Why Your Dog Food Labels May be Deceiving
Nutrition goes far beyond an ingredient label and the guaranteed analysis.
ABOUT THE AUTHOR:
Nicole Cammack
The Tough Questions We Ask Prospective Brands
Recently a pet food company reached out to us in an attempt to earn a spot on our shelves. In response, Nicci asked a series of questions regarding the quality and safety surrounding the food. The following is a dialogue between her and a Prospective Pet Food Company. (Please note that additional information is provided for context.)
An ‘FDA Warning Letter’ is not just a ‘Warning’
….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!
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.
Won’t my dog (or my family) get sick if I feed a raw diet?
We have always received advice to cook meat thoroughly in order to eliminate pathogens such as Salmonella, E. Coli, or Campylobacter. However, there is limited documentation linking raw feeding to enteric pathogens. A study conducted by DogRisk1 examined stool samples from dogs fed raw diets and those fed kibble-based diets. The study found that “Zoonotic meat-borne bacteria, such as Campylobacter, Salmonella, and enteropathogenic Yersinia, were only sporadically detected in RMBD (raw meat-based diets) by PCR.”1 In other words, there is no consistent association between raw diets and enteric pathogens.
By following basic, safe handling practices (which we already do when handling our own meat to prevent illness) – such as practicing good hand hygiene, disinfecting surfaces after preparation, and not feeding spoiled meat – the risk of enteric pathogens can be minimized.
It is worth noting that some of the largest and most significant pet food recalls in the U.S. have been linked to dry food. This indicates that heat-treated foods also carry a significant risk of pathogens. Additionally, research shows that most pet owners do not regularly wash their hands or clean their pet food bowls. Therefore, regardless of the type of food you feed your pet, it is important to practice proper hygiene.
REFERENCES:
- Anturaniemi (o.s. Roine), J., Barrouin-Melo, S., Zaldivar-López, S., Sinkko, H., & Hielm-Björkman, A. (2019). Owners perception of acquiring infections through raw pet food: a comprehensive internet-based survey. Veterinary Record, 185(21). https://doi.org/10.1136/vr.105122
The Covid-19 Pet Food Shortage
The Covid-19 pandemic has caused significant disruptions in the availability of pet food. If you rely on canned food for your pet, you may have noticed frequent out-of-stock situations at larger retailers. However, shopping at independent pet stores can offer a solution and support local businesses. In this article, we’ll explore the reasons behind supply chain disruptions, including labor and supply shortages, imported ingredient delays, and inclement weather. We’ll also discuss the increased demand for pet food due to higher pet adoption rates. Additionally, we’ll address the possibility of formula changes and provide guidance on finding assistance for out-of-stock pet food.
Large retailers such as supermarkets, big box stores, and even online retailers seem to have more significant out-of-stock problems than smaller independents. For you, this means that shopping at local independent stores could benefit you and the community you live in!
Reasons for Supply Chain Disruption
The Covid-19 pandemic has caused interruptions at every level of the supply chain, impacting various aspects that affect the availability of canned pet food. These disruptions, some of which may not have been previously considered, can take several weeks or months to manifest on store shelves. Let’s explore the key factors contributing to the slower production rates of canned pet food.
1. Labor Shortages
Labor shortages have had a significant impact on production, affecting livestock farms, canning facilities, and delivery drivers. These shortages have resulted from social distancing measures, lower facility capacities, and individuals needing to self-quarantine due to infection or exposure to the virus. With multiple instances of labor shortages, production lead times have increased from 1-2 weeks to 2-4 months. Consequently, some canned pet food manufacturers are currently unable to accept purchase orders. Certain brands or entire product lines may never resume production.
2. Supply Shortages
Supply shortages and delays are also contributing to the disruption. Livestock farms and slaughterhouses at the beginning of the supply chain have faced difficulties finding workers to process the necessary ingredients for pet food. Consequently, this has led to slower supply or temporary shortages. While there are alternative suppliers for common proteins like beef and chicken, more exotic options often experience long-term shortages.
3. Imported Ingredients
Imported ingredients have encountered delays as well. Both national and international production facilities have implemented measures that require extended closures for quarantine, cleaning, and labor and supply shortages. Additionally, staffing shortages and safety measures enforced by the U.S. Customs and Border Patrol have prolonged the time imported products spend at ports, further exacerbating delays.
4. Inclement Weather
Inclement weather has also impeded transportation throughout the supply chain. Widespread delays caused by hazardous travel conditions and power outages resulting from winter storms have affected suppliers, production facilities, and retailers. Although this factor may not be the primary cause for empty shelves, it contributes to slower replenishment.
5. Increased Adoption Rates
Many families took advantage of the extra time they’ve had the last couple of years and welcomed a new pet into their home.All those new pets inevitably brought a surge in demand for pet food. APPA reports 70% of U.S. households owned at least one pet in 2021, and pet owners have become increasingly interested in what they are feeding their pets. Wet and canned food, in particular, saw a dramatic increase in sales.
Have some formulas changed?
Some pet food manufacturers have chosen to discontinue or reformulate their recipes to bypass scarce ingredients to overcome some of the supply chain’s hurdles. So if your pet hesitates to eat his dinner, there may have been an ingredient swap that occurred. Be sure to check your pet food label to find possible ingredient substitutes.
Finding Answers and Assistance for Out-of-Stock Pet Food
If your pet food is currently unavailable, you likely have several questions in mind. Why is my pet food out of stock? Will it be restocked, and when? What alternatives are available for my pet’s dietary needs? Who can assist me in finding a comparable option?
Unfortunately, employees at Big Box stores are unlikely to provide answers because these large retailers do not have direct relationships with distributors. As a result, they possess limited or no information regarding out-of-stock items.
On the other hand, small independent pet retailers have the advantage of ordering and receiving products from multiple distributors. This proves beneficial when a particular supplier runs out of a specific item. Additionally, indie retailers maintain direct contact with distributors and enjoy close relationships with brand representatives. As a result, indie stores can provide accurate and real-time information sourced directly from the distributors themselves.
Moreover, indie pet store staff are well-equipped to assist you in finding suitable replacements if your preferred pet food is unavailable or discontinued. These recommendations are tailored to your pet’s needs, ensuring that they are not driven by sales goals but rather genuine concern for your pet’s well-being.
Covid-19 Pet Food Sales
The below charts show a significant dollar amount increase for both dry and wet pet food formats. Dry food experienced a greater dollar growth; however it was actually a smaller percentage of growth in comparison to wet foods (data as of August, 2020). This means that there likely was more of a strain put on wet food producers, further adding to shortages.[vc_column width=”1/2″]
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About the Authors:
Nicole Cammack
Nicole is the founder & owner of multiple-award-winning NorthPoint Pets & Company, in Connecticut, USA. She has completed undergraduate work in biological sciences, business and holds an M.S. in Nutrition. Currently, Nicole is pursuing a PhD in Comparative Biomedical Sciences (Canine Nutrition/Metabolomics) at the prestigious University of Georgia in the USA.
