our favorite pet treats include Small Batch, NOBL and Nandi freeze-dried. You can even supplement some frozen raw food as treats for a healthy and high value treat! Our team will be happy to show you their favorites too – just ask!

 

Be attentive to additives/preservatives, red meat and excess carbs in your pet’s food. These often tend to cause inflammation and irritation, resulting in tear stains. A fresh, well-balanced diet is best in pet’s who suffer from tear staining! Just remember that it may take several weeks to months to see a difference – patience and consistency will eventually pay off![eltdf_separator border_style=”” color=”#000000″ thickness=”1″ top_margin=”50px” bottom_margin=”50px”]

About the Author:

Morgan Hunt

Meet Morgan,  a Veterinary Assistant/Technician at Branford Veterinary Hospital and a Pet Problem Solver at NorthPoint Pets & Company! She is currently enrolled in a veterinary technician program at San Juan College and will one day be a Certified Technician. Her interests in the animal world are mainly behavior & nutrition.  She has a Pit Mix named Tyson and a Dalmatian named Pongo who keep her on her toes learning more and more every day.

 

References

  1. Bhargava R, Kumar P, Kumar M, Mehra N, Mishra A. A randomized controlled trial of omega-3 fatty acids in dry eye syndrome. Int J Ophthalmol. 2013;6(6):811-6. doi: 10.3980/j.issn.2222-3959.2013.06.13. PubMed PMID: 24392330.