Her background includes experience in the pharmaceutical industry on multiple R&D projects. Nicole has had the privilege to learn from leading figures in the human and pet health industries. Nicole has been heavily involved in police canine nutrition within the USA, helping to improve the modern care and feeding of working dogs. Her interests include working dog nutrition, raw feeding, pathogens, metabolomics, and nutrition’s relationship to disease in humans and canines. Her current research involves the exploration of the canine urinary metabolome and the relationship to diet.
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:
https://www.linkedin.com/in/nicole-cammack-8400084b/?trk=author_mini-profile_title
Jenna Harrison
Jenna enthusiastically joined our team in early 2021 bringing nearly a decade of pet industry knowledge and experience along with her. She is a proud mom to cats Aerie and Spook who are both credited with her interest in pet nutrition. Quickly Jenna realized that there was a lot to be desired for honest, unbiased and accurate information within the industry and she knew she wanted to help change that. Much like the team at NPP, she believes in the value individualized diet, fresh food and tailored advice can provide for overall health, regardless of age. She also is the mom to 4 sugar gliders, Crumb, Crosby, Bindi and Gatsby which helps bring additional small animal knowledge to our robust team. When she’s not helping pet parents at NPP Jenna can be found hiking with her husband Adam, horseback riding and painting pet portraits.
References:
https://todaysveterinarybusiness.com/pets-appa-survey-covid/ https://www.avma.org/resources-tools/animal-health-and-welfare/covid-19/covid-19-impacts-food-production-medicine https://www.petfoodindustry.com/blogs/7-adventures-in-pet-food/post/9165-how-prevalent-are-covid-19-pet-food-ingredient-shortages https://www.americanpetproducts.org/pubs_covidpulsestudy.asp https://foodindustryexecutive.com/2020/12/pet-food-and-treat-sales-stay-strong-in-an-unpredictable-year/#:~:text=In%20fact%2C%20US%20pet%20food,up%20by%20more%20than%207%25. https://www.petfoodprocessing.net/articles/14294-state-of-the-us-pet-food-and-treat-industry-2020
Everything You Need to Know About Aflatoxin and Your Pet’s Food
Recalls due to aflatoxin contamination have resulted in the retrieval of hundreds of thousands of pounds of pet food. Tragically, these recalls have caused the loss of hundreds, and possibly thousands, of beloved pets. You might be wondering why such recalls continue to occur. The truth is that preventable measures can be implemented to avoid recalls associated with contaminants like aflatoxin.
When pets fall ill or pass away, it can be incredibly frustrating for pet parents and those involved in the pet industry. Aflatoxicosis is the term used to describe illness caused by aflatoxin. Diagnosing it can be challenging as the associated symptoms are considered ‘non-specific.’ In other words, they are vague and can overlap with those of various other diseases and conditions. As a pet owner, what essential information should you be aware of?
Let’s dive into the fundamentals:
What are Aflatoxins?
Aflatoxins, produced by fungi such as Aspergillus flavus and Aspergillus parasiticus, belong to a group of toxins that can be found on various agricultural crops including corn, rice, wheat, oats, peanuts, cottonseed, and tree nuts, among others. These toxins are particularly prevalent in warm and humid regions of the world and are permitted in both human and pet food at very low levels. However, the risk and level of contamination increase under specific temperature and moisture conditions.
Four types of aflatoxins, namely B1, B2, G1, and G2, have the potential to contaminate food. Among them, aflatoxin B1 is the most concerning due to its hepatotoxic nature, meaning it is toxic to the liver and can cause severe illness and even death in pets. Aflatoxicosis, often resulting from cumulative exposure to contaminated pet food, can worsen over time. Consequently, contaminated products may remain in circulation for weeks or even months before the source is identified, leading to a recall announcement.
Previous incidents in 2005 and 2012 witnessed multiple recalls of aflatoxin-contaminated pet food, resulting in numerous pets falling critically ill or losing their lives after consuming these products. More recently, Sunshine Mills in 2020 and Midwestern Pet Foods in 2021 faced extensive recalls due to the presence of deadly aflatoxin contamination.
What signs should I look for in my pet?
If you suspect your pet has consumed pet food contaminated with aflatoxin there are several signs you should watch for. Be sure to alert your veterinarian and seek medical attention for your pet should any of these signs develop.
Common Clinical Signs with Aflatoxicosis:
- Lethargy (sluggishness, tiredness, lack of excitement)
- Food Aversion or Anorexia (not wanting to eat)
- Vomiting, or vomiting blood
- Jaundice (yellow discoloration of the eyes, gums, or skin)
- Diarrhea or Melena (dark bloody stool, sometimes looks like coffee grounds)
Detecting Aflatoxicosis: Veterinary Tests and Symptom Recognition
Your veterinarian or emergency clinic will conduct various tests to assess the health of your pet. In many cases, liver function tests, which are part of a comprehensive blood chemistry panel, can provide valuable clues for detecting aflatoxicosis. Elevated liver values, such as ALT (alanine transaminase) and AST (aspartate transaminase), are often observed in the test results. Additionally, increased total bilirubin concentrations and prolonged prothrombin time (PPT) may also be indicative of aflatoxicosis.
Pet owners frequently notice changes in their pets’ behavior, food intake, or energy levels around the time these symptoms begin to manifest. It is crucial to inform your veterinarian about any such changes as they can provide essential insights. Even small details can contribute to a better understanding of the overall picture. It’s important to note that unlike humans, pets consume the same diet consistently, which results in faster toxin accumulation in their systems. Consequently, their bodies may have limited time and capacity for detoxification in such situations.
Mitigating Aflatoxin Contamination in Pet Food
Corn is widely recognized as a major contributor to aflatoxin contamination in pet food, making grain-free pet foods increasingly popular in recent years. However, it’s important to note that aflatoxin contamination is not limited to corn and remains a potential risk regardless of the type of pet food or its ingredients. To mitigate this risk, pet food manufacturers should diligently test all ingredients and final products for aflatoxin and other contaminants. Unfortunately, some manufacturers neglect this crucial step, leading to the presence of contaminated products in the market.
As a responsible pet owner, you can take action by contacting your pet food company or inquiring at the store where you purchase your pets’ food to ensure that the manufacturer implements adequate safety checks. Although safety checks are not currently mandated by law, contamination with aflatoxin would necessitate a product recall. Therefore, it is in the best interest of any pet food manufacturer to prioritize implementing rigorous safety measures.
Factors Influencing Pet Susceptibility to Aflatoxicosis
Remember that every pet, as well as every person, is unique, leading to various factors that can impact a pet’s susceptibility to aflatoxicosis and other conditions. These factors include genetics, age, hormonal status, nutritional status, exercise, and other underlying illnesses, all of which can influence the severity of aflatoxicosis. In essence, even if pets consume the same food, their reactions may differ.
Taking Action When Suspecting a Pet Food Recall
If you are feeding a currently recalled food, or if you suspect your pet may be exhibiting signs of aflatoxicosis:
- Contact your veterinarian immediately
- Save any remaining pet food you have
- Save pet food packaging and take pictures to document date and lot codes
- Bring the packaging and pet food to your veterinarian who can help you file a complaint with the FDA and send samples out for laboratory testing if needed
If you want to know more about the types of questions you should ask your pet food company you can click here.
About the Authors:
Morgan Hunt
Meet Morgan, a Veterinary Assistant/Technician at Branford Veterinary Hospital and a Pet Problem Solver at NorthPoint Pets & Company! She is a Certified Veterinary 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.
Nicole Cammack
Nicole is the founder & owner of award-winning NorthPoint Pets & Company, in Connecticut. She is also the Founder & CEO of Undogmatic Inc. 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 the human and pet health industry. She regularly lectures at national conferences, including federal, state, and municipal K9 events. Her current research involves identifying pathogenic risk factors and transmission among raw fed pets through a comprehensive worldwide survey.
Reality: The Problem Isn’t China, It’s Us
You walk the aisles of your local pet store, or maybe you shop online – and you notice that your pet’s food, treats and supplements are marked “Made in the USA.” You think that this means it is free from any foreign ingredients, and therefore safe – right? Wrong. In fact, various ingredients can be sourced from anywhere in the world and then assembled (made) in the USA. And, suddenly we see how deceptive that “Made in the USA” claim can be.
Where It All Began: 2007 Melamine Recall
China immediately comes to mind as a danger when we think about pet food and supply sourcing. This is because the 2007 melamine pet food recall was a rude awakening for pet owners in the USA. Prior to 2007, not many pet owners thought about where their pet food, treats, or ingredients contained within them came from. In fact, most recalls the decade prior were small in comparison and limited to excess vitamin D, methionine, and aflatoxin contamination.1 At the time, the melamine recall was the largest and most widespread recall of pet food in history – resulting in over 5,300 different products being removed from American shelves and at least four-thousand pet deaths.2 The biggest takeaway from this recall was that it included over 150 brands – those from grocery channel all the way to ‘premium’ brands. Showing that many companies sourced the same ingredients from the same places and utilized the same manufacturers despite what their marketing claims said. This is ultimately what prompted pet owners to start asking questions.
What is Melamine?
Melamine is an industrial chemical with uses ranging from a binding agent, flame retardant and as a polymer for utensils and plates. It has also been used as a fertilizer, although it is also not approved for use as such in the USA.3 For context, melamine-related compounds in the same family include cyanuric acid, ammeline, and ammelide. Melamine and related compounds have no approved use as an ingredient in animal or human food in the United States.3 Just knowing these facts, the thought that melamine was even introduced into the pet food supply is unsettling and it was only by sheer chance that these products did not make it into the human food supply.
Recall Summary
The short version of the 2007 recall is that wheat gluten and rice protein were intentionally combined with melamine for its high nitrogen content. Higher amounts of nitrogen can cause the protein content of an ingredient to test higher than it actually is. In addition, cyanuric acid was also present and this combination of melamine and cyanuric acid is likely the reason the recall was so deadly – not the melamine on its own.3 This entire incident fueled the American pet owners obsession for ‘Made in the USA’ products. But are products that claim to be made in the USA void of ingredients from China? Maybe not.
Made in the USA – Sort Of
The melamine recall gave rise to the “Made in the USA” mark on pet food packaging, and the current Covid-19 Pandemic is fueling another wave of consumer demand for these products. But what many consumers and pet owners don’t realize is that this term does not mean sourced in the USA. Instead, it means an American company could make pet food on American soil, but source ingredients like vitamin and mineral mixes from outside the USA and still put “Made in the USA” or “Manufactured in X US state” on the label. Further, many manufacturers will claim – at least verbally, that they do not source any ingredients or vitamins from China. So, is this actually the case? No, because most pet foods on the market contain a vitamin premix, at least in part that comes from outside the USA, which many include China. More on that in a bit.
The Federal Trade Commission (FTC) does oversee ‘Made in the USA’ claims – either expressed or perceived. This claim according to FTC standards means that all, or virtually all of the product must be made in the USA and contain no or negligible foreign content.4 According to the FTC standards, sourcing for foreign vitamin and mineral mix would be considered ‘negligible’ and therefore allow a pet food company to use ‘Made in the USA’ on the label so long as a significant majority of the remaining ingredients were indeed US sourced. One grey area here is that ‘negligible’ is not explicitly defined.
Further, negligible doesn’t necessarily mean a small amount of the final product because the FTC also takes into account the economic factors of where ingredients are processed and where the final product is processed.4 Simply, a fair amount of ingredients could be sourced outside the US, but the economic impact of processing the final product could potentially outweigh the outside sourcing.
Misleading Consumers
Evidence of how misleading some companies could be can be seen in the recent case Weaver v. Champion Petfoods USA Inc., et al. The plaintiff in this case alleged that Champion Petfoods deceptively marketed their dog food products via claims such as “biologically appropriate”, “fresh”, “regional”, and “never outsourced”. In addition, he claimed that Champion should have to disclose trace amounts of BPA and pentobarbital – just for example.5 In short, the court dismissed all complaints because Champion Petfoods asserts that “biologically appropriate” is a nutritional philosophy – not a nutritional statement (aka a marketing tagline). Champion also asserts that they did not intentionally add BPA or pentobarbital to their foods – and also never warranted their products were free of these contaminants which releases them from any liability.
While rulings on all complaints favored Champion – it does not absolve them of the significant issues that have been exposed. It also doesn’t negate the fact that this is a loss for consumers who expect transparency and truth in what they are buying for their pets. The outcome of this case just proves the point that many of us in the industry often make: most pet food companies are marketing companies first, pet food companies second.
Ultimately this decision reinforces that manufacturers are not responsible for listing each and every material that may make its way into a final pet food product, nor are they required to be fully transparent on where and how ingredients are sourced.5 It also shows that many companies are not required, nor do they satisfactorily test inbound ingredients or outbound product for adequacy. Instead it provides examples of many of the marketing loopholes that manufacturers use to give the perception that the ingredients are superior, or sourced in one way over another – when in fact they are no different than other manufacturers.
Manufactured in the USA Loopholes:
One loophole that does not appear to have any regulation governing claims or advertising involves a phrase such as “Manufactured in our US facility” and/or “Manufactured in our Kentucky Kitchens”. Simply naming a US state is a gray area since this statement would be true, but it does not point to the sourcing of the ingredients. This is extremely deceptive to the consumer who is unaware of these details. Regardless, companies such as Tyson, Fromm, Wysong, Merrick, Wellpet (Wellness, Eagle Pack, Holistic Select) have had lawsuits dismissed as a result of this gray area – or due to gray areas under the FTC standards.6
There are multiple vitamin premix companies in the US that also source individual components from outside the US, including China. The way they get around that fact is they mill or blend the vitamin premix in US facilities and simply act as if as if ‘manufactured’ is the same as ‘sourced’ in the USA. Regardless, sourcing of a particular ingredient from the US or otherwise does not guarantee safety, and therefore doesn’t discount the need for adequacy or contaminant testing.
Understanding Origin:
If pet food or vitamin premix companies advertise ‘made in the USA’ they should be willing to provide a certificate of origin for each of the ingredients on their label. Interestingly, most companies we surveyed were not willing to provide this information. Opening the discussion about vitamin premix sourcing opens up another complicated layer of pet food industry safety, sourcing and transparency. Although, as discussed, a certificate of origin for a final pet food or premix product would not ensure individual ingredients did not originate from outside the country of origin. For example, if a vitamin premix is formulated and combined in Germany – it can still have individual vitamins that are sourced from China or otherwise. The certificate of origin for the final product would say Germany. This is because the country of origin is defined as the country where the last substantial economically justified working or processing is carried out. This is the very reason why pet food companies may not understand their product contains ingredients from China – although ignorance should not be an excuse.
Do Any Vitamin Mixes Come From the USA?
As of the date of this article, there is only one vitamin mix company claiming to be 3rd party verified to not source any ingredients from China.7 This sounds good, however, it is simply marketing because there is not an authority providing benchmarks for determining what 3rd party verification in this context means. In fact, there are several companies that perform the verification by sourcing and auditing. There are several non-China sourced vitamin premixes for pet food available in the market, but there is only one that advertises it. However – one must realize that there are some ingredients to these premixes that only come from outside the USA. For example, sources for L-carnitine only come from China or the Czech Republic, meaning that if a premix contains L-carnitine, that premix is not 100% USA sourced – despite any marketing claims. The same goes for some other vitamins and minerals as well.
Vitamin Premix Concerns
The above considered, there are reputable premix companies that have been sourcing ingredients from places other than China both before and after the melamine recall. Some even make the ingredients themselves ensuring control over the process. These companies are the ones that continually receive awards and recognition for their blending, sourcing and commitment to quality each year. These companies also have marketplace longevity showing an extensive safety record. Simply, they don’t have to advertise their USA sourced, or non-China sourced ingredients because their reputation and performance speaks for itself. Vitamin premix companies that hang on advertising claims without verification, performance, or data to back their claims are likely a disaster waiting to happen. This is something that pet owners and pet industry professionals should be cognizant of.
We’ve learned that most US pet food companies who claim not to use ingredients from China aren’t exactly transparent. For instance, when companies are specifically questioned about whether they source ingredients from China, they typically respond in one of two ways: either stating that their ingredients are sourced “globally” (which, by the way, includes China), or claiming that such information is proprietary.
The proprietary response is a problem because companies will use this to hide certificates of origin for various ingredients, or the premix itself (China or elsewhere), or the fact that they do not perform adequacy testing. What the big miss here is that not all ingredients from China are bad. Yes, I said it – not everything that comes from China is dangerous – so long as a company is verifying safety and adequacy. In fact, ‘USA’ made or sourced should never be an excuse to not adequately test products.
So Why Does ‘Everything’ Come from China?
The reality is that China actually owns and controls a vast majority of the vitamin and supplement market. The same goes for human vitamin products as well. Chinese companies were able to see the consumer trends toward health and wellness decades ago and purchased a large amount of businesses in this sector. As with anything else, there are bad players and there are some that go above and beyond – even exceed US quality in some instances. It’s common knowledge that some industrially produced vitamins and supplements from China pose significant risk. In addition, we know that this area is also a significant culprit for counterfeit medications. The concerns from this area are legitimate and created significant issues for countless people across the globe. However, these do not negate the fact that some legitimate supplies largely come from China or may be superior to others.
While high-quality ingredients coming from China may actually sound counterintuitive, we often forget that Traditional Chinese Medicine (TCM) dates back at least 23 centuries – likely much further. One of the foundational concepts of TCM is the balance of energy and includes the use of herbs, whole foods and other modalities to promote a healing effect within the body. While my description is oversimplified, the point is that those within the Chinese culture who embrace the philosophy of TCM believe in and understand the importance of high quality, clean and well-sourced raw materials and supplements. In other words, obtaining vitamins, minerals and supplements from reputable sources within China, or elsewhere, and then verifying quality and purity with 3rd party testing for use in pet food and human supplements can be safe.
The Problem Isn’t China
In fact, the problem is that we are focusing on the wrong target. This argument is often used to disguise significant issues of our own. Instead of looking to place blame on one particular thing, we should be seeking to hold ourselves and others accountable. Instead of simply blaming China, we should realize that the problem is actually twofold:
- Lack of raw ingredient testing/verification by American pet food companies
- The lack of legitimate transparency from American pet food companies regarding this testing
Poorly sourced and contaminated ingredients can come from anywhere. We have allowed those within other countries and the US to get away with providing subpar and dangerous raw materials for a very long time. These adulterated ingredients could be by error, accident, be innocent, or intentional. As discussed earlier, incidents have originated from the USA as well as China. Instead, we should be asking pet food companies how they ensure the safety of their ingredients and product as a whole. Those questions include:
Do you inbound test all ingredients for pathogens, toxicants and ensure the nutrient value is correct?
This question is important because it identifies whether or not a company has processes and procedures in place that would have prevented issues like the melamine incident and the recent Hill’s vitamin D recall. The pet food company or more likely the manufacturer that makes their products should have a Global Food Safety Initiative recognized 3rd party food safety certification (i.e. SQF, BRC, etc.). These certifications verify they follow procedures they have in place ensuring adequacy.
Do you conduct a 3rd party nutrition analysis on all of your finished products?
If the answer is yes, follow up questions should be: do those products meet an AAFCO nutrient profile? Are you willing to provide a copy of that analysis?
Note that most companies are deceptive and provide ‘target analysis’, which is what is predicted – not necessarily representative of what is in the finished product. Be careful with terminology here. In addition, beware of the word proprietary – this does not hold a strong argument and may be a tactic to hide lack of testing or inadequate testing. Most companies we surveyed either answered “no” or that this information was “proprietary”.
Do you conduct 3rd party digestibility studies for each of your formulas?
If the answer is yes, for any number of their formulations you should also ask if they make those publicly available. Again, proprietary is often used when this question is asked and that should be a red flag for any pet owner or pet store owner.
To assess digestibility, researchers feed a predetermined amount of the formula under study to several dogs for 14 days. Subsequently, they collect and analyze the stool to determine the percentage of absorbed macronutrients and micronutrients in comparison to the amount that was fed. This process does not involve any invasive procedures, inhumane conditions, or otherwise harm to the animal. Again, most of the companies we asked either refused to answer, claimed the information was proprietary, or indicated they do not perform this test. In short, companies that do not conduct digestibility trials remain unaware of the actual calorie content or digestibility of their food, which ultimately makes your pet the subject of experimentation.
Keep in mind that digestibility and typical nutrient analysis mean nothing without the other. Digestibility shows the amount of nutrients absorbed. The analysis shows the amount of nutrients contained within a product.
Do you source any ingredients from China? Are you willing to provide certificates of origin?
As we discussed, ingredients from China are not necessarily bad as long as they are well-sourced. Also, we now know that companies can and should be able to verify quality and purity via analysis and contamination testing of ingredients coming into their facility.
Do you complete an analysis of your final product to ensure the formulation is correct and ensure there are not any contamination issues?
Again, if companies were analyzing their final product both for nutritional adequacy and contaminants many of the memorable recalls and pet food scandals could have been prevented. The same examples apply – the melamine recall, the Hill’s Vitamin D recall and it’s also highly likely the dilated cardiomyopathy (DCM) and grain-free debacle would never have amounted to the mess it has with these quality control measures in place. In other words, if companies were able to 3rd party verify that their foods contained required nutrients at appropriate levels and that those nutrients were digestible then grain-free foods, taurine deficiency, or other factors would not have been ‘blamed’ for DCM.
Summary
Ultimately, dangerous ingredients and products can come from anywhere. Believing that because something comes from the USA provides assurance of safety is arguably irresponsible. It’s also arguably reckless for companies to advertise USA made/sourced products in an effort to provide the perception of transparency. Ff companies don’t have solid quality control in place – it’s not a matter of if, but when, and how big or deadly that recall will be.
Now, with our understanding that it is highly probable that a portion of your pet food originates from China, and that ingredients from other regions could also pose a risk, we realize that these risks are persistent and cannot be disregarded. Instead, it’s up to us to ensure we’re supporting companies who are doing the right thing.
References:
- Rumbeiha W, Morrison J. A review of class I and class II pet food recalls involving chemical contaminants from 1996 to 2008. J Med Toxicol Off J Am Coll Med Toxicol. 2011;7(1):60-66. doi:10.1007/s13181-010-0123-5
- Pet Food Recalls Spring 2007 – VIN. Accessed July 16, 2020. https://www.vin.com/AppUtil/project/defaultadv1.aspx?id=5715799&template=ContentOnly
- Medicine C for V. Melamine Pet Food Recall – Frequently Asked Questions. FDA. Published online November 3, 2018. Accessed July 13, 2020. https://www.fda.gov/animal-veterinary/recalls-withdrawals/melamine-pet-food-recall-frequently-asked-questions
- Complying with the Made In USA Standard. :42.
- Judge Dismisses Deceptive Labeling Claim Suit. Accessed July 18, 2020. https://www.natlawreview.com/article/deceptive-labeling-claims-based-trace-amounts-sent-to-dog-house?fbclid=IwAR3Qk40CojVyUFqFFozxkdcG0lsVlRBiGgd_3ompZ_5EUORUKMGGB3WkMIQ
- More phony “Made in the USA” pet food claims under attack; Multiple class action lawsuits filed | Poisoned Pets | Pet Food Safety News. Accessed July 17, 2020. https://www.poisonedpets.com/lawsuits-accuse-pet-food-makers-over-phony-made-in-the-usa-claims/
- Non-China sourced vitamin premix ‘first for North American pet food industry.’ Accessed July 14, 2020. https://www.petfoodprocessing.net/articles/13636-non-china-sourced-vitamin-premix-first-for-north-american-pet-food-industry
‘Voluntary’ Pet Food Recalls are NOT Voluntary
A Brief History of Deadly Pet Food Recalls
Many pet owners, retailers and veterinarians believe that ‘voluntary’ pet food recalls show that pet food companies have caught problems as a result of quality and safety checks. However, this is mostly false. In fact, some of the largest and most dangerous pet food recalls were not caught by the pet food manufacturer – and instead a regulatory authority. So why are these recalls labeled as ‘voluntary’?
Meriam Webster’s definition of Voluntary is as follows:
Voluntary (adj.):
1: proceeding from the will or from one’s own choice or consent
2: unconstrained by interference
The Truth About Voluntary Pet Food Recalls
When it comes to pet food; however, many pet food recalls are not a result of the manufacturer finding a problem (e.g. mis-formulation, toxicant, etc.) like most people believe. In fact, some of the largest ‘voluntary’ recalls were not in fact voluntary even though that word is often used with FDA announcements and manufacturer press releases.
The truth is that most ‘voluntary’ pet food recalls are indeed forced, usually by a state department of agriculture and/or the FDA. In order to determine if a recall was truly voluntary you have to read the FDA announcement as well as put a few pieces of the puzzle together. The problem is that most consumers, retailers and even veterinary professionals are completely unaware that most of these recalls are not voluntary. What is worse is that many seem to believe that if a company issues a ‘voluntary’ recall it somehow absolves them of any wrongdoing – even if the problem was truly their fault. In short, voluntary recalls DO NOT mean that the manufacturer caught the problem – it usually means that some other regulatory agency (state department of agriculture, FDA and/or CDC) was made aware of an adulteration or illness and is forcing the manufacturers hand. Usually if a manufacturer fails or refuses to cooperate then involuntary recalls or FDA advisories and press releases are issued, but they are rare. An example of such an incident would be the Answers Pet food recall involving Salmonella detected in their straight beef formula. In this case the FDA issued an advisory because Answers (Lystn, LLC) recalled the affected lot in Nebraska, but did not implement a nationwide recall.
So how do you do know where to look to determine if a recall was really voluntary? And how do you know where to look?
Let’s look at some examples in recent pet food history:
Diamond Pet Food ‘Voluntary’ Recall (Salmonella):
April 6, 2012 was the initial announcement of a ‘voluntary’ Diamond Pet Food recall due to detection of Salmonella. This is because the pathogen was detected by the Michigan Department of Agriculture & Rural Development on April 2nd, 2012. While the FDA announcement and media outlets labeled this as ‘voluntary’ it surely was not. Ultimately a CDC investigation, in collaboration with other agencies, used DNA fingerprinting of a Salmonella strain infecting humans to ultimately trace it back to a specific Diamond Pet Food manufacturing facility. In other words, Diamond did not detect the Salmonella pathogen on their own simply because they were not adequately testing inbound ingredients and outbound products. Additionally, Diamond was not keeping adequate records regarding ingredient tracing, manufacturing schedules, cleaning schedules or retaining properly labeled samples of products manufactured. In other words, this could have been prevented if they followed proper procedure. As a result 49 human infections of Salmonella Infantis and over 50 pets sicked and at least 6 pet deaths.
This recall expanded to numerous expansions of brands made by Diamond including Diamond Naturals, Taste of the Wild, Kirkland, Solid Gold, Wellness, Natural Balance, Canidae just to name a few. However, foods manufactured but sold under different brand names were not recalled until after the CDC reported the outbreak of human illnesses which also were reported in Canada. Which should have been a lesson for other manufacturers to do their due diligence.
Evanger’s Pet Food ‘Voluntary’ Recall (Pentobarbitol):
February 3, 2017 was the initial ‘voluntary’ recall of what would be multiple Evanger’s canned pet food products due to adulteration with pentobarbital – a euthanasia drug. Initial reports of ill dogs surfaced at the end of 2016, although it took over a month for the ‘voluntary’ recall being issued. Expansion of the recall was announced on March 2, of 2017 that included all ‘chunk’ beef canned products made by the company. Another problem being that Evanger’s is a co-manufacturer – meaning they made canned pet food for other brands leading to this incident and previous incident possibly effecting other brands. This recall was also not ‘voluntary’ as Evanger’s did not detect the pentobarbital, and it’s also important to note they delayed recalling additional product. It doesn’t stop there though, because the ‘adulterated’ product actually turned out to be horse meat and not beef.
Taking a trip down memory lane, Evanger’s has had significant and widespread sanitary and food handling problems at their facility dating back to 2006. This was evidenced in citations and a lawsuit filed by the Village of Wheeling which resulted in restitution payments. Further, other significant problems were regularly in the news from 2008-2017 surrounding both Evanger’s products and illegal business activity. These issues included Fair Labor Standards Act violations, utility theft, theft and money laundering. On the product front further citations, FDA inspections, permit suspensions, warning letters for sanitary conditions, adulterated products, misbranded products and contaminant recalls. This long chain of issues was rounded out by the 2017 pentobarbital contamination incident.
Hill’s Pet Nutrition (Science Diet) ‘Voluntary’ Recall (Excess Vitamin D) –
January 31, 2019 Hill’s ‘voluntarily’ recalled numerous lots of canned pet food due to toxic levels of vitamin D. Ultimately two additional recall expansions were also released on March 20th, 2019 and again on May 20th, 2019. This recall turned into one of the largest pet food recalls worldwide with over 22 million cans of pet food involved, and likely a large number of pets that became sick or died. The incident involving Hill’s was also not ‘voluntary’ because they did not detect the problem themselves, and in fact the FDA found Hill’s failed to follow their own safety and quality control procedures even though Hill’s attempted to place the blame on the ingredient supplier. The FDA issued a warning letter to Hill’s with highlights as followed:
- Pet food contained vitamin D at levels in excess of 33 times the recommended safe upper limit, which classifies the food as adulterated
- Hill’s failed to follow their own procedures to ensure that inbound ingredients such as Vitamin D were safe, and at proper levels for their formulation considering Vitamin D excess is a reasonably foreseeable hazard.
- The FDA noted that Hill’s proposed ‘corrective actions’ because most were already preexisting procedures that they failed to follow in the first place resulting in the recall.
In short – even though Hill’s Pet Nutrition is touted to be ‘one of the best pet food companies’ by organizations such as the American Veterinary Medical Association and other vet groups because of their research and development into pet nutrition, publication of peer reviewed papers and for employing veterinary and PhD nutritionist – those ‘attributes’ can’t save them if they don’t follow their own food safety, quality and formulation procedures!
Sunshine Mill’s ‘Voluntary’ Recall (Aflatoxin) –
On September 2, 2020 Sunshine Mills, manufacturer of several brands of pet food issued the first wave of recalls due to dangerously high levels of aflatoxin. On October 8th, the second announcement expanded the
recall to 18 brands that Sunshine Mills produced. Again, this recall was not ‘voluntary’ and was initiated after the Louisiana Department of Agriculture found elevated levels of the contaminant during routine testing. The department then issued a stop sale order on the product in the state of Louisiana, which then triggered the ‘voluntary’ recall by Sunshine Mills. This again is another example of a company either not testing inbound ingredients and/or outbound product for safety and adequacy. This is yet another example of a large recall that also could have been prevented!
Midwestern Pet Foods ‘Voluntary’ Recall (Aflatoxin)
Most recently on December 30, 2020 Midwestern Pet Foods ‘Voluntarily’ recalled several SportMix dog and cat foods due to dangerously high levels of aflatoxin. Note that this date is not too long after the Sunshine Mills recall, which should have been a clue to pet food manufacturers to ensure they were adequately testing their products and ingredients for safety and adequacy. In addition, Neogen releases contaminant reports for agricultural crops each week and because of these reports the industry was well aware of aflatoxins present from corn crops in various regions of the country. Aflatoxin, along with other common agriculture contaminants were present due to various conditions tied to the growing season. Given the Sunshine Mills recall likely from the same 2020 corn crop, Midwestern Pet Foods should have been even more aggressive in testing inbound ingredients (as should other companies using corn).
It’s likely that Midwestern Pet Foods was not inbound testing their ingredients for aflatoxin and/or outbound testing their final products. The larger problem is that Midwestern Pet Foods has indicated in the past that they do perform these types of early 2 weeks later on January 11, the recall was expanded to include well over one-thousand (1,000) lots of pet food, and additional brands. To date over 70 dogs have been reported dead and over 80 ill – which is likely to expand. Again – another deadly event that was completely preventable!
Summary:
At this point you’ve probably realized a common theme – all companies were either not following their own established food safety procedures, or any quality control checks at all. You also likely noticed that none of the above companies caught their own issue – they were all discovered by outside agencies. This means that companies had released product into the marketplace without adequate food safety checks which resulted in numerous pet deaths and illnesses, and some even resulting in human illnesses. In addition, all companies issued expanded recalls, which further solidifies the point that these companies did not have or were not following sufficient quality control measures to ensure safety of their products nor knew the impact of the adulterated products in the marketplace.
A Key Takeaway
The major point is that these were ALL preventable. If they the companies were testing inbound ingredients for aflatoxin or vitamin D the ingredients would have never enter their manufacturing facility. If they had positive release programs for pathogens like Salmonella, the foods would have never left their facility.
What all of this means is that pet food companies that do not have such measures in place are essentially playing Russian roulette with your pet’s health and safety (and sometimes your own health). It’s our responsibility as pet owners, retailers and veterinarians to contact our pet food manufacturers and ensure that they have appropriate procedures in place and that they follow them. When they do not follow the procedures and issues arise, we need to know why and what they are doing to prevent it again. We are human, mistakes happen. When they cannot explain or chose to ignore the questions we ask, why should we feed or sell their foods? The days of pet food companies lacking transparency in their ingredient sourcing and quality control are over – or at least they should be if we demand it.
About the Author: Nicole Cammack
Nicci is the founder & owner of award winning NorthPoint Pets & Company, in Connecticut. She is also the Founder & CEO of Undogmatic Inc. 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 the human and pet health industry. She regularly lectures at national conferences, including federal, state, and municipal K9 events. Her current research involves identifying pathogenic risk factors and transmission among raw fed pets through a comprehensive worldwide survey.
Must Read: Aflatoxin Pet Food Recalls
The recall of SportMix dog and cat foods may impact you even if you’re not feeding the food being recalled.
UPDATE: JANUARY 25, 2021
The FDA released an update which indicated the recall has expanded internationally. Further, based on the number of reported deaths and illnesses as of this date this is likely the largest documented aflatoxin recall within the pet industry.
UPDATE: JANUARY 11, 2021
The FDA released an update on the original recall announcement adding over 1,000 lots of pet food manufactured by Midwestern pet. Affected foods were made in their Oklahoma facility. More than seventy deaths have been reported with an additional 80+ pets ill.
This recall indicates there are some clear quality control issues within Midwestern Pet’s manufacturing operations. As foreshadowed in the original article below, it likely meant that they were not inbound testing their ingredients for safety and adequacy. Midwestern was likely not outbound testing their final product for safety and nutritional adequacy either. The recall expansion supports this and we can expect the number of reports of ill pets to increase, as well as further expansion of this recall.
ORIGINAL ARTICLE: JANUARY 1, 2021
Recently a recall of SportMix dog and cat foods due to ‘potentially fatal levels of aflatoxin’ was announced by the FDA & Midwestern Pet Foods. SportMix is manufactured by Midwestern Pet Foods who also makes well-known brands Earthborn, ProPac, Venture, Wholesomes, CanineX and most recently their ancient grain food Unrefined. The first FDA update indicated 28 dogs reported dead, and at least 8 more ill, with 70+ ill and 80+ dead as of the second announcement. It’s likely the FDA announcements will result in more reported cases.
If you are feeding SportMix, you can check the most recent FDA announcement for lot and date codes to see if your food has been recalled. If your pet is ill, be sure to contact your veterinarian right away. You can learn more about filing a Pet Food Complaint with the FDA here: Report A Complaint.
The recall was prompted when the Missouri Department of Agriculture tested multiple SportMix products which contained very high levels of aflatoxin. Currently, the Missouri Department of Agriculture and the FDA are investigating the incident to determine how and why the foods contained such high levels of aflatoxin.
What Is Aflatoxin?
Aflatoxin is produced by a mold Aspergillus flavus. Aflatoxin is dangerous at high levels, although low levels exist in common foods we and pets eat. These foods include nuts and grains (including ancient grains!) such as peanuts, and corn. In pet food, the most common culprit is corn, however numerous recalls have been announced over the years for a variety of human and pet products.
The FDA states that pets are more at risk of aflatoxin poisoning because they do not eat a varied diet like humans do. In other words, the cumulative effect of eating food with already high levels of aflatoxin makes the situation worse.
What symptoms should I look for?
The FDA States:
“Pets with aflatoxin poisoning may experience symptoms such as sluggishness, loss of appetite, vomiting, jaundice (yellowish tint to the eyes, gums or skin due to liver damage), and/or diarrhea. In some cases, this toxicity can cause long-term liver issues and/or death. Some pets suffer liver damage without showing any symptoms. Pet owners whose pets have been eating the recalled products should contact their veterinarians, especially if they are showing signs of illness.”
Why this recall should concern you:
Aflatoxin at dangerously high levels in pet food is preventable from a manufacturing standpoint. If a manufacturer is testing their inbound ingredients and outbound testing their final product, dangerously high levels of aflatoxin should never make it to the marketplace. The fact that it has been found in 9 different lots of pet food is concerning and raises several questions:
Was Midwestern inbound testing their raw ingredients to ensure that they were safe? In this case, it is likely that the ingredient containing the aflatoxin was corn.
Note: The past year there were agricultural reports indicating high levels of aflatoxin in some crops, meaning that if Midwestern was purchasing from these regions they should have been testing for aflatoxin, and other contaminants more frequently.
Was Midwestern outbound testing their final products to ensure that they were safe and nutritionally adequate?
What types of quality control does Midwestern have in place to prevent problems like this from occurring?
What steps does Midwestern take to clean machinery and storage containers in an effort to prevent cross contamination to other products made in the same facility?
What other products were made in this facility during and after the recalled product was made?
Does Midwestern hold a sample of each lot of food produced so that it may be tested if issues arise such as this?
Another Lesson?
The recall of SportMix dog and cat foods is another lesson to both retailers and pet owners that it is important to ask questions of the brand of food you feed your pets. You can learn more about those questions here. I am well aware of many who think that I’m being unreasonable when asking the questions I ask, or pushing for changes in regard to food safety and nutrition adequacy testing – but the reason why I do it is because things like this are PREVENTABLE. Sure, implementing nutritional adequacy testing is inconvienent if you’re a manufacturer – but it’s worse when pets get sick or die because you didn’t implement that testing. As a retailer it’s inconvenient to have to constantly reach out to pet food companies – but it’s worse when a pet experiences a problem because I didn’t do my homework. It’s clear that many companies do not check all the boxes, but I can do my best to support companies that are doing their best to improve. I can also educate my clients and customers on who does and does not have certain safety/nutritional adequacy measures in place. I can also tell them who refuses to answer questions!
Simply said, knowing what quality control measures a manufacturer has or does not have can make a world of difference. While we don’t know if this recall will be expanded to other lots, or even brands – it is not out of the realm of possibility. For example, if Midwestern truly did have one batch of a contaminated ingredient such as corn, and does have proper quality control measures in place (e.g. proper cleaning of machinery and storage containers to prevent cross contamination) then other products may not be affected. If they do not have adequate measures in place (or failed to follow them) it is possible other products will be affected.
In either case, the question still remains: how did the contaminated food end up in the marketplace to begin with? Was it because they were not inbound testing raw ingredients, or outbound testing the final product or both? We’ll have to wait and see.
Original Recalled Products: Date accessed: 11 January 2021 https://www.fda.gov/animal-veterinary/outbreaks-and-advisories/fda-alert-certain-lots-sportmix-pet-food-recalled-potentially-fatal-levels-aflatoxin
Second Recall (January 11, 2021) Date accessed: 11 January 2021 https://www.fda.gov/animal-veterinary/outbreaks-and-advisories/fda-alert-certain-lots-sportmix-pet-food-recalled-potentially-fatal-levels-aflatoxin
Date code example: Date accessed 11 January 2021 https://www.fda.gov/animal-veterinary/outbreaks-and-advisories/fda-alert-certain-lots-sportmix-pet-food-recalled-potentially-fatal-levels-aflatoxin
Must Read: Aflatoxin Pet Food Recalls
The recall of SportMix dog and cat foods may impact you even if you’re not feeding the food being recalled.
UPDATE: JANUARY 25, 2021
The FDA released an update which indicated the recall has expanded internationally. Further, based on the number of reported deaths and illnesses as of this date this is likely the largest documented aflatoxin recall within the pet industry.
UPDATE: JANUARY 11, 2021
The FDA released an update on the original recall announcement adding over 1,000 lots of pet food manufactured by Midwestern pet. Affected foods were made in their Oklahoma facility. More than seventy deaths have been reported with an additional 80+ pets ill.
This recall indicates there are some clear quality control issues within Midwestern Pet’s manufacturing operations. As foreshadowed in the original article below, it likely meant that they were not inbound testing their ingredients for safety and adequacy. Midwestern was likely not outbound testing their final product for safety and nutritional adequacy either. The recall expansion supports this and we can expect the number of reports of ill pets to increase, as well as further expansion of this recall.
ORIGINAL ARTICLE: JANUARY 1, 2021
Recently a recall of SportMix dog and cat foods due to ‘potentially fatal levels of aflatoxin’ was announced by the FDA & Midwestern Pet Foods. SportMix is manufactured by Midwestern Pet Foods who also makes well-known brands Earthborn, ProPac, Venture, Wholesomes, CanineX and most recently their ancient grain food Unrefined. The first FDA update indicated 28 dogs reported dead, and at least 8 more ill, with 70+ ill and 80+ dead as of the second announcement. It’s likely the FDA announcements will result in more reported cases.
If you are feeding SportMix, you can check the most recent FDA announcement for lot and date codes to see if your food has been recalled. If your pet is ill, be sure to contact your veterinarian right away. You can learn more about filing a Pet Food Complaint with the FDA here: Report A Complaint.
The recall was prompted when the Missouri Department of Agriculture tested multiple SportMix products which contained very high levels of aflatoxin. Currently, the Missouri Department of Agriculture and the FDA are investigating the incident to determine how and why the foods contained such high levels of aflatoxin.
What Is Aflatoxin?
Aflatoxin is produced by a mold Aspergillus flavus. Aflatoxin is dangerous at high levels, although low levels exist in common foods we and pets eat. These foods include nuts and grains (including ancient grains!) such as peanuts, and corn. In pet food, the most common culprit is corn, however numerous recalls have been announced over the years for a variety of human and pet products.
The FDA states that pets are more at risk of aflatoxin poisoning because they do not eat a varied diet like humans do. In other words, the cumulative effect of eating food with already high levels of aflatoxin makes the situation worse.
What symptoms should I look for?
The FDA States:
“Pets with aflatoxin poisoning may experience symptoms such as sluggishness, loss of appetite, vomiting, jaundice (yellowish tint to the eyes, gums or skin due to liver damage), and/or diarrhea. In some cases, this toxicity can cause long-term liver issues and/or death. Some pets suffer liver damage without showing any symptoms. Pet owners whose pets have been eating the recalled products should contact their veterinarians, especially if they are showing signs of illness.”
Why this recall should concern you:
Aflatoxin at dangerously high levels in pet food is preventable from a manufacturing standpoint. If a manufacturer is testing their inbound ingredients and outbound testing their final product, dangerously high levels of aflatoxin should never make it to the marketplace. The fact that it has been found in 9 different lots of pet food is concerning and raises several questions:
- Was Midwestern inbound testing their raw ingredients to ensure that they were safe? In this case, it is likely that the ingredient containing the aflatoxin was corn.
- Note: The past year there were agricultural reports indicating high levels of aflatoxin in some crops, meaning that if Midwestern was purchasing from these regions they should have been testing for aflatoxin, and other contaminants more frequently.
- Was Midwestern outbound testing their final products to ensure that they were safe and nutritionally adequate?
- What types of quality control does Midwestern have in place to prevent problems like this from occurring?
- What steps does Midwestern take to clean machinery and storage containers in an effort to prevent cross contamination to other products made in the same facility?
- What other products were made in this facility during and after the recalled product was made?
- Does Midwestern hold a sample of each lot of food produced so that it may be tested if issues arise such as this?
Another Lesson?
The recall of SportMix dog and cat foods is another lesson to both retailers and pet owners that it is important to ask questions of the brand of food you feed your pets. You can learn more about those questions here. I am well aware of many who think that I’m being unreasonable when asking the questions I ask, or pushing for changes in regard to food safety and nutrition adequacy testing – but the reason why I do it is because things like this are PREVENTABLE. Sure, implementing nutritional adequacy testing is inconvienent if you’re a manufacturer – but it’s worse when pets get sick or die because you didn’t implement that testing. As a retailer it’s inconvenient to have to constantly reach out to pet food companies – but it’s worse when a pet experiences a problem because I didn’t do my homework. It’s clear that many companies do not check all the boxes, but I can do my best to support companies that are doing their best to improve. I can also educate my clients and customers on who does and does not have certain safety/nutritional adequacy measures in place. I can also tell them who refuses to answer questions!
Simply said, knowing what quality control measures a manufacturer has or does not have can make a world of difference. While we don’t know if this recall will be expanded to other lots, or even brands – it is not out of the realm of possibility. For example, if Midwestern truly did have one batch of a contaminated ingredient such as corn, and does have proper quality control measures in place (e.g. proper cleaning of machinery and storage containers to prevent cross contamination) then other products may not be affected. If they do not have adequate measures in place (or failed to follow them) it is possible other products will be affected.
In either case, the question still remains: how did the contaminated food end up in the marketplace to begin with? Was it because they were not inbound testing raw ingredients, or outbound testing the final product or both? We’ll have to wait and see.[vc_single_image image=”4225″ img_size=”large”]Original Recalled Products: Date accessed: 11 January 2021 https://www.fda.gov/animal-veterinary/outbreaks-and-advisories/fda-alert-certain-lots-sportmix-pet-food-recalled-potentially-fatal-levels-aflatoxin[vc_single_image image=”4226″ img_size=”large”]Second Recall (January 11, 2021) Date accessed: 11 January 2021 https://www.fda.gov/animal-veterinary/outbreaks-and-advisories/fda-alert-certain-lots-sportmix-pet-food-recalled-potentially-fatal-levels-aflatoxin[vc_single_image image=”4227″ img_size=”large”]Date code example: Date accessed 11 January 2021 https://www.fda.gov/animal-veterinary/outbreaks-and-advisories/fda-alert-certain-lots-sportmix-pet-food-recalled-potentially-fatal-levels-aflatoxinAbout the Author
Nicole is the founder & owner of award winning NorthPoint Pets & Company, in Connecticut. She is also the Founder & CEO of Undogmatic Inc. 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 the human and pet health industry. She regularly lectures at national conferences, including federal, state, and municipal K9 events. Her current research involves identifying pathogenic risk factors and transmission among raw fed pets through a comprehensive worldwide survey.
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